Energy Conservation Program: Energy Conservation Standards for Automatic Commercial Ice Makers, 4645-4756 [2015-00326]
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Vol. 80
Wednesday,
No. 18
January 28, 2015
Part II
Department of Energy
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10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for
Automatic Commercial Ice Makers; Final Rule
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket Number EERE–2010–BT–STD–
0037]
RIN 1904–AC39
Energy Conservation Program: Energy
Conservation Standards for Automatic
Commercial Ice Makers
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Final rule.
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 automatic commercial
icemakers (ACIM). EPCA also requires
the U.S. Department of Energy (DOE) to
determine whether more-stringent
standards would be technologically
feasible and economically justified, and
would save a significant amount of
energy. In this final rule, DOE is
adopting more-stringent energy
conservation standards for some classes
of automatic commercial ice makers as
well as establishing energy conservation
standards for other classes of automatic
commercial ice makers. It has
determined that the amended energy
conservation standards for these
products would result in significant
conservation of energy, and are
technologically feasible and
economically justified.
DATES: The effective date of this rule is
March 30, 2015. Compliance with the
amended standards established for
automatic commercial ice makers in this
final rule is required on January 28,
2018.
ADDRESSES: The docket, which includes
Federal Register notices, public meeting
attendee lists and transcripts,
comments, and other supporting
documents/materials, is available for
review at www.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://www.regulations.gov/#
!docketDetail;D=EERE-2010-BT-STD0037.
The regulations.gov Web page will
contain simple instructions on how to
access all documents, including public
comments, in the docket.
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SUMMARY:
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For further information on how to
review the docket, contact Ms. Brenda
Edwards at (202) 586–2945 or by email:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
John Cymbalsky, 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) 287–1692. Email:
commercial_ice_makers@EE.Doe.Gov.
Ms. Sarah Butler, U.S. Department of
Energy, Office of the General Counsel,
Mailstop GC–71, 1000 Independence
Avenue SW., Washington, DC 20585–
0121. Telephone: (202) 586–1777.
Email: Sarah.Butler@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Discussion of the Final Rule and Its
Benefits
A. Benefits and Costs to Customers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for
Automatic Commercial Ice Makers
III. General Discussion
A. Equipment Classes and Scope of
Coverage
B. Test Procedure
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible
Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and
Commercial Customers
b. Savings in Operating Costs Compared to
Increase in Price (Life Cycle Costs)
c. Energy Savings
d. Lessening of Utility or Performance of
Equipment
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 of
Comments
A. General Rulemaking Issues
1. Proposed Standard Levels
2. Compliance Date
3. Negotiated Rulemaking
4. Refrigerant Regulation
5. Data Availability
6. Supplemental Notice of Proposed
Rulemaking.
7. Rulemaking Structure Comments
B. Market and Technology Assessment
1. Equipment Classes
a. Cabinet Size
b. Large-Capacity Batch Ice Makers
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c. Regulation of Potable Water Use
d. Regulation of Condenser Water Use
e. Continuous Models
f. Gourmet Ice Machines
2. Technology Assessment
a. Alternative Refrigerants
C. Screening Analysis
a. General Comments
b. Drain Water Heat Exchanger
c. Tube Evaporator Design
d. Low Thermal Mass Evaporator Design
e. Microchannel Heat Exchangers
f. Smart Technologies
g. Motors
D. Engineering Analysis
1. Representative Equipment for Analysis
2. Efficiency Levels
a. Baseline Efficiency Levels
b. Incremental Efficiency Levels
c. IMH–A-Large–B Treatment
d. Maximum Available Efficiency
Equipment
e. Maximum Technologically Feasible
Efficiency Levels
3. Design Options
a. Design Options that Need Cabinet
Growth
b. Improved Condenser Performance
c. Compressors
d. Evaporator
e. Interconnectedness of Automatic
Commercial Ice Maker System
4. Cost Assessment Methodology
a. Manufacturing Cost
b. Energy Consumption Model
c. Revision of NOPR and NODA
Engineering Analysis
E. Markups Analysis
F. Energy Use Analysis
G. Life-Cycle Cost and Payback Period
Analysis
1. Equipment Cost
2. Installation, Maintenance, and Repair
Costs
a. Installation Costs
b. Repair and Maintenance Costs
3. Annual Energy and Water Consumption
4. Energy Prices
5. Energy Price Projections
6. Water Prices
7. Discount Rates
8. Lifetime
9. Compliance Date of Standards
10. Base-Case and Standards-Case
Efficiency Distributions
11. Inputs to Payback Period Analysis
12. Rebuttable Presumption Payback
Period
H. National Impact Analysis—National
Energy Savings and Net Present Value
1. Shipments
2. Forecasted Efficiency in the Base Case
and Standards Cases
3. National Energy Savings
4. Net Present Value of Customer Benefit
I. Customer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model
a. Government Regulatory Impact Model
Key Inputs
b. Government Regulatory Impact Model
Scenarios
3. Discussion of Comments
a. Conversion Costs
b. Cumulative Regulatory Burden
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c. SNAP and Compliance Date
Considerations
d. ENERGY STAR
e. Request for DOE and EPA Collaboration
f. Compliance With Refrigerant Changes
Could Be Difficult
g. Small Manufacturers
h. Large Manufacturers
i. Negative Impact on Market Growth
j. Negative Impact on Non-U.S. Sales
k. Employment
l. Compliance With 12866 and 13563
m. Warranty Claims
n. Impact to Suppliers, Distributors,
Dealers, and Contractors
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other
Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Development of Social Cost of Carbon
Values
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions
Reductions
M. Utility Impact Analysis
N. Employment Impact Analysis
O. Regulatory Impact Analysis
V. Analytical Results
A. Trial Standard Levels
1. Trial Standard Level Formulation
Process and Criteria
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 Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Amount and Significance of Energy
Savings
b. Net Present Value of Customer Costs and
Benefits
c. Water Savings
d. Indirect 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. Conclusions/Proposed Standard
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866
and 13563
B. Review Under the Regulatory Flexibility
Act
1. Description and Estimated Number of
Small Entities Regulated
2. Description and Estimate of Compliance
Requirements
3. Duplication, Overlap, and Conflict With
Other Rules and Regulations
4. Significant Alternatives to the Rule
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
M. Congressional Notification
VII. Approval of the Office of the Secretary
I. Discussion of the Final Rule and Its
Benefits
Title III, Part C 1 of the Energy Policy
and Conservation Act of 1975 (EPCA or
the Act), Public Law 94–163 (42 U.S.C.
6311–6317, as codified), established the
Energy Conservation Program for
Certain Industrial Equipment, a program
covering certain industrial equipment,2
which includes the focus of this final
rule: Automatic commercial ice makers
(ACIM).
Pursuant to EPCA, any new or
amended energy conservation standard
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that DOE prescribes for certain
products, such as automatic commercial
ice makers, shall be designed to achieve
the maximum improvement in energy
efficiency that DOE determines is both
technologically feasible and
economically justified. (42 U.S.C.
6295(o)(2)(A)) Furthermore, the new or
amended standard must result in
significant conservation of energy. (42
U.S.C. 6295(o)(3)(B) and 6313(d)(4))
In accordance with these and other
statutory criteria discussed in this final
rule, DOE is amending energy
conservation standards for automatic
commercial ice makers,3 and new
standards for covered equipment not yet
subject to energy conservation
standards. The amended standards,
which consist of maximum allowable
energy use per 100 lb of ice production,
are shown in Table I.1 and Table I.2.
Standards shown on Table I.1 for batch
type ice makers represent the
amendments to existing standards set
for cube type ice makers at 42 U.S.C.
6313(d)(1), and new standards for cube
type ice makers with expanded harvest
capacities up to 4,000 pounds of ice per
24 hour period (lb ice/24 hours) and an
explicit coverage of other types of batch
machines, such as tube type ice makers.
Table I.2 provides new standards for
continuous type ice-making machines,
which were not previously currently
covered by DOE’s existing standards.
The amended standards include, for
applicable equipment classes, maximum
condenser water usage values in gallons
per 100 lb of ice production. These new
and amended standards apply to all
equipment manufactured in, or
imported into, the United States, on or
after January 28, 2018. (42 U.S.C.
6313(d)(2)(B)(i) and (3)(C)(i))
TABLE I.1—ENERGY CONSERVATION STANDARDS FOR BATCH TYPE AUTOMATIC COMMERCIAL ICEMAKERS
[Compliance required starting January 28, 2018]
Type of cooling
Harvest rate
lb ice/24 hours
Ice-Making Head .......................................................
Water ................
Ice-Making Head .......................................................
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Equipment type
Air .....................
<300
≥300 and <850
≥850 and <1,500
≥1,500 and <2,500
≥2,500 and <4,000
<300
≥300 and <800
≥800 and <1,500
≥1500 and <4,000
1 For editorial reasons, upon codification in the
U.S. Code, Part C was re-designated Part A–1.
2 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).
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3 EPCA as amended by EPACT 2005 established
maximum energy use and maximum condenser
water use standards for cube type automatic
commercial ice makers with harvest capacities
between 50 and 2,500 lb ice/24 hours. In this
rulemaking, DOE is amending the legislated energy
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Maximum energy use
kilowatt-hours (kWh)/
100 lb ice *
Maximum condenser
water use
gal/100 lb ice **
6.88—0.0055H
5.80—0.00191H
4.42—0.00028H
4.0
4.0
10—0.01233H
7.05—0.0025H
5.55—0.00063H
4.61
200—0.022H.
200—0.022H.
200—0.022H.
200—0.022H.
145.
NA.
NA.
NA.
NA.
use standards for these automatic commercial ice
maker types. DOE is not, however, amending the
existing condenser water use standards for
equipment with existing condenser water
standards.
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TABLE I.1—ENERGY CONSERVATION STANDARDS FOR BATCH TYPE AUTOMATIC COMMERCIAL ICEMAKERS—Continued
[Compliance required starting January 28, 2018]
Equipment type
Type of cooling
Harvest rate
lb ice/24 hours
Remote Condensing (but not remote compressor) ..
Air .....................
Remote Condensing and Remote Compressor .......
Air .....................
Self-Contained ..........................................................
Water ................
Self-Contained ..........................................................
Air .....................
≥50 and <1,000
≥1,000 and <4,000
<942
≥942 and <4,000
<200
≥200 and <2,500
≥2,500 and <4,000
<110
≥110 and <200
≥200 and <4,000
Maximum energy use
kilowatt-hours (kWh)/
100 lb ice *
Maximum condenser
water use
gal/100 lb ice **
7.97—0.00342H
4.55
7.97—0.00342H
4.75
9.5—0.019H
5.7
5.7
14.79—0.0469H
12.42—0.02533H
7.35
NA.
NA.
NA.
NA.
191—0.0315H.
191—0.0315H.
112.
NA.
NA.
NA.
* H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
** Water use is for the condenser only and does not include potable water used to make ice.
TABLE I.2—ENERGY CONSERVATION STANDARDS FOR CONTINUOUS TYPE AUTOMATIC COMMERCIAL ICE MAKERS
[Compliance required starting January 28, 2018]
Equipment type
Type of cooling
Harvest rate
lb ice/24 hours
Ice-Making Head .......................................................
Water ................
Ice-Making Head .......................................................
Air .....................
Remote Condensing (but not remote compressor) ..
Air .....................
Remote Condensing and Remote Compressor .......
Air .....................
Self-Contained ..........................................................
Water ................
Self-Contained ..........................................................
Air .....................
<801
≥801 and <2,500
≥2,500 and <4,000
<310
≥310 and <820
≥820 and <4,000
<800
≥800 and <4,000
<800
≥800 and <4,000
<900
≥900 and <2,500
≥2,500 and <4,000
<200
≥200 and <700
≥700 and <4,000
Maximum energy use
kWh/100 lb ice *
Maximum condenser
water use
gal/100 lb ice **
6.48—0.00267H
4.34
4.34
9.19—0.00629H
8.23—0.0032H
5.61
9.7—0.0058H
5.06
9.9—0.0058H
5.26
7.6—0.00302H
4.88
4.88
14.22—0.03H
9.47—0.00624H
5.1
180—0.0198H.
180—0.0198H.
130.5.
NA.
NA.
NA.
NA.
NA.
NA.
NA.
153—0.0252H.
153—0.0252H.
90.
NA.
NA.
NA.
* H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
** Water use is for the condenser only and does not include potable water used to make ice.
A. Benefits and Costs to Customers
Table I.3 presents DOE’s evaluation of
the economic impacts of the standards
set by this final rule on customers of
automatic commercial ice makers, as
measured by the average life-cycle cost
(LCC) savings 4 and the median payback
period (PBP).5 The average LCC savings
are positive for all equipment classes for
which customers are impacted by the
new and amended standards.
TABLE I.3—IMPACTS OF TODAY’S STANDARDS ON CUSTOMERS OF AUTOMATIC COMMERCIAL ICE MAKERS
Average LCC
savings
2013$
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Equipment class *
IMH–W–Small–B ..............................................................................................................................................
IMH–W–Med–B ................................................................................................................................................
IMH–W–Large–B ** ..........................................................................................................................................
IMH–W–Large–B–1 ..................................................................................................................................
IMH–W–Large–B–2 ..................................................................................................................................
IMH–A–Small–B ...............................................................................................................................................
IMH–A–Large–B ** ...........................................................................................................................................
IMH–A–Large–B–1 ...................................................................................................................................
IMH–A–Large–B–2 ...................................................................................................................................
RCU–Large–B ** ..............................................................................................................................................
4 Life-cycle cost of automatic commercial ice
makers 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
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energy conservation standards when compared to
the life-cycle costs of the equipment in the absence
of amended energy conservation standards.
5 Payback period refers to the amount of time (in
years) it takes customers to recover the increased
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214
308
NA
NA
NA
77
361
407
110
748
Median PBP
years
2.7
2.1
NA
NA
NA
4.7
2.3
1.5
6.9
1.1
installed cost of equipment associated with new or
amended standards through savings in operating
costs. Further discussion can be found in chapter
8 of the final rule TSD.
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TABLE I.3—IMPACTS OF TODAY’S STANDARDS ON CUSTOMERS OF AUTOMATIC COMMERCIAL ICE MAKERS—Continued
Average LCC
savings
2013$
Equipment class *
RCU–Large–B–1 ......................................................................................................................................
RCU–Large–B–2 ......................................................................................................................................
SCU–W–Large–B ............................................................................................................................................
SCU–A–Small–B ..............................................................................................................................................
SCU–A–Large–B .............................................................................................................................................
IMH–A–Small–C ..............................................................................................................................................
IMH–A–Large–C ..............................................................................................................................................
RCU–Small–C ..................................................................................................................................................
SCU–A–Small–C .............................................................................................................................................
743
820
550
281
439
313
626
505
290
Median PBP
years
0.9
3.0
1.8
2.6
2.1
1.7
0.7
1.2
1.5
* Abbreviations are: IMH is ice-making head; RCU is remote condensing unit; SCU is self-contained unit; W is water-cooled; A is air-cooled;
Small refers to the lowest harvest category; Med refers to the Medium category (water-cooled IMH only); RCU with and without remote compressor were modeled as one group. For three large batch categories, a machine at the low end of the harvest range (B–1) and a machine at
the higher end (B–2) were modeled. Values are shown only for equipment classes that have significant volume of shipments and, therefore, were
directly analyzed. See chapter 5 of the final rule technical support document, ‘‘Engineering Analysis,’’ for a detailed discussion of equipment
classes analyzed.
** LCC savings and PBP results for these classes are weighted averages of the typical units modeled for the large classes, using weights provided in TSD chapter 7.
DOE’s analyses indicate that the
amended standards for automatic
commercial ice makers would save a
significant amount of energy. The
lifetime energy savings for equipment
purchased in the 30-year period that
begins in the year of compliance with
amended and new standards (2018–
2047), 7 relative to the base case without
amended standards, amount to 0.18
quadrillion British thermal units (quads)
of cumulative energy. This represents a
savings of 8 percent relative to the
energy use of these products in the base
case.
The cumulative national net present
value (NPV) of total customer savings of
the amended standards for automatic
commercial ice makers in 2013$ ranges
from $0.430 billion (at a 7-percent
discount rate) to $0.942 billion (at a 3percent discount rate 8). This NPV
expresses the estimated total value of
future operating cost savings minus the
estimated increased installed costs for
equipment purchased in the period from
2018–2047, discounted back to the
current year (2014).
In addition, the amended standards
are expected to have significant
environmental benefits. The energy
savings described above are estimated to
result in cumulative emission
reductions of 10.9 million metric tons
(MMt) 9 of carbon dioxide (CO2), 16.2
thousand tons of nitrogen oxides (NOX),
0.1 thousand tons of nitrous oxide
(N2O), 47.4 thousand tons of methane
(CH4), 0.03 tons of mercury (Hg),10 and
9.3 thousand tons of sulfur dioxide
(SO2) based on energy savings from
equipment purchased over the period
from 2018–2047.11 The cumulative
reduction in CO2 emissions through
2030 amounts to 4 MMt, which is
equivalent to the emissions resulting
from the annual electricity use of over
half a million homes.
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 a recent Federal
interagency process.12 The derivation of
the SCC value is discussed in section
IV.L. Using discount rates appropriate
for each set of SCC values, DOE
estimates the net present monetary
value of the CO2 emissions reduction is
between $0.08 and $1.11 billion,
expressed in 2013$ and discounted to
2014, with a value of $0.36 billion using
the central SCC case represented by
$40.5/t in 2015. DOE also estimates the
net present monetary value of the NOX
emissions reduction, expressed in 2013$
and discounted to 2014, is between $2.1
and $22.0 million at a 7-percent
discount rate, and between $4.2 and
$43.4 million at a 3-percent discount
rate.13
Table I.4 summarizes the national
economic costs and benefits expected to
result from these new and amended
standards for automatic commercial ice
makers.
6 All dollar values presented are in 2013$
discounted back to the year 2014.
7 The standards analysis period for national
benefits covers the 30-year period, plus the life of
equipment purchased during the period. 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.
8 These discount rates are used in accordance
with the Office of Management and Budget (OMB)
guidance to Federal agencies on the development of
regulatory analysis (OMB Circular A–4, September
17, 2003), and section E, ‘‘Identifying and
Measuring Benefits and Costs,’’ therein. Further
details are provided in section IV.J.
9 A metric ton is equivalent to 1.1 U.S. short tons.
Results for NOX, Hg, and SO2 are presented in short
tons.
10 DOE calculates emissions reductions relative to
the Annual Energy Outlook 2014 (AEO2014)
Reference Case, which generally represents current
legislation and environmental regulations for which
implementing regulations were available as of
October 31, 2013.
11 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 3.9 million metric tons CO2, 395 thousand tons
CO2eq for CH4, and 12 thousand tons CO2eq for
N2O.
12 https://www.whitehouse.gov/sites/default/files/
omb/assets/inforeg/technical-update-social-cost-ofcarbon-for-regulator-impact-analysis.pdf.
13 DOE has decided to await further guidance
regarding consistent valuation and reporting of Hg
emissions before it monetizes Hg in its rulemakings.
B. Impact on Manufacturers 6
The industry net present value (INPV)
is the sum of the discounted cash flows
to the industry from 2015 through the
end of the analysis period in 2047.
Using a real discount rate of 9.2 percent,
DOE estimates that the INPV for
manufacturers of automatic commercial
ice makers is $121.6 million in 2013$.
Under the amended standards, DOE
expects that manufacturers may lose up
to 12.5 percent of their INPV, or
approximately $15.1 million.
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C. National Benefits and Costs
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TABLE I.4—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF AMENDED AUTOMATIC COMMERCIAL ICE
MAKERS ENERGY CONSERVATION STANDARDS *
Present value
million 2013$
Category
Discount rate
(%)
Benefits
Operating Cost Savings ...................................................................................................................................
CO2 at 5% dr, average ....................................................................................................................................
CO2 at 3% dr, average ....................................................................................................................................
CO2 at 2.5% dr, average .................................................................................................................................
CO2 at 3% dr, 95th perc ..................................................................................................................................
NOX Reduction Monetized Value (at $2,684/Ton) ** .......................................................................................
Total Benefits † ................................................................................................................................................
654
1,353
80
361
570
1,113
12
24
1,027
1,738
7
3
5
3
2.5
3
7
3
7
3
224
411
7
3
803
1,326
7
3
Costs
Incremental Installed Costs .............................................................................................................................
Net Benefits
Including CO2 and NOX Reduction Monetized Value .....................................................................................
* The CO2 values represent global monetized values of the SCC in 2013$ in year 2015 under several scenarios. The values of $12, $40.5, and
$62.4 per metric ton (t) are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively.
The value of $119.0/t represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The SCC time series
used by DOE incorporate an escalation factor.
** 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 the 7-percent cases are derived using the series corresponding to SCC value of $40.5/t.
mstockstill on DSK4VPTVN1PROD with RULES2
The benefits and costs of these new
and amended standards, for automatic
commercial ice makers sold in 2018–
2047, 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 the operation of
equipment that meets the amended
standards (consisting primarily of
operating cost savings from using less
energy and water, minus increases in
equipment installed cost, which is
another way of representing customer
NPV); and (2) the annualized monetary
value of the benefits of emission
reductions, including CO2 emission
reductions.14
Although adding the values of
operating savings to the values of
14 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 2014, 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 3 and 7 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.4. From the present value, DOE then
calculated the fixed annual payment over a 30-year
period (2018 through 2047) 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.
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emission reductions provides an
important perspective, two issues
should be considered. First, the national
operating savings are domestic U.S.
customer monetary savings that occur as
a result of market transactions, whereas
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 over the lifetimes of
automatic commercial ice makers
shipped from 2018 to 2047. The SCC
values, on the other hand, reflect the
present value of some future climaterelated impacts resulting from the
emission of 1 ton of CO2 in each year.
These impacts continue well beyond
2100.
Estimates of annualized benefits and
costs of the amended standards are
shown in Table I.5. (All monetary
values below are expressed in 2013$.)
Table I.5 shows the primary, low net
benefits, and high net benefits scenarios.
The primary estimate is the estimate in
which the operating cost savings were
calculated using the Annual Energy
Outlook 2014 (AEO2014) Reference Case
forecast of future electricity prices. The
low net benefits estimate and the high
net benefits estimate are based on the
low and high electricity price scenarios
from the AEO2014 forecast,
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respectively.15 Using a 7-percent
discount rate for benefits and costs, the
cost in the primary estimate of the
standards amended in this rule is $22
million per year in increased equipment
costs. (Note that DOE used a 3-percent
discount rate along with the
corresponding SCC series value of
$40.5/ton in 2013$ to calculate the
monetized value of CO2 emissions
reductions.) The annualized benefits are
$65 million per year in reduced
equipment operating costs, $20 million
in CO2 reductions, and $1.19 million in
reduced NOX emissions. In this case, the
annualized net benefit amounts to $64
million. At a 3-percent discount rate for
all benefits and costs, the cost in the
primary estimate of the amended
standards presented in this rule is $23
million per year in increased equipment
costs. The benefits are $75 million per
year in reduced operating costs, $20
million in CO2 reductions, and $1.33
million in reduced NOX emissions. In
this case, the net benefit amounts to $74
million per year.
DOE also calculated the low net
benefits and high net benefits estimates
15 The AEO2014 scenarios used are the ‘‘High
Economics’’ and ‘‘Low Economics’’ scenarios.
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by calculating the operating cost savings
and shipments at the AEO2014 low
economic growth case and high
economic growth case scenarios,
respectively. The low and high benefits
for incremental installed costs were
derived using the low and high price
learning scenarios. The net benefits and
costs for low and high net benefits
estimates were calculated in the same
4651
manner as the primary estimate by using
the corresponding values of operating
cost savings and incremental installed
costs.
TABLE I.5—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR AUTOMATIC COMMERCIAL ICE MAKERS *
Low net
benefits
estimate *
million 2013$
Primary
estimate*
million 2013$
Discount rate
(%)
High net
benefits
estimate *
million 2013$
Benefits
Operating Cost Savings ...................................................................
7
3
5
3
2.5
3
7
3
68
80
6
21
30
64
1.22
1.36
86
97
82
92
90
102
7
3
Total Benefits (Operating Cost Savings, CO2 Reduction and NOX
Reduction) † .................................................................................
62
71
6
20
28
60
1.16
1.29
7
3
CO2 at 5% dr, average ** .................................................................
CO2 at 3% dr, average ** .................................................................
CO2 at 2.5% dr, average ** ..............................................................
CO2 at 3% dr, 95th perc ** ..............................................................
NOX Reduction Monetized Value (at $2,684/Ton) ** .......................
65
75
6
20
29
62
1.19
1.33
22
23
23
24
21
22
64
74
60
68
69
80
Costs
Total Incremental Installed Costs ....................................................
Net Benefits Less Costs
Total Benefits Less Incremental Costs ............................................
7
3
* The primary, low, and high estimates utilize forecasts of energy prices from the AEO2014 Reference Case, Low Economic Growth Case, and
High Economic Growth Case, respectively.
** These values represent global values (in 2013$) of the social cost of CO2 emissions in 2015 under several scenarios. The values of $12,
$40.5, and $62.4 per ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $119.0 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. See section
IV.L for details. For NOX, an average value ($2,684) of the low ($476) and high ($4,893) values was used.
† Total monetary benefits for both the 3-percent and 7-percent cases utilize the central estimate of social cost of NOX and CO2 emissions calculated at a 3-percent discount rate (averaged across three integrated assessment models), which is equal to $40.5/ton (in 2013$).
D. Conclusion
Based on the analyses culminating in
this final rule, DOE found the benefits
to the nation of the amended standards
(energy savings, consumer LCC savings,
positive NPV of consumer benefit, and
emission reductions) outweigh the
burdens (loss of INPV and LCC
increases for some users of this
equipment). DOE has concluded that the
standards in this final rule represent the
maximum improvement in energy
efficiency that is both technologically
feasible and economically justified, and
would result in significant conservation
of energy. (42 U.S.C. 6295(o),
6313(d)(4))
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II. Introduction
The following section briefly
discusses the statutory authority
underlying this final rule, as well as
some of the relevant historical
background related to the establishment
of amended standards for automatic
commercial ice makers.
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A. Authority
Title III, Part C 16 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 automatic commercial
ice makers, the focus of this rule.17
EPCA prescribed energy conservation
standards for automatic commercial ice
makers that produce cube type ice with
capacities between 50 and 2,500 lb ice/
24 hours. (42 U.S.C. 6313(d)(1)) EPCA
requires DOE to review these standards
and determine, by January 1, 2015,
whether amending the applicable
standards is technically feasible and
economically justified. (42 U.S.C.
6313(d)(3)(A)) If amended standards are
16 For editorial reasons, upon codification in the
U.S. Code, Part C was re-designated Part A–1.
17 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).
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technically feasible and economically
justified, DOE must issue a final rule by
the same date. (42 U.S.C. 6313(d)(3)(B))
Additionally, EPCA granted DOE the
authority to conduct rulemakings to
establish new standards for automatic
commercial ice makers not covered by
42 U.S.C. 6313(d)(1)), and DOE is using
that authority in this rulemaking. (42
U.S.C. 6313(d)(2)(A))
Pursuant to EPCA, 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 automatic commercial
ice makers, DOE is responsible for the
entirety of this program. Subject to
certain criteria and conditions, DOE is
required to develop test procedures to
measure the energy efficiency, energy
use, or estimated annual operating cost
of each type or class of covered
equipment. (42 U.S.C. 6314)
Manufacturers of covered equipment
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must use the prescribed DOE test
procedure as the basis for certifying to
DOE that their equipment complies with
the applicable energy conservation
standards adopted under EPCA and
when making representations to the
public regarding the energy use or
efficiency of that equipment. (42 U.S.C.
6315(b), 6295(s)) Similarly, DOE must
use these test procedures to determine
whether that equipment complies with
standards adopted pursuant to EPCA.
The DOE test procedure for automatic
commercial ice makers currently
appears at title 10 of the Code of Federal
Regulations (CFR) part 431, subpart H.
DOE must follow specific statutory
criteria for prescribing amended
standards for covered equipment. As
indicated above, any amended standard
for covered equipment must be designed
to achieve the maximum improvement
in energy efficiency that is
technologically feasible and
economically justified. (42 U.S.C.
6295(o)(2)(A) and 6313(d)(4))
Furthermore, DOE may not adopt any
standard that would not result in the
significant conservation of energy. (42
U.S.C. 6295(o)(3) and 6313(d)(4)) DOE
also may not prescribe a standard: (1)
For certain equipment, including
automatic commercial ice makers, if no
test procedure has been established for
the product; or (2) if DOE determines,
by rule that such standard is not
technologically feasible or economically
justified. (42 U.S.C. 6295(o)(3)(A)–(B)
and 6313(d)(4)) In deciding whether a
proposed standard is economically
justified, DOE must determine whether
the benefits of the standard exceed its
burdens. (42 U.S.C. 6295(o)(2)(B)(i) and
6313(d)(4)) DOE must make this
determination after receiving comments
on the proposed standard, and by
considering, to the greatest extent
practicable, the following seven factors:
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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
U.S. Attorney General (Attorney General),
that is likely to result from the imposition of
the standard;
6. The need for national energy and water
conservation; and
7. Other factors the Secretary considers
relevant.
(42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII) and
6313(d)(4))
EPCA, as codified, also contains what
is known as an ‘‘anti-backsliding’’
provision, which prevents the Secretary
from prescribing any amended standard
that either increases the maximum
allowable energy use or decreases the
minimum required energy efficiency of
covered equipment. (42 U.S.C.
6295(o)(1) and 6313(d)(4)) Also, the
Secretary may not 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.
(42 U.S.C. 6295(o)(4) and 6313(d)(4))
Further, EPCA, as codified,
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 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) and 6313(d)(4) Section
III.E.2 presents additional discussion
about the rebuttable presumption
payback period.
Additionally, 42 U.S.C. 6295(q)(1) and
6316(a) specifies requirements when
promulgating a standard for a type or
class of covered equipment that has two
or more subcategories that may justify
different standard levels. DOE must
specify a different standard level than
that which applies generally to such
type or class of equipment for any group
of covered products that has the same
function or intended use if DOE
determines that products within such
group (A) consume a different kind of
energy from that consumed by other
covered equipment within such type (or
class); or (B) have a capacity or other
performance-related feature that other
equipment within such type (or class)
do not have and such feature justifies a
higher or lower standard. (42 U.S.C.
6295(q)(1)) and 6316(a)) In determining
whether a performance-related feature
justifies a different standard for a group
of equipment, DOE must consider such
factors as the utility to the consumer of
the feature and other factors DOE deems
appropriate. Id. Any rule prescribing
such a standard must include an
explanation of the basis on which such
higher or lower level was established.
(42 U.S.C. 6295(q)(2)) and 6316(a))
Federal energy conservation
requirements generally supersede State
laws or regulations concerning energy
conservation testing, labeling, and
standards. (42 U.S.C. 6297(a)–(c) and
6316(f)) DOE may, however, grant
waivers of Federal preemption for
particular State laws or regulations in
accordance with the test procedures and
other provisions set forth under 42
U.S.C. 6297(d) and 6316(f).
B. Background
1. Current Standards
In a final rule published on October
18, 2005, DOE adopted the energy
conservation standards and water
conservation standards prescribed by
EPCA in 42 U.S.C. 6313(d)(1) for certain
automatic commercial ice makers
manufactured on or after January 1,
2010. 70 FR 60407, 60415–16. These
standards consist of maximum energy
use and maximum condenser water use
to produce 100 pounds of ice for
automatic commercial ice makers with
harvest rates between 50 and 2,500 lb
ice/24 hours. These standards appear at
10 CFR part 431, subpart H, Automatic
Commercial Ice Makers. Table II.1
presents DOE’s current energy
conservation standards for automatic
commercial ice makers.
TABLE II.1—AUTOMATIC COMMERCIAL ICE MAKERS STANDARDS PRESCRIBED BY EPCA—COMPLIANCE REQUIRED
BEGINNING ON JANUARY 1, 2010
Equipment type
Type of cooling
Ice-Making Head .......................................................
Water ................
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Harvest rate
lb ice/24 hours
<500
≥500 and <1,436
Sfmt 4700
Maximum energy use
kWh/100 lb ice
Maximum condenser
water use *
gal/100 lb ice
7.8–0.0055H **
5.58–0.0011H
200–0.022H.**
200–0.022H.
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4653
TABLE II.1—AUTOMATIC COMMERCIAL ICE MAKERS STANDARDS PRESCRIBED BY EPCA—COMPLIANCE REQUIRED
BEGINNING ON JANUARY 1, 2010—Continued
Equipment type
Type of cooling
Air .....................
Remote Condensing (but not remote compressor) ..
Air .....................
Remote Condensing and Remote Compressor .......
Air .....................
Self-Contained ..........................................................
Water ................
Air .....................
≥1,436
<450
≥450
<1,000
≥1,000
<934
≥934
<200
≥200
<175
≥175
Maximum energy use
kWh/100 lb ice
Maximum condenser
water use *
gal/100 lb ice
4.0
10.26–0.0086H
6.89–0.0011H
8.85–0.0038H
5.10
8.85–0.0038H
5.30
11.4–0.019H
7.60
18.0–0.0469H
9.80
Harvest rate
lb ice/24 hours
200–0.022H.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
191–0.0315H.
191–0.0315H.
Not Applicable.
Not Applicable.
mstockstill on DSK4VPTVN1PROD with RULES2
Source: 42 U.S.C. 6313(d).
* Water use is for the condenser only and does not include potable water used to make ice.
** H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.
2. History of Standards Rulemaking for
Automatic Commercial Ice Makers
As stated above, EPCA prescribes
energy conservation standards and
water conservation standards for certain
cube type automatic commercial ice
makers with harvest rates between 50
and 2,500 lb ice/24 hours: Selfcontained ice makers and ice-making
heads (IMHs) using air or water for
cooling and ice makers with remote
condensing with or without a remote
compressor. Compliance with these
standards was required as of January 1,
2010. (42 U.S.C. 6313(d)(1)) DOE
adopted these standards and placed
them under 10 CFR part 431, subpart H,
Automatic Commercial Ice Makers.
In addition, EPCA requires DOE to
conduct a rulemaking to determine
whether to amend the standards
established under 42 U.S.C. 6313(d)(1),
and if DOE determines that amendment
is warranted, DOE must also issue a
final rule establishing such amended
standards by January 1, 2015. (42 U.S.C.
6313(d)(3)(A))
Furthermore, EPCA granted DOE
authority to set standards for additional
types of automatic commercial ice
makers that are not covered in 42 U.S.C.
6313(d)(1). (42 U.S.C. 6313(d)(2)(A))
Additional types of automatic
commercial ice makers DOE identified
as candidates for standards to be
established in this rulemaking include
flake and nugget, as well as batch type
ice makers that are not included in the
EPCA definition of cube type ice
makers.
To satisfy its requirement to conduct
a rulemaking, DOE initiated the current
rulemaking on November 4, 2010 by
publishing on its Web site its
‘‘Rulemaking Framework for Automatic
Commercial Ice Makers.’’ The
Framework document is available at:
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https://www.regulations.gov/#!document
Detail;D=EERE-2010-BT-STD-00370024.
DOE also published a notice in the
Federal Register announcing the
availability of the Framework
document, as well as a public meeting
to discuss the document. The notice
also solicited comment on the matters
raised in the document. 75 FR 70852
(Nov. 19, 2010). The Framework
document described the procedural and
analytical approaches that DOE
anticipated using to evaluate amended
standards for automatic commercial ice
makers, and identified various issues to
be resolved in the rulemaking.
DOE held the Framework public
meeting on December 16, 2010, at 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)
equipment classes; (3) analytical
approaches and methods used in the
rulemaking; (4) impacts of standards
and burden on manufacturers; (5)
technology options; (6) distribution
channels, shipments, and end users; (7)
impacts of outside regulations; and (8)
environmental issues. 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
automatic commercial ice makers
relevant to this rulemaking.
DOE then gathered additional
information and performed preliminary
analyses to help review standards for
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this equipment. This process
culminated in DOE publishing a notice
of another public meeting (the January
2012 notice) to discuss and receive
comments regarding the tools and
methods DOE used in performing its
preliminary analysis, as well as the
analyses results. 77 FR 3404 (Jan. 24,
2012) DOE also invited written
comments on these subjects and
announced the availability on its Web
site of a preliminary analysis technical
support document (preliminary analysis
TSD). Id. The preliminary analysis TSD
is available at: www.regulations.gov/#
!documentDetail;D=EERE-2010-BT-STD0037-0026. DOE sought comments
concerning other relevant issues that
could affect amended standards for
automatic commercial ice makers. Id.
The preliminary analysis TSD
provided an overview of DOE’s review
of the standards for automatic
commercial ice makers, discussed the
comments DOE received in response to
the Framework document, and
addressed issues including the scope of
coverage of the rulemaking. The
document also described the analytical
framework that DOE used (and
continues to use) in considering
amended standards for automatic
commercial ice makers, 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 analysis TSD presented
in detail each analysis that DOE had
performed for this equipment up to that
point, including descriptions of inputs,
sources, methodologies, and results.
These analyses were as follows: (1) A
market and technology assessment, (2) a
screening analysis, (3) an engineering
analysis, (4) an energy and water use
analysis, (5) a markups analysis, (6) a
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life-cycle cost analysis, (7) a payback
period analysis, (8) a shipments
analysis, (9) a national impact analysis
(NIA) and (10) a preliminary
manufacturer impact analysis (MIA).
The public meeting announced in the
January 2012 notice took place on
February 16, 2012 (February 2012
preliminary analysis public meeting). At
the February 2012 preliminary analysis
public meeting, DOE presented the
methodologies and results of the
analyses set forth in the preliminary
analysis TSD. Interested parties
provided comments on the following
issues: (1) Equipment classes; (2)
technology options; (3) energy modeling
and validation of engineering models;
(4) cost modeling; (5) market
information, including distribution
channels and distribution markups; (6)
efficiency levels; (7) life-cycle costs to
customers, including installation, repair
and maintenance costs, and water and
wastewater prices; and (8) historical
shipments.
On March 17, 2014, DOE published a
notice of proposed rulemaking (NOPR)
in the Federal Register (March 2014
NOPR). 79 FR 14846. In the March 2014
NOPR, DOE addressed, in detail, the
comments received in earlier stages of
rulemaking, and proposed amended
energy conservation standards for
automatic commercial ice makers. In
conjunction with the March 2014
NOPR, DOE also published on its Web
site the complete technical support
document (TSD) for the proposed rule,
which incorporated the analyses DOE
conducted and technical documentation
for each analysis. Also published on
DOE’s Web site were the engineering
analysis spreadsheets, the LCC
spreadsheet, and the national impact
analysis standard spreadsheet. These
materials are available at: https://www1.
eere.energy.gov/buildings/appliance_
standards/rulemaking.aspx/ruleid/29.
The standards which DOE proposed
for automatic commercial ice makers at
the NOPR stage of this rulemaking are
shown in Table II.2 and Table II.3. They
are provided solely for background
informational purposes and differ from
the amended standards set forth in this
final rule.
TABLE II.2—PROPOSED ENERGY CONSERVATION STANDARDS FOR BATCH TYPE AUTOMATIC COMMERCIAL ICE MAKERS
Equipment type
Type of cooling
Harvest rate
lb ice/24 hours
Ice-Making Head .......................................................
Water ................
Ice-Making Head .......................................................
Air .....................
Remote Condensing (but not remote compressor) ..
Self-Contained ..........................................................
Air .....................
Air .....................
Air .....................
Air .....................
Water ................
Self-Contained ..........................................................
Air .....................
<500
≥500 and <1,436
≥1,436 and <2,500
≥2,500 and <4,000
<450
≥450 and <875
≥875 and <2,210
≥2,210 and <2,500
≥2,500 and <4,000
<1,000
≥1,000 and <4,000
<934
≥934 and <4,000
<200
≥200 and <2,500
≥2,500 and <4,000
<175
≥175 and <4,000
Remote Condensing and Remote Compressor .......
Maximum energy use
kilowatt-hours (kWh)/
100 lb ice *
Maximum condenser
water use
gal/100 lb ice **
5.84—0.0041H
3.88—0.0002H
3.6
3.6
7.70—0.0065H
5.17—0.0008H
4.5
6.89—0.0011H
4.1
7.52—0.0032H
4.3
7.52—0.0032H
4.5
8.55—0.0143H
5.7
5.7
12.6—0.0328H
6.9
200–0.022H.
200–0.022H.
200–0.022H.
145.
NA.
NA.
NA.
NA.
NA.
NA.
NA.
NA.
NA.
191–0.0315H.
191–0.0315H.
112.
NA.
NA.
* H = Harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
** Water use is for the condenser only and does not include potable water used to make ice.
TABLE II.3—PROPOSED ENERGY CONSERVATION STANDARDS FOR CONTINUOUS TYPE AUTOMATIC COMMERCIAL ICE
MAKERS
Type of cooling
Harvest rate
lb ice/24 hours
Ice-Making Head .......................................................
Water ................
Ice-Making Head .......................................................
Air .....................
Remote Condensing (but not remote compressor) ..
Air .....................
Remote Condensing and Remote Compressor .......
Air .....................
Self-Contained ..........................................................
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Equipment type
Water ................
Self-Contained ..........................................................
Air .....................
<900
≥900 and <2,500
≥2,500 and <4,000
<700
≥700 and <4,000
<850
≥850 and <4,000
<850
≥850 and <4,000
<900
≥900 and <2,500
≥2,500 and <4,000
<700
≥700 and <4,000
Maximum energy use
kWh/100 lb ice *
Maximum condenser
water use
gal/100 lb ice **
6.08—0.0025H
3.8
3.8
9.24—0.0061H
5.0
7.5—0.0034H
4.6
7.65—0.0034H
4.8
7.28—0.0027H
4.9
4.9
9.2—0.0050H
5.7
160–0.0176H.
160–0.0176H.
116.
NA.
NA.
NA.
NA.
NA.
NA.
153–0.0252H.
153–0.0252H.
90.
NA.
NA.
* H = Harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
** Water use is for the condenser only and does not include potable water used to make ice.
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In the March 2014 NOPR, DOE
identified nineteen issues on which it
was particularly interested in receiving
comments and views of interested
parties: Standards compliance dates,
utilization factors, baseline efficiency,
screening analysis, maximum
technology feasibility, markups,
equipment life, installation costs, openvs closed loop installations, ice maker
shipments by type of equipment,
intermittency of manufacturer R&D and
impact of standards, INPV results and
impact of standards, small businesses,
consumer utility and performance,
analysis period, social cost of carbon,
remote to rack equipment, design
options associated with each TSD, and
standard levels for batch type ice
makers over 2,500 lb ice/hour. 79 FR
14846 at 14947–49. After the
publication of the March 2014 NOPR,
DOE received written comments on
these and other issues. DOE also held a
public meeting in Washington, DC, on
April 14, 2014, to discuss and receive
comments regarding the tools and
methods DOE used in the NOPR
analysis, as well as the results of the
analysis. DOE also invited written
comments and announced the
availability of a NOPR analysis
technical support document (NOPR
TSD). The NOPR TSD is available at:
https://www.regulations.gov/#!document
Detail;D=EERE-2010-BT-STD-00370061.
The NOPR TSD described in detail
DOE’s analysis of potential standard
levels for automatic commercial ice
makers. The document also described
the analytical framework used in
considering standard levels, including a
description of the methodology, the
analytical tools, and the relationships
between the various analyses. In
addition, the NOPR TSD presented each
analysis that DOE performed to evaluate
automatic commercial ice makers,
including descriptions of inputs,
sources, methodologies, and results.
DOE included the same analyses that
were conducted at the preliminary
analysis stage, with revisions based on
comments received and additional
research.
At the public meeting held on April
14, 2014, DOE presented the
methodologies and results of the
analyses set for in the NOPR TSD.
Interested parties provided comments.
Key issues raised by stakeholders
included: (1) Whether the energy model
accurately predicts efficiency
improvements; (2) the size restrictions
and applications of 22-inch wide ice
makers; (3) the efficiency distributions
assumed for shipments of icemakers;
and (4) the impact on manufacturers
relating to design of icemaker models, in
light of the proposed compliance date of
3 years after publication of the final
rule.
In response to comments regarding
the energy model used in the analysis,
DOE held a public meeting on June 19,
2014 in order to facilitate an additional
review of the energy model, gather
additional feedback and data on the
energy model, and to allow for a more
thorough explanation of DOE’s use of
the model in the engineering analysis.
79 FR 33877 (June 13, 2014). At that
meeting, DOE presented the energy
model, demonstrated its operations, and
described how it was used in the
rulemaking’s engineering analysis. DOE
indicated in this meeting that it was
considering modifications to its NOPR
analyses based on the NOPR comments
and additional research and information
gathering.
On September 11, 2014, DOE
published a notice of data availability
(NODA) in the Federal Register
(September 2014 NODA). 79 FR 54215.
The purpose of the September 2014
NODA was to notify industry,
manufacturers, customer groups,
efficiency advocates, government
agencies, and other stakeholders of the
publication of the updated rulemaking
analysis for new and/or amended energy
conservation standards for automatic ice
makers. The comments received since
the publication of the March 2014
NOPR, including those received at the
April 2014 and the June 2014 public
meetings, provided inputs which led
DOE to revise its analysis. Stakeholders
also submitted additional information to
DOE’s consultant pursuant to nondisclosure agreements regarding
efficiency gains and costs of potential
design options. DOE reviewed
additional market data, including
4655
published ratings of available ice
makers, to recalibrate its engineering
analysis. Generally, the revisions to the
NOPR analysis as specified in the
NODA include modifications of inputs
for its engineering, LCC, and NIA
analyses, adjustments of its energy
model calculations, and more thorough
considerations of size-constrained ice
maker applications. The analysis
revisions addressing size-constrained
applications include development of
engineering analyses for three sizeconstrained equipment categories and
restructuring of the LCC and NIA
analyses to consider size constraints for
applicable equipment classes. DOE
encouraged stakeholders to provide
comments and additional information in
response to the September NODA
publication.
This final rule responds to the issues
raised by commenters for the March
2014 NOPR and the September 2014
NODA.18
III. General Discussion
A. Equipment Classes and Scope of
Coverage
When evaluating and establishing
energy conservation standards, DOE
divides covered equipment into
equipment classes by the type of energy
use or by capacity or other performancerelated features that justifies a different
standard. In making a determination
whether a performance-related feature
justifies a different standard, DOE must
consider such factors as the utility to the
consumer of the feature and other
factors DOE determines are appropriate.
(42 U.S.C. 6295(q)) and 6316(a))
Throughout this rulemaking, DOE’s
analysis has been based on a set of
equipment classes derived from the
existing DOE batch commercial ice
maker standards, effective as of January
1, 2010 (42 U.S.C. 6313(d)(1)) and
review of the existing ice maker market.
These equipment classes form the basis
of analysis and public comments. In this
final rule, equipment class names are
frequently abbreviated. These
abbreviations are shown on Table III.1.
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TABLE III.1—LIST OF EQUIPMENT CLASS ABBREVIATIONS
Abbreviation
Equipment type
Condenser
type
Harvest rate
lb ice/24 hours
IMH–W–Small–B ..........................................
IMH–W–Med–B ............................................
Ice-Making Head ..........................................
Ice-Making Head ..........................................
Water .........
Water .........
<500
≥500 and <1,436
18 A parenthetical reference at the end of a
quotation or paraphrase provides the location of the
item in the public record.
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Ice type
Batch.
Batch.
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE III.1—LIST OF EQUIPMENT CLASS ABBREVIATIONS—Continued
Abbreviation
Equipment type
Condenser
type
IMH–W–Large–B * ........................................
IMH–A–Small–B ...........................................
IMH–A–Large–B * ** (also IMH–A–Large–B–
1).
IMH–A–Extended–B * ** (also
IMH–A–
Large–B–2).
RCU–NRC–Small–B .....................................
Ice-Making Head ..........................................
Ice-Making Head ..........................................
Ice-Making Head ..........................................
Water .........
Air ..............
Air ..............
≥1,436 and <4,000
<450
≥450 and <875
Batch.
Batch.
Batch.
Ice-Making Head ..........................................
Air ..............
≥875 and <4,000
Batch.
Remote Condensing, not Remote Compressor.
Remote Condensing, not Remote Compressor.
Remote Condensing, and Remote Compressor.
Remote Condensing, and Remote Compressor.
Self-Contained Unit ......................................
Self-Contained Unit ......................................
Self-Contained Unit ......................................
Self-Contained Unit ......................................
Ice-Making Head ..........................................
Ice-Making Head ..........................................
Ice-Making Head ..........................................
Ice-Making Head ..........................................
Remote Condensing, not Remote Compressor.
Remote Condensing, not Remote Compressor.
Remote Condensing, and Remote Compressor.
Remote Condensing, and Remote Compressor.
Self-Contained Unit ......................................
Self-Contained Unit ......................................
Self-Contained Unit ......................................
Self-Contained Unit ......................................
Air ..............
<1,000
Batch.
Air ..............
≥1,000 and <4,000
Batch.
Air ..............
<934
Batch.
Air ..............
≥934 and <4,000
Batch.
Water .........
Water .........
Air ..............
Air ..............
Water .........
Water .........
Air ..............
Air ..............
Air ..............
<200
≥200 and
<175
≥175 and
<900
≥900 and
<700
≥700 and
<850
Batch.
Batch.
Batch.
Batch.
Continuous.
Continuous.
Continuous.
Continuous.
Continuous.
Air ..............
≥850 and <4,000
Continuous.
Air ..............
<850
Continuous.
Air ..............
≥850 and <4,000
Continuous.
Water .........
Water .........
Air ..............
Air ..............
<900
≥900 and <4,000
<700
≥700 and <4,000
Continuous.
Continuous.
Continuous.
Continuous.
RCU–NRC–Large–B * ..................................
RCU–RC–Small–B .......................................
RCU–RC–Large–B .......................................
SCU–W–Small–B .........................................
SCU–W–Large–B .........................................
SCU–A–Small–B ..........................................
SCU–A–Large–B ..........................................
IMH–W–Small–C ..........................................
IMH–W–Large–C ..........................................
IMH–A–Small–C ...........................................
IMH–A–Large–C ...........................................
RCU–NRC–Small–C ....................................
RCU–NRC–Large–C ....................................
RCU–RC–Small–C .......................................
RCU–RC–Large–C .......................................
SCU–W–Small–C .........................................
SCU–W–Large–C .........................................
SCU–A–Small–C ..........................................
SCU–A–Large–C ..........................................
Harvest rate
lb ice/24 hours
<4,000
<4,000
<4,000
<4,000
Ice type
* IMH–W–Large–B, IMH–A–Large–B, and RCU–NRC–Large–B were modeled in some final analyses as two different units, one at the lower
end of the harvest range and one near the high end of the harvest range in which a significant number of units are available. In the LCC and
NIA models, the low and high harvest rate models were denoted simply as B–1 and B–2. Where appropriate, the analyses add or perform
weighted averages of the two typical sizes to present class level results.
** IMH–A–Large–B was established by EPACT–2005 as a class between 450 and 2,500 lb ice/24 hours. In this rule, DOE analyzed this class
as two ranges, which could either be considered ‘‘Large’’ and ‘‘Very Large’’ or ‘‘Medium’’ and ‘‘Large.’’ In the LCC and NIA modeling, this was
denoted as B–1 and B–2.
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B. Test Procedure
On December 8, 2006, DOE published
a final rule in which it incorporated by
reference Air-Conditioning and
Refrigeration Institute (ARI) Standard
810–2003, ‘‘Performance Rating of
Automatic Commercial Ice Makers,’’
with a revised method for calculating
energy use, as the DOE test procedure
for this equipment. 71 FR 71340. The
DOE rule included a clarification to the
energy use rate equation to specify that
the energy use be calculated using the
entire mass of ice produced during the
testing period, normalized to 100 lb ice
produced. Id. at 71350. ARI Standard
810–2003 requires performance tests to
be conducted according to the American
National Standards Institute (ANSI)/
American Society of Heating,
Refrigerating, and Air-Conditioning
Engineers (ASHRAE) Standard 29–1988
(reaffirmed 2005), ‘‘Method of Testing
Automatic Ice Makers.’’ The DOE test
procedure also incorporated by
reference the ANSI/ASHRAE Standard
29–1988 (Reaffirmed 2005) as the
method of test.
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On January 11, 2012, DOE published
a test procedure final rule (2012 test
procedure final rule) in which it
adopted several amendments to the DOE
test procedure. 77 FR 1591. The 2012
test procedure final rule included an
amendment to incorporate by reference
Air-Conditioning, Heating, and
Refrigeration Institute (AHRI) Standard
810–2007 with Addendum 1 19 as the
DOE test procedure for this equipment.
AHRI Standard 810–2007 with
Addendum 1 amends ARI Standard
810–2003 to expand the capacity range
of covered equipment, provide
definitions and specific test procedures
for batch and continuous type ice
makers, provide a definition for ice
hardness factor, and incorporate several
new or amended definitions regarding
how water consumption and capacity
are measured, particularly for
continuous type machines. 77 FR at
19 In March 2011, AHRI published Addendum 1
to Standard 810–2007, which revised the definition
of ‘‘potable water use rate’’ and added new
definitions for ‘‘purge or dump water’’ and ‘‘harvest
water.’’
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1592–93. The 2012 test procedure final
rule also included an amendment to
incorporate by reference the updated
ANSI/ASHRAE Standard 29–2009. Id. at
1613.
In addition, the 2012 test procedure
final rule included several amendments
designed to address issues that were not
accounted for by the previous DOE test
procedure. 77 FR at 1593 (Jan. 11, 2012).
First, DOE expanded the scope of the
test procedure to include equipment
with capacities from 50 to 4,000 lb ice/
24 hours.20 DOE also adopted
20 EPCA defines automatic commercial ice maker
under 42 U.S.C. 6311(19) as ‘‘a factory-made
assembly (not necessarily shipped in 1 package)
that—(A) Consists of a condensing unit and icemaking section operating as an integrated unit, with
means for making and harvesting ice; and (B) May
include means for storing ice, dispensing ice, or
storing and dispensing ice.’’ 42 U.S.C. 6313(d)(1)
explicitly sets standards for cube type ice makers
up to 2,500 lb ice/24 hours, however, 6313(d)(2)
establishes authority to set standards for other
equipment types, such as those with capacities
greater than 2,500 lb ice/24 hours, provided the
equipment types meet the EPCA definition of an
automatic commercial ice maker.
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amendments to provide test methods for
continuous type ice makers and to
standardize the measurement of energy
and water use for continuous type ice
makers with respect to ice hardness. In
the 2012 test procedure final rule, DOE
also clarified the test method and
reporting requirements for remote
condensing automatic commercial ice
makers designed for connection to
remote compressor racks. Finally, the
2012 test procedure final rule
discontinued the use of the clarified
energy use rate calculation and instead
required energy-use to be calculated per
100 lb ice as specified in ANSI/
ASHRAE Standard 29–2009. The 2012
test procedure final rule became
effective on February 10, 2012, and the
changes set forth in the final rule
became mandatory for equipment
testing starting January 7, 2013. 77 FR
1591.
The test procedure amendments
established in the 2012 test procedure
final rule are required to be used in
conjunction with new and amended
standards promulgated as a result of this
standards rulemaking. Thus,
manufacturers must use the amended
test procedure to demonstrate
compliance with the new and amended
energy conservation standards on the
compliance date of any energy
conservation standards established as
part of this rulemaking. 77 FR at 1593
(Jan. 11, 2012).
C. Technological Feasibility
1. General
In each energy conservation standards
rulemaking, DOE conducts a screening
analysis, which is based on information
that the Department has 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
options for improving efficiency are
technologically feasible. DOE considers
a design option to be technologically
feasible if it is used by the relevant
industry or if a working prototype has
been developed. Technologies
incorporated in commercially available
equipment or in working prototypes
were considered technologically
feasible. 10 CFR part 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),
which could allow a single
manufacturer to monopolize the market.
Once DOE has determined that
particular design options are
technologically feasible, DOE further
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 equipment 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) Chapter 4 of the final rule
TSD discusses the results of the
screening analyses for automatic
commercial ice makers. Specifically, it
presents the designs DOE considered,
those it screened out, and those that are
the bases for the TSLs considered in this
rulemaking.
4657
2. Maximum Technologically Feasible
Levels
When DOE adopts (or does not adopt)
an amended or new energy conservation
standard for a type or class of covered
equipment such as automatic
commercial ice makers, it determines
the maximum improvement in energy
efficiency that is technologically
feasible for such equipment. (See 42
U.S.C. 6295(p)(1) and 6313(d)(4))
Accordingly, DOE determined the
maximum technologically feasible
(‘‘max-tech’’) improvements in energy
efficiency for automatic commercial ice
makers in the engineering analysis using
the design options that passed the
screening analysis.
As indicated previously, whether
efficiency levels exist or can be
achieved in commonly used equipment
is not relevant to whether they are
considered max-tech levels. DOE
considers technologies to be
technologically feasible if they are
incorporated in any currently available
equipment or working prototypes.
Hence, a max-tech level results from the
combination of design options predicted
to result in the highest efficiency level
possible for an equipment class, with
such design options consisting of
technologies already incorporated in
automatic commercial ice makers or
working prototypes. DOE notes that it
reevaluated the efficiency levels,
including the max-tech levels, when it
updated its results for the NODA and
final rule. See chapter 5 of the final rule
TSD for the results of the analyses and
a list of technologies included in maxtech equipment. Table III.2 and Table
III.3 shows the max-tech levels
determined in the engineering analysis
for batch and continuous type automatic
commercial ice makers, respectively.
TABLE III.2—FINAL RULE ‘‘MAX-TECH’’ LEVELS FOR BATCH AUTOMATIC COMMERCIAL ICE MAKERS
Energy use lower than baseline
IMH–W–Small–B .........................................................
IMH–W–Med–B ...........................................................
IMH–W–Large–B .........................................................
IMH–A–Small–B ..........................................................
IMH–A–Large–B ..........................................................
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Equipment type *
23.9%, 21.5% (22-inch wide).
18.1%.
8.3% (at 1,500 lb ice/24 hours), 7.4% (at 2,600 lb ice/24 hours).
25.5%, 18.1% (22-inch wide).
23.4% (at 800 lb ice/24 hours), 15.8% (at 590 lb ice/24 hours, 22-inch wide), 11.8% (at
1,500 lb ice/24 hours).
Not directly analyzed.
17.3% (at 1,500 lb ice/24 hours), 13.9% (at 2,400 lb ice/24 hours).
Not directly analyzed.
29.8%.
32.7%.
29.1%.
RCU–Small–B .............................................................
RCU–Large–B .............................................................
SCU–W–Small–B ........................................................
SCU–W–Large–B ........................................................
SCU–A–Small–B .........................................................
SCU–A–Large–B .........................................................
* IMH is ice-making head; RCU is remote condensing unit; SCU is self-contained unit; W is water-cooled; A is air-cooled; Small refers to the
lowest harvest category; Med refers to the Medium category (water-cooled IMH only); Large refers to the large size category; RCU units were
modeled as one with line losses used to distinguish standards.
Note: For equipment classes that were not analyzed, DOE did not develop specific cost-efficiency curves but attributed the curve (and maximum technology point) from one of the analyzed equipment classes.
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TABLE III.3—FINAL RULE ‘‘MAX-TECH’’ LEVELS FOR CONTINUOUS AUTOMATIC COMMERCIAL ICE MAKERS
Equipment type *
Energy use lower than baseline
IMH–W–Small–C ......................................................................................
IMH–W–Large–C ......................................................................................
IMH–A–Small–C .......................................................................................
IMH–A–Large–C .......................................................................................
RCU–Small–C ..........................................................................................
RCU–Large–C ..........................................................................................
SCU–W–Small–C .....................................................................................
SCU–W–Large–C * ...................................................................................
SCU–A–Small–C ......................................................................................
SCU–A–Large–C * ....................................................................................
Not directly analyzed.
Not directly analyzed.
25.7%.
23.3% lb ice.
26.6%.
Not directly analyzed.
Not directly analyzed.
No units available.
26.6%.
No units available.
* DOE’s investigation of equipment on the market revealed that there are no existing products in either of these two equipment classes (as defined in this final rule).
Note: For equipment classes that were not analyzed, DOE did not develop specific cost-efficiency curves but attributed the curve (and maximum technology point) from one of the analyzed equipment classes.
D. Energy Savings
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1. Determination of Savings
For each TSL, DOE projected energy
savings from automatic commercial ice
makers purchased during a 30-year
period that begins in the year of
compliance with amended standards
(2018–2047). The savings are measured
over the entire lifetime of products
purchased in the 30-year period. DOE
used the NIA model to estimate the
national energy savings (NES) for
equipment purchased over the period
2018–2047. The model forecasts total
energy use over the analysis period for
each representative equipment class at
efficiency levels set by each of the
considered TSLs. DOE then compares
the energy use at each TSL to the basecase energy use to obtain the NES. The
NIA model is described in section IV.H
of this rule and in chapter 10 of the final
rule TSD.
DOE used its NIA spreadsheet model
to estimate energy savings from
amended standards for automatic
commercial ice makers. The NIA
spreadsheet model (described in section
IV.H of this preamble) calculates energy
savings in site energy, which is the
energy directly consumed by products
at the locations where they are used.
Because automatic commercial ice
makers use water, water savings were
quantified in the same way as energy
savings.
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) AEO.
DOE also has begun to estimate fullfuel-cycle energy savings. 76 FR 51282
(August 18, 2011), as amended by 77 FR
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49701 (August 17, 2012). The full-fuelcycle (FFC) metric includes the energy
consumed in extracting, processing, and
transporting primary fuels, and thus
presents a more complete picture of the
impacts of energy efficiency standards.
DOE’s approach is based on calculations
of an FFC multiplier for each of the
fuels used by automatic commercial ice
makers.
2. Significance of Savings
EPCA prohibits DOE from adopting a
standard that would not result in
significant additional energy savings.
(42 U.S.C. 6295(o)(3)(B) and
6313(d)(4)While the term ‘‘significant’’
is not defined in EPCA, the U.S. Court
of Appeals for the District of Columbia
in Natural Resources Defense Council v.
Herrington, 768 F.2d 1355, 1373 (D.C.
Cir. 1985), indicated that Congress
intended significant energy savings to
be savings that were not ‘‘genuinely
trivial.’’ The energy savings for all of the
TSLs considered in this rulemaking
(presented in section V.B.3.a) are
nontrivial, and, therefore, DOE
considers them ‘‘significant’’ within the
meaning of section 325 of EPCA.
E. Economic Justification
1. Specific Criteria
As discussed in section III.E.1, EPCA
provides seven factors to be evaluated in
determining whether a potential energy
conservation standard is economically
justified. (42 U.S.C. 6295(o)(2)(B)(i) and
6313(d)(4) The following sections
generally discuss how DOE is
addressing 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 this rule.
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a. Economic Impact on Manufacturers
and Commercial Customers
In determining the impacts of a
potential new or amended energy
conservation standard on
manufacturers, DOE first determines its
quantitative impacts using an annual
cash flow approach. This includes both
a short-term assessment (based on the
cost and capital requirements associated
with new or amended standards during
the period between the announcement
of a regulation and the compliance date
of the regulation) and a long-term
assessment (based on the costs and
marginal impacts over the 30-year
analysis period). The impacts analyzed
include INPV (which values the
industry based on 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
potential impacts on different types of
manufacturers, paying particular
attention to impacts on small
manufacturers. Third, DOE considers
the impact of new or amended
standards on domestic manufacturer
employment and manufacturing
capacity, as well as the potential for
new or amended standards to result in
plant closures and loss of capital
investment. Finally, DOE takes into
account cumulative impacts of other
DOE regulations and non-DOE
regulatory requirements on
manufacturers.
For individual customers, measures of
economic impact include the changes in
LCC and the PBP associated with new
or amended standards. These measures
are discussed further in the following
section. For consumers in the aggregate,
DOE also calculates the national net
present value of the economic impacts
applicable to a particular rulemaking.
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DOE also evaluates the LCC impacts of
potential standards on identifiable
subgroups of consumers that may be
affected disproportionately by a national
standard.
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b. Savings in Operating Costs Compared
To Increase in Price (Life Cycle Costs)
EPCA requires DOE to consider the
savings in operating costs throughout
the estimated average life of the covered
product compared to any increase in the
price of the covered product that are
likely to result from the imposition of
the standard. (42 U.S.C.
6295(o)(2)(B)(i)(II) and 6313(d)(4) DOE
conducts this comparison in its LCC and
PBP analysis.
The LCC is the sum of the purchase
price of equipment (including the cost
of its installation) and the operating
costs (including energy and
maintenance and repair costs)
discounted over the lifetime of the
equipment. To account for uncertainty
and variability in specific inputs, such
as product lifetime and discount rate,
DOE uses a distribution of values, with
probabilities attached to each value. For
its analysis, DOE assumes that
consumers will purchase the covered
products in the first year of compliance
with amended standards.
The LCC savings and the PBP for the
considered efficiency levels are
calculated relative to a base-case
scenario, which reflects likely trends in
the absence of new or amended
standards. DOE identifies the percentage
of consumers estimated to receive LCC
savings or experience an LCC increase,
in addition to the average LCC savings
associated with a particular standard
level. DOE’s LCC and PBP analysis is
discussed in further detail in section
IV.G.
c. Energy Savings
While significant conservation of
energy is a statutory requirement for
imposing an energy conservation
standard, EPCA also 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. (42 U.S.C. 6295(o)(2)(B)(i)(III)
and 6313(d)(4)) DOE uses 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
IV.H of this preamble and chapter 10 of
the final rule TSD.
d. Lessening of Utility or Performance of
Equipment
In establishing classes of equipment,
and in evaluating design options and
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the impact of potential standard levels,
DOE seeks to develop standards that
would not lessen the utility or
performance of the equipment under
consideration. DOE has determined that
none of the TSLs presented in today’s
final rule would reduce the utility or
performance of the equipment
considered in the rulemaking. (42 U.S.C.
6295(o)(2)(B)(i)(IV) and 6313(d)(4))
During the screening analysis, DOE
eliminated from consideration any
technology that would adversely impact
customer utility. For the results of
DOE’s analyses related to the potential
impact of amended standards on
equipment utility and performance, see
section IV.C of this preamble and
chapter 4 of the final rule TSD.
e. Impact of Any Lessening of
Competition
EPCA requires DOE to consider any
lessening of competition that is likely to
result from setting new or amended
standards for covered equipment.
Consistent with its obligations under
EPCA, DOE sought the views of the
United States Department of Justice
(DOJ). DOE asked DOJ to provide a
written determination of the impact, if
any, of any lessening of competition
likely to result from the amended
standards, together with an analysis of
the nature and extent of such impact. 42
U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii).
DOE transmitted a copy of its proposed
rule to the Attorney General with a
request that the Department of Justice
(DOJ) provide its determination on this
issue. DOJ’s response, that the proposed
energy conservation standards are
unlikely to have a significant adverse
impact on competition, is reprinted at
the end of this rule.
f. Need of the Nation To Conserve
Energy
Another factor that DOE must
consider in determining whether a new
or amended standard is economically
justified is the need for national energy
and water conservation. (42 U.S.C.
6295(o)(2)(B)(i)(VI) and 6313(d)(4))) The
energy savings from new or amended
standards are likely to provide
improvements to the security and
reliability of the Nation’s energy system.
Reductions in the demand for electricity
may also result in reduced costs for
maintaining the reliability of the
Nation’s electricity system. DOE
conducts a utility impact analysis to
estimate how new or amended
standards may affect the Nation’s
needed power generation capacity, as
discussed in section IV.M.
Amended standards also are likely to
result in environmental benefits in the
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4659
form of reduced emissions of air
pollutants and greenhouse gases
associated with energy production and
use. DOE conducts an emissions
analysis to estimate how standards may
affect these emissions, as discussed in
section IV.K. DOE reports the emissions
impacts from each TSL it considered, in
section V.B.6 of this rule. DOE also
estimates the economic value of
emissions reductions resulting from the
considered TSLs, as discussed in
section IV.L.
g. Other Factors
EPCA allows the Secretary, in
determining whether a new or amended
standard is economically justified, to
consider any other factors that the
Secretary deems to be relevant. (42
U.S.C. 6295(o)(2)(B)(i)(VII) and
6313(d)(4)) There were no other factors
considered for this final rule.
2. Rebuttable Presumption
As set forth in 42 U.S.C.
6295(o)(2)(B)(iii) and 6313(d)(4), EPCA
provides for a rebuttable presumption
that an energy conservation standard is
economically justified if the additional
cost to the customer of equipment that
meets the new or amended 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
that calculate the PBP for customers of
potential new and amended energy
conservation standards. These analyses
include, but are not limited to, the 3year PBP contemplated under the
rebuttable presumption test. However,
DOE routinely conducts a full economic
analysis that considers the full range of
impacts to the customer, manufacturer,
Nation, and environment, as required
under 42 U.S.C. 6295(o)(2)(B)(i) and
6313(d)(4). The results of these analyses
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.G.12 of this rule
and chapter 8 of the final rule TSD.
IV. Methodology and Discussion of
Comments
A. General Rulemaking Issues
During the April 2014 and June 2014
public meetings, and in subsequent
written comments in response to the
NOPR and NODA, stakeholders
provided input regarding general issues
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pertinent to the rulemaking, such as
issues regarding proposed standard
levels and the compliance date. These
issues are discussed in this section.
1. Proposed Standard Levels
In response to the level proposed in
the NOPR (TSL 3), Manitowoc
commented that there are significant
deficiencies in the models and cost
assumptions that were used to arrive at
the proposed efficiency levels and that,
consequently, the selected levels are not
optimal from a life-cycle cost
standpoint. (Manitowoc, Public Meeting
Transcript, No. 70 at p. 24–26) Follett
commented that DOE is recommending
efficiency levels that are neither
technologically nor economically
justified. (Follett, No. 84 at p. 8)
Hoshizaki and Scotsman both
recommended DOE select NOPR TSL 1
(Hoshizaki, No. 86 at p. 5–6; Scotsman,
Public Meeting Transcript, No. 70
Public Meeting Transcript, at p. 44–46)
Scotsman stated that doing so effective
2020 is technologically feasible,
economically justified, consistent with
past regulations, and will save a
significant amount of energy.
(Scotsman, Public Meeting Transcript,
Public Meeting Transcript, No. 70 at p.
44–46) Although the following comment
regarding choosing a standard level
mentioned ‘‘ELs,’’ efficiency levels, DOE
believes Hoshizaki intended that this
comment refer to ‘‘TSLs,’’ trial standard
levels levels and DOE has interpreted
the comment accordingly. Hoshizaki
stated that NOPR EL1 (interpreted as
TSL1) would garner similar savings as
NOPR EL3 (interpreted as TSL3) while
reducing the burden on the industry to
meet such stringent standards in such a
short amount of time. (Hoshizaki, No. 86
at p. 5–6)
Scotsman stated that they have not
identified technology combinations that
are suitable for achieving any efficiency
level beyond NOPR TSL 1. (Scotsman,
No. 85 at p. 8b) Scotsman added that
they do not have data indicating that
their machines will be able to meet
NOPR TSL 3 using the design options
under consideration. (Scotsman, No. 85
at p. 7b)
Pacific Gas and Electric Company
(PG&E) and San Diego Gas and Electric
Company (SDG&E), commenting jointly,
and a group including the Appliance
Standards Awareness Project (ASAP),
the American Council for an EnergyEfficient Economy (ACEEE), the
Alliance to Save Energy, Natural
Resources Defense Council (NRDC), and
the Northwest Power and Conservation
Council (NPCC) (Joint Commenters)
both recommended that DOE adopt a
higher TSL for ACIMs. (Joint
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Commenters, No. 87 at p. 1–2; PG&E
and SDG&E, No. 89 at p. 1–2) ASAP
noted that based on their review of the
certification database, there are products
existing on the market today that meet
the proposed standard levels. (ASAP,
Public Meeting Transcript, No. 70 at p.
50–52) Joint Commenters urged DOE to
adopt TSL 5 for batch type equipment
and TSL 4 for continuous type
equipment. (Joint Commenters, No. 87
at p. 1–2) PG&E and SDG&E
recommended that DOE adopt the
maximum cost-effective TSL for each
equipment class noting that DOE could
adopt TSLs higher than TSL 3 while
maintaining a net benefit to U.S.
consumers. (PG&E and SDG&E, No. 89
at p. 1–2)
Although the NODA only provided
data regarding the updated analysis and
did not propose a standard level, several
interested parties provided comment
regarding the appropriateness of setting
the ACIM energy conservation standard
at a given NODA TSL.
In their written comment, Manitowoc
stated that the NODA analysis was an
improvement over the original NOPR
analysis. Manitowoc stated that they did
not believe the standard should be set
at a single TSL level for all equipment
classes and suggested a different TSL
level for each equipment class.
Although the following comments
regarding specific classes mention
‘‘ELs,’’ efficiency levels, DOE believes
Manitowoc intended that these
comments apply to ‘‘TSLs,’’ trial
standard levels and DOE has interpreted
the comment accordingly. For IMH–A
batch equipment with package widths
less than 48 inches (the 48-inch
corresponds to the 1,500 lb ice/24 hour
representative capacity), Manitowoc
supported an efficiency level no higher
than EL 3 (interpreted as TSL3).
Manitowoc suggested that DOE adopt a
standard that would be limited to 5%
improvement in efficiency over baseline
for the IMH–A–B2 (48-inch wide)
equipment. DOE believes Manitowoc’s
third point in the comments, citing the
‘‘IMH-small’’ class refers to IMH–W–
Small–B, for which Manitowoc
indicated that the standard level should
be set no higher than EL 3 (interpreted
as TSL3). Manitowoc also suggested
DOE adopt standards with efficiency
gains no greater than 4.7% and 3.7%
efficiency gains, respectfully, for the
MH–W–Large–B1 (1,500 lb ice/24 hours
representative capacity) and IMH–W–
Large–B2 (2,600 lb ice/24 hours
representative capacity) equipment.
Manitowoc suggested that DOE adopt
EL 2 (interpreted as TSL2) for the RCU–
NRC–B1 (1,500 lb ice/24 hours
representative capacity) and RCU–NRC–
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B2 (2,400 lb ice/24 hours representative
capacity) equipment, as well as the
SCU–A–Small and SCU–A–Large
equipment classes and for 22-inch IMH
equipment. For the RCU–NRC–Large–
B1, Manitowoc indicated that the 20
percent improvement in compressor
energy efficiency ratio (EER) used in
DOE’s analysis for this equipment is
unrealistic. For the RCU–NRC–Large–
B2, Manitowoc mentioned that the
increase in condenser size considered in
the DOE analysis would present
significant issues with refrigerant charge
management. For the SCU–A–Small–B
class, Manitowoc indicated that the
40% improvement in compressor EER
considered in DOE’s analysis is not
likely to be achieved and adding a tube
row to the condenser may not be
possible. For the SCU–A–Large–B class,
Manitowoc similarly commented that
the compressor EER improvement and
condenser size increases considered in
DOE’s analyses are unrealistic. For the
22-inch IMH equipment, Manitowoc
indicated that some of the considered
design options (increase in evaporator
size and/or a drain water heat
exchanger) would not be feasible due to
the compact nature of these units.
Manitowoc suggested that DOE select
EL 3 (interpreted as TSL3) for IMH–A–
B small and large-1 batch equipment
classes (not including 48″ models), as
well as the IMH-Small equipment class
and all other equipment classes not
specifically mentioned. (Manitowoc,
No. 126 at p. 1–2)
Ice-O-Matic requested that DOE select
NODA TSL 3. (Ice-O-Matic, No. 121 at
p. 1) Scotsman suggested that DOE
select NODA TSL 2. (Scotsman, No. 125
at p. 3) Hoshizaki suggested that DOE
select NODA TSL 2 for batch units.
(Hoshizaki, No. 124 at p. 3)
ASAP encouraged DOE to adopt
NODA TSL 5 for batch type remote
condensing equipment and NODA TSL
4 for all other equipment classes, noting
that these choices would be cost
effective. (ASAP, No. 127 at p. 1) CA
IOU suggested that DOE adopt the
NODA TSL for each equipment class
that saves the most energy and has a
positive NPV. CA IOU noted that DOE
could adopt a level more stringent than
NODA TSL 3 for all equipment classes
while maintaining a net benefit to US
consumers. (CA IOU, No. 129 at p. 1)
DOE understands the concerns voiced
by stakeholders regarding their future
ability to meet standard levels as
proposed in the NOPR. DOE must
adhere to the EPCA guidelines for
determining the appropriate level of
standards that were outlined in sections
III.E.1. In this Final Rule, DOE selected
the TSL that best meets the EPCA
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requirements for establishing that a
standard is economically justified. (42
U.S.C. 6295(o)(2)(B)(i) and 6313(d)(4)).
Since the publication of the NOPR, DOE
has revised and updated its analysis
based on stakeholders comments
received at the NOPR public meeting,
comments made during the June 19
meeting, and in written comments
received in response to the NOPR and
NODA. These updates included changes
in its approach to calculating the energy
use associated with groups of design
options, changes in inputs for
calculations of energy use and
equipment manufacturing cost, and
consideration of space-constrained
applications. After applying these
changes to the analyses, the efficiency
levels that DOE determined to be cost
effective changed considerably. The
NODA comments described above
reveal partial industry support for the
standard levels chosen by DOE in the
final rule.
DOE notes that much of the
commentary regarding the selection of
efficiency levels for the standard are
based on more detailed comments
regarding the feasibility of design
options, the savings that these design
options can achieve, and their costs.
DOE response regarding many of these
comments is provided in section IV.D.3.
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2. Compliance Date
In the March 2014 NOPR analysis,
DOE assumed a 3-year period for
manufacturers to prepare for
compliance. DOE requested comments
as to whether a January 1, 2018 effective
date provides an inadequate period for
compliance and what economic impacts
would be mitigated by a later effective
date.
Following the publication of the
NOPR, several manufacturers and
NAFEM expressed an expected inability
to meet the proposed standard levels
within the three year compliance
period. (Manitowoc, No. 92 at p. 2–3,
Scotsman, No. 85 at p. 2b, Hoshizaki,
No. 86 at p. 2, NAFEM, No. 82 at pg. 2–
3) Manitowoc and Hoshizaki both
commented that a 5-year compliance
period would be necessary for this
rulemaking. (Manitowoc, No. 92 at p. 2–
3; Hoshizaki, No. 86 at p. 2) Scotsman
commented that an 8-year compliance
period would be more feasible for the
technology specification, R&D
investment, performance evaluation,
reliability evaluation, and
manufacturing required for product
redesign. Scotsman added that the
negative economic impacts of the rule
would be mitigated by a later effective
date. (Scotsman, No. 85 at p. 2b–3)
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AHRI, Manitowoc, and NAFEM
commented that a three year compliance
period is not adequate for this
rulemaking and that DOE should extend
the compliance period to allow time for
manufacturers to obtain new
components. (AHRI, Public Meeting
Transcript, No. 70 at p. 18; NAFEM, No.
82 at pg. 2–3; Manitowoc, No. 92 at p.
2 –3) NAFEM and AHRI commented
that DOE should extend the compliance
period by two years. (AHRI, No. 93 at
p. 2; NAFEM, No. 82 at pg. 2–3) AHRI
and Manitowoc noted that there is a
potential for Environmental Protection
Agency (EPA) Significant New
Alternatives Policy (SNAP) regulations
to force further product redesign and
extending the compliance period would
provide relief should refrigerant
regulatory issues not be finalized in
time.21 (AHRI, No. 93 at p. 2;
Manitowoc, No. 126 at p. 3) Emerson
urged DOE to wait until after EPA
finalizes its decision on refrigerants
before starting the 3-year period given to
manufacturers to meet the new
standards so manufacturers can redesign for both energy efficiency and
low global warming potential (GWP)
refrigerants in one design cycle.
(Emerson, No. 122, p. 1)
NAFEM stated that manufacturers
will only be able to achieve energy
efficiency gains up to the level of NOPR
TSL 1 within the five-year compliance
timeline and that the current proposal
will result in the unavailability of ice
makers with the characteristics, sizes,
capacities, and volumes that are
generally available in the U.S. (NAFEM,
No. 82 at p. 2) NAFEM’s comment
mentions a five-year compliance
timeline, although DOE proposed a
three-year timeline in the NOPR. 79 FR
at 14949 (March 17, 2014).
Another concern amongst
manufacturers was the belief that the
proposed standard levels were based on
technology that was currently not
available. At the April 2014 NOPR
public meeting, Ice-O-Matic commented
that they did not believe that the
technology exists to achieve the
proposed standards in the allotted time
frame. (Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 33)
Joint Commenters noted that, in
balancing the stringency of the
standards with the compliance dates
and manufacturer impacts, they believe
that the stringency of the standard is
more important for national energy
savings than the compliance dates.
(Joint Commenters, No. 87 at p. 4)
21 Details regarding EPA SNAP regulations are
discussed in section IV.A.4.
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In response to the assertion that
DOE’s standard levels were not based
upon currently available technologies,
DOE maintains that all technology
options and equipment configurations
included in its NOPR reflect
technologies currently in use in
automatic commercial ice makers. For
example, DOE considered use only of
compressors that are currently
commercially available and which
manufacturers have indicated are
acceptable for use in ice makers in
confidential discussions with DOE’s
contractor. Moreover, the proposed
standard levels are exceeded by the
ratings of some products that are
currently commercially available.
However, the standard levels
established in this final rule are
significantly less stringent than the
standard levels proposed in the NOPR,
and a greater percentage of currentlyavailable products already meet these
efficiency levels. DOE expects that this
reduction in stringency and the reduced
number of products requiring redesign
means that the time required for
manufacturers to achieve compliance
would be reduced.
In response to the NODA, Scotsman,
Manitowoc, NAFEM, and Ice-O-Matic
all requested that the effective date for
the new efficiency standard for ACIMs
be extended to 5 years after the
publication of the final rule. (Scotsman,
No. 125 at p. 3; Manitowoc, No. 126 at
p. 3; NAFEM, No. 123 at p. 2; Ice-OMatic, No. 121 at p. 1) NAFEM stated
that even with the more realistic
assumptions presented in the NODA,
manufactures still require an extended
timeline to obtain new components
needed to meet higher efficiency levels.
In response to the request that DOE
extend the compliance date period for
automatic commercial ice makers
beyond the 3 years specified by the
NOPR, DOE notes that EPCA requires
that the amended standards established
in this rulemaking must apply to
equipment that is manufactured on or
after 3 years after the final rule is
published in the Federal Register 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. 6313(d)(3)(C)) DOE believes that
the modifications to the analysis,
relative to the NOPR, it announced in
the NODA and made to the final rule
will reduce the burden on
manufacturers to meet requirements
established by this rule, because the
standard levels are less stringent and
fewer ice maker models will require
redesign to meet the new standard.
Therefore, DOE has determined that the
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3-year period is adequate and is not
extending the compliance date for
ACIMs.
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3. Negotiated Rulemaking
Stakeholders AHRI, Hoshizaki,
Manitowoc, and the North American
Association of Food Equipment
Manufactures (NAFEM) both suggested
that DOE use a negotiated rulemaking to
develop ACIM standards. (AHRI, Public
Meeting Transcript, No. 70 at p. 15–16;
AHRI, Public Meeting Transcript, No.
128 at p. 1; Hoshizaki, Public Meeting
Transcript, No. 70 at p. 38–39;
Hoshizaki, Public Meeting Transcript,
No. 124 at p. 3; Manitowoc, Public
Meeting Transcript, No. 70 at p. 344–
345; NAFEM, No. 82 at p. 2; NAFEM,
No. 123 at p. 1) NAFEM stated that a
negotiated rulemaking would ensure the
level of enhanced dialogue needed for
DOE to effectively assess the rule’s
impact on end-users. (NAFEM, No. 82 at
p. 2) AHRI stated that there are
significant issues in the analysis, that
the current direction of this rulemaking
will place significant burden on the
industry, and that the completion of this
rulemaking under the current process
will be difficult, expensive, and not
timely. (AHRI, Public Meeting
Transcript, No. 70 at p. 15–16)
In response to the manufacturers’
suggestion to use a negotiated
rulemaking to develop ACIM standards,
DOE notes that this issue was raised
before the Appliance Standards and
Rulemaking Federal Advisory
Committee (ASRAC) on June 6, 2014
and the ASRAC membership declined to
establish a working group to negotiate a
final rule for ACIM energy conservation
standards. Several ASRAC members
voiced concern of using ASRAC at such
a late stage in the rulemaking when it
would be more appropriate to raise
these concerns in the normal public
comment process. (See public transcript
at: https://www.regulations.gov/
#!documentDetail;D=EERE-013-BTNOC-0005-0025)
4. Refrigerant Regulation
Manitowoc noted that the EPA has
proposed delisting R–404A, the
refrigerant used in nearly all currently
available ice makers, for commercial
refrigeration applications. Manitowoc
stated that while commercial ice makers
are not within the current scope for the
SNAP NOPR, it seems likely that ice
makers could be affected by a
subsequent rulemaking. (Manitowoc,
No. 126 at p. 3) Several interested
parties, including AHRI, NAFEM,
Hoshizaki, Manitowoc, and Howe
requested that DOE consider the
hardships associated with refrigerant
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choice uncertainty caused by potential
future EPA SNAP regulations in the
analysis (AHRI, Public Meeting
Transcript, No. 70 at p. 16–18; NAFEM,
No. 82 at p. 7; Hoshizaki, No. 86 at p.
6–7; Howe, No. 88 at p. 2–3; Manitowoc,
Public Meeting Transcript, No. 70 at p.
286–287; Manitowoc, No. 126 at p. 3)
Manitowoc suggested that DOE do a
sensitivity analysis that examines what
would happen to life-cycle costs, etc. if
manufacturers had to re-engineer twice.
(Manitowoc, Public Meeting Transcript,
No. 70 at p. 286–287)
AHRI commented that the potential
for SNAP rulemakings to require a
refrigerant change will necessitate major
redesigns just to maintain current
efficiency levels. (AHRI, Public Meeting
Transcript, No. 70 at p. 16–18)
Manitowoc and Hoshizaki also
expressed concern regarding the
redesign work that would be needed if
the EPA were to ban R–404A.
(Manitowoc, Public Meeting Transcript,
No. 70 at p. 286–287; Hoshizaki, No. 86
at p. 6–7) AHRI added that the burden
of the potential EPA SNAP rulemaking
must be taken into account in the
engineering and life-cycle cost analyses.
AHRI requested that DOE put a hold on
the ACIM rulemaking until after the
next SNAP rollout is completed. (AHRI,
Public Meeting Transcript, No. 70 at p.
16–18)
AHRI also commented that the DOE
should make an effort to look at
refrigerants because its cost-benefit
analysis is based solely on a refrigerant
that may not exist three years from now.
(AHRI, Public Meeting Transcript, No.
70 at p. 284–285) AHRI noted that,
because low-GWP refrigerants also have
lower heat transfer capability than R–
404A, coil sizes may need to further
increase in order to maintain the
performance with other refrigerants,
which could be infeasible if the
proposed standards are already calling
for an increased coil size for units using
R–404A. (AHRI, Public Meeting
Transcript, No. 70 at p. 293–294)
Scotsman and Hoshizaki suggested
that DOE and EPA collaborate so that
both the energy conservation
rulemaking and the SNAP rulemaking
don’t promulgate standards that are
unduly burdensome. (Scotsman, No.
125 at p. 2; Hoshizaki, No. 86 at p. 6–
7)
Manitowoc stated that even if the EPA
takes no action on ice makers in the
next 3 years, the component supplier
industry (compressors, expansion
valves, heat exchangers, etc.) will focus
its efforts on supporting the transition to
hydrocarbons, HFO blends, and other
acceptable refrigerants for the
refrigeration industry as the volume of
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display case, reach-in, walk-in, and
vending is significantly larger than that
for commercial ice machines.
(Manitowoc, No. 126 at p. 3)
ASAP commented that the way that
DOE is dealing with the refrigerants
issue is consistent with how it has dealt
with it in all other rulemakings. (ASAP,
Public Meeting Transcript, No. 70 at p.
52–53) Joint Commenters commented
that DOE’s approach of conducting their
analysis based on the most commonlyused refrigerants today is appropriate
and that it does not appear that a phaseout of R–404A would negatively impact
ice maker efficiency, given the fact that
propane, DR–33, and N–40 all have
lower GWP and similar efficiency
compared to R–404A. (Joint
Commenters, No. 87 at p. 4) NEEA
expressed their support for DOE’s
current refrigerant-neutral position.
(NEEA, No. 91 at p. 2)
In response to these comments, DOE
notes that the EPA SNAP NOPR
mentioned by Manitowoc (see 79 FR
46149 (Aug. 6, 2014)) did not propose
to delist the use of R–404A for ACIMs.
EPA proposed to delist R–404A for
certain retail food refrigeration
applications including condensing
units. However, ACIMs do not qualify as
retail food refrigeration equipment and
therefore will not be subject to SNAP
regulations that pertain to retail
refrigeration applications. Further,
alternate refrigerants have not been
proposed by the SNAP program for use
in ACIMs.22 DOE recognizes that the
engineering analysis is based on the use
of R–404A, the most commonly used
refrigerant in ACIMs, and that a
restriction of R–404A in ACIMs would
have impacts on the design options
selected in the engineering analysis.
However, DOE cannot speculate on the
outcome of a rulemaking in progress
and can only consider in its
rulemakings rules that are currently in
effect. Therefore, DOE has not included
possible outcomes of a potential EPA
SNAP rulemaking in the engineering or
LCC analysis. This position is consistent
with past DOE rulings, such as in the
2011 direct final rule for room air
conditioners. 76 FR 22454 (April 21,
2011). DOE is aware of stakeholder
concerns that EPA may broaden the uses
for which R–404A is phased out at some
point in the future. DOE is confident
22 EPA on July 9, 2014 proposed new alternative
refrigerants for several applications, but not ACIMs.
79 FR 38811. EPA also, on August 6, 2014,
proposed delisting of refrigerants for several
applications, but not ACIMs. 79 FR 46126 (Aug. 6,
2014). The notice did indicate that EPA is
considering whether to delist use of R–404A for
ACIMs, but did not propose such action. 79 FR at
46149.
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that there will be an adequate supply of
R–404A for compliance with the
standards being finalized in today’s
rule, however, consistent with EO
13563, Improving Regulation and
Regulatory Review, DOE will prioritize
its review of the potential effects of any
future phase-out of the refrigerant R–
404A (should there be one) on the
efficiency standards set by this
rulemaking.
DOE does not have reason to believe
that EPA’s SNAP proposal to delist R–
404A for commercial refrigeration
applications will have a deleterious
impact on the availability of
components for ACIMs. Although the
component supplier industry may focus
efforts on supporting the transition to
alternative refrigerants for the
commercial refrigeration industry as
suggested by Manitowoc, the design
options included in this final rule are
based on existing component
technology and do not assume an
advancement in such components.
Therefore, DOE believes that those
components currently on the market
will remain available for use by ACIM
manufactures. DOE wishes to clarify
that it will continue to consider ACIM
models meeting the definition of
automatic commercial ice makers to be
part of their applicable covered
equipment class, regardless of the
refrigerant that the equipment uses. If a
manufacturer believes that its design is
subjected to undue hardship by
regulations, the manufacturer may
petition DOE’s Office of Hearing and
Appeals (OHA) for exception relief or
exemption from the standard pursuant
to OHA’s authority under section 504 of
the DOE Organization Act (42 U.S.C.
7194), as implemented at subpart B of
10 CFR part 1003. OHA has the
authority to grant such relief on a caseby-case basis if it determines that a
manufacturer has demonstrated that
meeting the standard would cause
4663
hardship, inequity, or unfair
distribution of burdens.
DOE investigated ice makers which it
believes use refrigerants other than R–
404A, specifically refrigerants HFC–
134a and R–410A. While these
refrigerants are also HFCs, their GWP is
significantly lower than that of R–
404A,23 and for this reason may be less
likely to be delisted for use in ice
makers under future SNAP rule
revisions. Based on the available
information, DOE concludes that
compliance challenges for these
alternative refrigerants are not greater
than for R–404A. Table IV.1 below
presents performance data of
alternative-refrigerant ice makers and
compares their energy use to the energy
use associated with TSL3 for their
equipment class and capacity. Thirteen
of these 31 ice makers meet the TSL3
level.
TABLE IV.1—ICE MAKERS USING ALTERNATIVE REFRIGERANTS
Harvest
capacity rate
(lb ice/24 hr)
Refrigerant
Equipment class
HFC–134a .....................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
R–410A ..........................
SCU–A–Small–B .................................................
IMH–W–Small–B * ...............................................
IMH–W–Small–B .................................................
IMH–W–Small–B .................................................
IMH–W–Small–B .................................................
IMH–W–Small–B .................................................
IMH–W–Small–B .................................................
IMH–W–Med–B ...................................................
IMH–W–Med–B * .................................................
IMH–W–Med–B * .................................................
IMH–A–Small–B ..................................................
IMH–A–Small–B ..................................................
IMH–A–Small–B ..................................................
IMH–A–Small–B ..................................................
IMH–A–Large–B ..................................................
IMH–A–Large–B ..................................................
IMH–A–Large–B ..................................................
IMH–A–Large–B ..................................................
IMH–A–Large–B ..................................................
IMH–A–Large–B ..................................................
IMH–A–Large–B ..................................................
IMH–A–Large–B ..................................................
IMH–A–Large–B * ................................................
RCU–NRC–Small–B ............................................
RCU–NRC–Small–B ............................................
RCU–NRC–Small–B * ..........................................
Energy use
(kWh/100 lb)
121
302
305
310
428
430
494
510
730
1,200
222
300
305
388
485
714
230
320
310
405
538
714
1,100
724
720
1,200
8.4
6.1
5.2
5.2
4.7
4.7
5
5
4.75
4.1
7.5
6.2
6.8
6
6
6.1
7.5
6.2
6.8
5.8
6
6.1
5.3
5.4
5.4
5
Energy use
percent below
baseline
31.8
0.6
15.1
14.7
13.7
13.5
1.6
0.4
0.6
3.8
10.2
19.3
11.0
13.3
5.6
0.1
9.4
17.4
10.5
14.4
4.7
0.1
6.7
11.5
8.8
2.0
TSL3 Energy
use
(kWh/100 lb)
9.4
5.2
5.2
5.2
5.0
5.0
4.9
4.8
4.4
4.1
7.3
6.3
6.3
6.1
5.8
5.3
6.5
6.3
6.3
6.0
5.7
5.3
4.9
5.5
5.5
4.6
* Two ice makers with these ratings, one each for full-cube and half-cube ice.
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5. Data Availability
AHRI, PGE/SDG&E, and NAFEM
requested that DOE make data available
for stakeholder review. (AHRI, Public
Meeting Transcript, No. 70 at p. 349;
PG&E and SDG&E, No. 89 at p. 3;
NAFEM, No. 82 at p. 2) Specifically,
AHRI requested that DOE’s test results
be made available to manufacturers for
review. (AHRI, Public Meeting
Transcript, No. 70 at p. 349) NAFEM
suggested that DOE identify the model
and serial number of components used
in the engineering analysis in order to
enhance transparency. (NAFEM, No. 82
at p. 2)
AHRI and Danfoss both suggested that
DOE facilitate more informal dialog to
discuss data and assumptions for the
department to receive feedback. (AHRI,
Public Meeting Transcript, No. 70 at p.
342–343; Danfoss, No. 72 at p. 1–2)
23 See https://www.epa.gov/ozone/snap/
subsgwps.html.
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Danfoss recommended that DOE publish
the list of all persons, companies and
organizations they have contacted in
regards to this rulemaking. (Danfoss, No.
72 at p. 1–2)
In response to stakeholders, DOE held
a public meeting on June 19 to provide
stakeholders with more information
about the energy modeling used in
developing the NOPR analysis. 79 FR
33877 (June 13, 2014). In addition, DOE
published a NODA presenting analyses
revised based on stakeholder comments
and additional research conducted after
the NOPR. 79 FR 54215 (Sept. 11, 2014).
DOE’s contractor also engaged in
additional discussions with
manufacturers under non-disclosure
agreements after publication of the
NOPR in order to collect additional
information relevant to the analyses.
DOE generally does not publish test data
to avoid revealing information about
product performance that may be
considered trade secrets. Also for this
reason, DOE does not intend to publish
the model and serial number of
equipment or components obtained,
tested, and reverse-engineered during
the analysis. DOE also does not reveal
the identity of companies and
organizations from which its contractor
has collected information under nondisclosure agreement.
In their written response to the
NODA, AHRI expressed their belief that
DOE’s current process in this
rulemaking is not compliant with the
objective of using transparent and
robust analytical methods producing
results that can be explained and
reproduced, as required by DOE’s
process rule and guidelines. AHRI
expressed their belief that it has been
difficult to analyze and provide
feedback on this rulemaking as
important portions such as the energy
model have not been disclosed to the
public. (AHRI, No. 128 at p. 6–8)
AHRI and NAFEM requested that
DOE publically release the FREEZE
model for stakeholder review. NAFEM
and AHRI stated that DOE was unable
to show that the FREEZE model
functioned and was unable to produce
accurate results at the June 2014 public
meeting. (AHRI, No. 128 at p. 2–3;
NAFEM, No. 123 at p. 1–2) AHRI stated
that given the results of the limited runs
model at the June 19th meeting, they
believe that there are serious concerns
about the quality and reproducibility of
the information that is not in
accordance with the applicable
guidelines for ensuring and maximizing
the quality, objectivity, utility and
integrity of information disseminated to
the public by the Department of Energy.
AHRI added that without public release
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of the model, DOE cannot demonstrate
sufficient transparency about the data
and methods such that an independent
reanalysis can be undertaken by a
qualified member of the public. AHRI
noted that if DOE had compelling
interests that prohibit public access to
the model, DOE must identify those
interests and describe and document the
rigorous checks it has undertaken to
ensure reproducibility. (AHRI, No. 128
at p. 6–8)
DOE notes that stakeholders have
placed great emphasis on the FREEZE
model in their responses, but this model
is only part of the analysis. Moreover,
DOE has published output of the
engineering analysis on which
stakeholders have had the opportunity
to comment, for both the NOPR and
NODA phases. As part of the final rule
documentation, DOE presents the
revised engineering analysis output.
Over the course of the rulemaking,
DOE has attained additional information
regarding the efficiency improvements
associated with different design options,
through public comments as well as
through confidential information
exchange between DOE’s contractor and
manufacturers. As a result the efforts
made by all parties in preparing and
providing this additional information,
the projections of efficiency
improvements associated with the
design options considered in the
analysis are based more on test data
than theoretical analysis. For example,
in the NODA and final rule analysis, the
energy use reduction in a batch ice
maker as a result of compressor EER
improvement is based on test data
provided both in written comments and
through confidential information
exchange.
In the NOPR and the NODA phases,
DOE has published engineering
spreadsheets that show projected energy
savings associated with specific design
options for the analyses of energy use
for the ice maker models representing
most of the ice maker equipment
classes. These results document the
analysis and have allowed stakeholders
to review details of the analysis as a
check on accuracy. DOE’s calibration of
the energy use analysis results at the
highest commercially-available
efficiency levels, described in section
IV.D.4.b, provides a check of the
analysis, specifically ensuring that the
group of design options required to
attain these highest available efficiency
levels (as predicted by the analysis) is
consistent with actual equipment. The
section presents examples of maximum
available commercial units against
which the energy use calculations are
calibrated for the highest analyzed
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efficiency levels not using permanent
magnet motors and drain water heat
exchangers. DOE conducted calibration
at this efficiency level because these
design options are not generally used in
commercially available units, thus
preventing calibration with
commercialized units at higher
efficiency levels. These calibration
comparisons, which are discussed in
section IV.D.4.b and in Chapter 5 of the
TSD, show (a) that the efficiency levels
attainable without use of permanent
magnet motors and drain water heat
exchangers have not been overestimated
by the analysis, and (b) the design
options that are projected to be required
to attain these maximum available
efficiency levels are consistent with or
conservative (more costly) as compared
with the design options used in
maximum-available ice makers that are
available for purchase.
DOE is not at liberty to release the
FREEZE energy model to the public
because it does not own the modeling
tool.
AHRI stated that DOE did not
publically provide the information
necessary for affected parties to have
adequate notice and ability to comment
on the results of the public meeting.
AHRI stated that DOE failed to
publically state a timeframe for
collecting the data it has requested.
AHRI added that the public statement
issued after the public meeting did not
indicate to whom the data should be
sent. AHRI stated their belief that
without the clarity of a defined
comment period, or the knowledge of
the next steps in the process DOE is not
following its own process rule and the
notice and comment requirements for
federal agency rulemaking. (AHRI, No.
128 at p. 6–8)
In response to AHRI’s comment, DOE
expressed willingness during the NOPR
public meeting, subject to potential legal
restrictions, to allow additional
information exchange by stakeholders
with DOE’s contractor under nondisclosure agreement. DOE also
expressed willingness to possibly
publish a NODA which would allow
stakeholders additional opportunity to
comment. (DOE, NOPR Public Meeting
Transcript, No. 70 at pp. 341–344) In
general, any information exchange
regarding a rulemaking is strictly
limited after publication of a NOPR, in
order to limit the potential for undue
influence on the process from any
particular interested party. DOE allowed
additional information exchange with
stakeholders and published a NODA to
allow additional opportunity for input.
79 FR 54215 (Sept. 11, 2014). Thus,
contrary to AHRI’s comment, with the
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additional public meeting and with the
issuance of the NODA, stakeholders
have had several opportunities to
provide input beyond the opportunities
normally provided for an energy
conservation standard rulemaking.
6. Supplemental Notice of Proposed
Rulemaking
NAFEM stated that DOE should not
issue a final rule because the revisions
in the NODA did not address each issue
raised in response to the NOPR analysis.
(NAFEM, No. 123 at p. 1) NAFEM and
AHRI both requested that the
department issue a supplemental notice
of proposed rulemaking (SNOPR) to
allow manufacturers and end users
enough time to address the substantial
changes in the analysis made between
the NOPR and NODA phases. (NAFEM,
No. 123 at p. 1; AHRI, No. 128 at p. 2)
NAFEM stated that there are many
unknowns regarding the changes made
in the NODA analysis and noted that
DOE did not identify a technologically
feasible and economically justified
standard level. NAFEM also requested
that DOE release the model used to
determine TSL standards. (NAFEM, No.
123 at p. 1)
In response to AHRI and NAFEM,
DOE notes that the modifications made
to the analyses in the NODA were based
on stakeholder participation, and each
issue raised in response to the NOPR
and NODA have been addressed in this
final rule. The objective of the NODA
was to enable stakeholders to
understand the changes made in the
basic analyses as a result of input
received during the NOPR phase, and
DOE believes that was accomplished.
Therefore, DOE does not believe that an
SNOPR is necessary for this rulemaking.
In response to NAFEM’s request for
DOE to release the model used to
determine the TSL standard, DOE
assumes that this refers to the FREEZE
model, which is discussed in section
IV.A.5. DOE is not at liberty to release
the FREEZE energy model to the public
because it does not own the modeling
tool. Regarding NAFEM’s comment
concerning identification of a
technologically feasible and
economically justified standard level,
DOE notes that the NODA did not
propose a standard level. Rather the
NODA’s purpose was to provide
stakeholders the opportunity to
comment on revisions in DOE’s
analysis.
7. Rulemaking Structure Comments
A Policy Analyst at the George
Washington University Regulatory
Studies Center commented on basic
underpinnings of the DOE energy
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conservation standards rulemaking
process. Policy Analyst commented that
DOE does not explain why
sophisticated, profit-motivated
purchasers of ACIMs would suffer from
informational deficits or cognitive
biases that would cause them to
purchase products with high lifetime
costs without demanding higher-price,
higher-efficiency products. (Policy
Analyst, No. 75 at p. 5)
Policy Analyst indicated that two of
the three problems identified by DOE,
lack of access to information and
information asymmetry, are not
addressed by the rule, indicating that
DOE’s rule is flawed. (Policy Analyst,
No. 75 at p. 6) Policy Analyst added that
only one of the problems identified by
DOE is addressed by any of the metrics
stated in the proposed rule:
Internalizing the externality of
greenhouse gas emissions. (Policy
Analyst, No. 75 at p. 7)
Policy Analyst suggested that the
proposed rule should include DOE’s
plans for how it will gather information
to assess the success of the rule and
whether its assumptions were accurate.
(Policy Analyst, No. 75 at p. 8) Policy
Analyst added that DOE should include
a timeframe for retrospective review in
its final rule. (Policy Analyst, No. 75 at
p. 8)
Policy Analyst stated that DOE should
pay attention to the linkages between
the rule and the measured outcomes in
order to increase its awareness of
mediating factors that may have
accomplished or undermined the stated
metrics absent the rule. (Policy Analyst,
No. 75 at p. 8)
In response, DOE believes there are
two main reasons that purchasers of
ACIM equipment would lack complete
information, causing them to, in Policy
Analyst’s words, ‘‘purchase products
with high lifetime costs without
demanding higher-price, higherefficiency products.’’ The first reason is
the time involved in collection and
processing of information and the
second is that the available information
is incomplete. ACIM purchasers have
access only to information that is
readily available, and would not have
ready access to information about
additional efficiency options that could
be made available to the market. The
information that is available is
dispersed in many sources, and the cost
of querying all information sources
takes the form of time taken away from
the primary business of the purchaser,
whether running a hotel or provision of
medical care. By virtue of simply
undertaking the energy conservation
standard rulemaking, DOE provides
significant information to all who are
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4665
interested via the analyses undertaken
by the rulemaking.
As the energy conservation standard
rulemaking has proceeded from the
initial framework phase through to the
final rule phase, DOE has solicited
information, purchased, examined and
tested actual ACIM products, and
performed numerous analyses to ensure
assumptions are as accurate as possible.
Once a rule is finalized, DOE continues
collecting information as well as
interacting with the industry, and such
activities will enable DOE to measure
whether the rule is achieving its
intended results—namely increasing the
efficiency of automatic commercial ice
makers.
DOE will undertake subsequent
analyses of ACIM equipment in order to
meet legislative requirements for
reviewing the standard by a date no
later than 5 years after the effective date
of new and amended standards
established by this rulemaking. DOE
follows a standard process in energy
conservation standards rulemakings,
and believes as such, that establishing
plans within this final rule for gathering
information for the next proceeding is
unnecessary.
B. Market and Technology Assessment
When beginning an energy
conservation standards rulemaking,
DOE develops information that provides
an overall picture of the market for the
equipment concerned, including the
purpose of the equipment, 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, 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 equipment
sold and offered for sale; (2) retail
market trends; (3) equipment 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 equipment under examination. DOE
researched manufacturers of automatic
commercial ice makers and made a
particular effort to identify and
characterize small business
manufacturers. See chapter 3 of the final
rule TSD for further discussion of the
market and technology assessment.
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1. Equipment Classes
In evaluating and establishing energy
conservation standards, DOE generally
divides covered equipment into classes
by the type of energy used, or by
capacity or other performance-related
feature that justifies a different standard
for equipment having such a feature. (42
U.S.C. 6295(q) and 6316(a)) In deciding
whether a feature justifies a different
standard, DOE considers factors such as
the utility of the feature to users. DOE
normally establishes different energy
conservation standards for different
equipment classes based on these
criteria.
Automatic commercial ice makers are
divided into equipment classes based on
physical characteristics that affect
commercial application, equipment
utility, and equipment efficiency. These
equipment classes are based on the
following criteria:
• Ice-making process
Æ ‘‘Batch’’ icemakers that operate on
a cyclical basis, alternating between
periods of ice production and ice
harvesting
Æ ‘‘Continuous’’ icemakers that can
produce and harvest ice
simultaneously
• Equipment configuration
Æ Ice-making head (a single-package
ice-making assembly that does not
include an ice storage bin)
Æ Remote condensing (an ice maker
consisting of an ice-making head in
which the ice is produced—but also
without an ice storage bin—and a
separate condenser assembly that
can be remotely installed,)
• With remote compressor
(compressor packaged with the
condenser)
• Without remote compressor
(compressor packaged with the
evaporator in the ice-making head)
Æ Self-contained (with storage bin
included)
• Condenser cooling
Æ Air-cooled
Æ Water-cooled
• Capacity range
Table IV.2 shows the 25 automatic
commercial ice maker equipment
classes that DOE used for its analysis in
this rulemaking. These equipment
classes were derived from existing DOE
standards and commercially available
products. The final rule adjusts these
capacity ranges, based on this analysis,
as a result of setting appropriate energy
use standards across the overall capacity
range (50 to 4,000 lb ice/24 hours) for
a given type of equipment, such as all
batch air-cooled ice-making head units.
TABLE IV.2—FINAL RULE AUTOMATIC COMMERCIAL ICE MAKER EQUIPMENT CLASSES USED FOR ANALYSIS
Type of ice maker
Equipment type
Type of
condenser cooling
Batch ....................................
Ice-Making Head ...............................................................
Water ...................................
Air ........................................
Remote Condensing (but not remote compressor) ..........
Air ........................................
Remote Condensing and Remote Compressor ...............
Air ........................................
Self-Contained Unit ...........................................................
Water ...................................
Air ........................................
Continuous ...........................
Ice-Making Head ...............................................................
Water ...................................
Air ........................................
Remote Condensing (but not remote compressor) ..........
Air ........................................
Remote Condensing and Remote Compressor ...............
Air ........................................
Self-Contained Unit ...........................................................
Water ...................................
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Air ........................................
Batch type and continuous type ice
makers are distinguished by the
mechanics of their respective icemaking processes. Continuous type ice
makers are so named because they
simultaneously produce and harvest ice
in one continuous, steady-state process.
The ice produced in continuous
processes is called ‘‘flake’’ ice or
‘‘nugget’’ ice, which can both be a ‘‘soft’’
ice with high liquid water content, in
the range from 10 to 35 percent, but can
also be subcooled, i.e. be entirely frozen
and at temperature lower than 32 °F.
Continuous type ice makers were not
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included in the EPACT 2005 standards
and therefore were not regulated by
existing DOE energy conservation
standards.
Existing energy conservation
standards cover batch type ice makers
that produce ‘‘cube’’ ice, which is
defined as ice that is fairly uniform,
hard, solid, usually clear, and generally
weighs less than two ounces (60 grams)
per piece, as distinguished from flake,
crushed, or fragmented ice. 10 CFR
431.132 Batch ice makers alternate
between freezing and harvesting periods
and therefore produce ice in discrete
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Harvest capacity rate
lb ice/24 hours
≥50 and <500
≥500 and <1,436
≥1,436 and <4,000
≥50 and <450
≥450 and <4,000
≥50 and <1,000
≥1,000 and <4,000
≥50 and <934
≥934 and <4,000
≥50 and <200
≥200 and <4,000
≥50 and <175
≥175 and <4,000
≥50 and <900
≥900 and <4,000
≥50 and <700
≥700 and <4,000
≥50 and <850
≥850 and <4,000
≥50 and <850
≥850 and <4,000
≥50 and <900
≥900 and <4,000
≥50 and <700
≥700 and <4,000
batches rather than in a continuous
process. After the freeze period, hot gas
is typically redirected from the
compressor discharge to the evaporator,
melting the surface of the ice cubes that
is in contact with the evaporator
surface, enabling them to be removed
from the evaporator. The water that is
left in the sump at the end of the
icemaking part of the cycle is purged
(drained from the unit), removing with
it the impurities that could decrease ice
clarity form scale (the result of
dissolved solids in the incoming water
coming out of solution) on the ice maker
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surfaces. Consequently, batch type ice
makers typically have higher potable
water usage than continuous type ice
makers.
After the publication of the
Framework document, several parties
commented that machines producing
‘‘tube’’ ice, which is created in a batch
process with both freeze and harvest
periods similar to the process used for
cube ice, should also be regulated. DOE
notes that tube ice machines of the
covered capacity range that produce ice
fitting the definition for cube type ice
are covered by the current standards,
whether or not they are referred to as
cube type ice makers within the
industry. Nonetheless, DOE has
addressed the commenters’ suggestions
by emphasizing that all batch type ice
machines are within the scope of this
rulemaking, as long as they fall within
the covered capacity range of 50 to
4,000 lb ice/24 hours. This includes
tube ice machines and other batch type
ice machines (if any) that produce ice
that does not fit the definition of cube
type ice. To help clarify this issue, DOE
now refers to all batch automatic
commercial ice makers as ‘‘batch type
ice makers,’’ regardless of the shape of
the ice pieces that they produce. 77 FR
1591 (Jan. 11, 2012).
During the April 2014 NOPR public
meeting and in subsequent written
comments, a number of stakeholders
addressed issues related to proposed
equipment classes and the inclusion of
certain types of equipment in the
analysis. These topics are discussed in
this section.
a. Cabinet Size
In the March 2014 NOPR, DOE
indicated that it was not proposing to
create separate equipment classes for
space-constrained units. DOE requested
comment on this issue in the
preliminary analysis phase. Few
stakeholders commented on whether
DOE should consider establishing
equipment classes based on cabinet size.
Earthjustice supported such an
approach, while Manitowoc suggested
that such an approach would be
complicated. (Earthjustice, Preliminary
Analysis Public Meeting Transcript, No.
42 at pp. 90–91; Manitowoc,
(Manitowoc, Preliminary Analysis
Public Meeting Transcript, No. 42 at p.
91)) DOE also reviewed size/efficiency
trends of commercially available ice
makers and concluded that the data do
not show a definitive trend suggesting
specific size limits for space-constrained
classes. 79 FR 14846, at 14862 (March
17, 2014).
In response to the March 2014 NOPR,
AHRI and NAFEM commented that DOE
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did not conduct analysis for the full
range of product offerings in the market.
(AHRI, No. 93 at p. 12–13; NAFEM, No.
82 at p. 4) AHRI, NAFEM, and
Manitowoc commented that DOE’s
analysis did not take into account the
difficulty associated with increasing
cabinet volume for 22-inch models (i.e.
ice makers that are 22 inches wide).
(AHRI, No. 93 at p. 12–13; Manitowoc,
No. 92 at p. 2; NAFEM, No. 82 at p. 4)
Manitowoc added that the engineering
analysis focused on 30-inch cabinets
and that the design options may not all
fit within the 22-inch cabinet models.
(Manitowoc, No. 92 at p. 2 and p. 26–
27) AHRI stated that they had data
showing that 22-inch units cannot
accommodate evaporator or condenser
growth without chassis growth which is
not possible for these size-restricted
units. AHRI noted that DOE included
chassis size increases for some
equipment classes without taking into
account in the engineering analysis the
special case of 22-inch ice makers.
(AHRI, No. 93 at p. 12–13) NAFEM
specifically requested that DOE
differentiate between 22-inch and 30inch IMH–A–Small–B machines, since
22-inch models cannot achieve
increases in cabinet volume and 30-inch
models cannot be substituted for 22inch models. (NAFEM, No. 82 at p. 4)
Hoshizaki also urged DOE to take 22inch units into special consideration in
the analysis. (Hoshizaki, No. 86 at p. 8)
Manitowoc commented that 22-inch
air-cooled ice-making heads are growing
in importance due to the shrinking size
of restaurant kitchens and that such
machines cannot grow in height because
they are already very tall. Manitowoc
asserted that this product category may
disappear if efficiency standards require
significant chassis size growth.
(Manitowoc, Public Meeting Transcript,
No. 70 at p. 162–164)
However, the Northwest Energy
Efficiency Alliance (NEEA) stated that
they believe that DOE appropriately
considered the issues concerning
increased chassis size, citing DOE’s
consideration of chassis size increase
only for three of the twenty-two classes
analyzed, and the fact that DOE
considered only increases in height, not
increases in footprint. (NEEA, No. 91 at
p. 1–2)
DOE has maintained its position from
the NOPR and has not created a new
equipment class for 22-inch ACIMs.
However, in response to commenters
DOE revised the NOPR analysis to
consider the size restrictions and
applications of 22-inch wide ice makers
in its revised analysis. Specifically, DOE
has developed cost-efficiency curves for
22-inch width units in the IMH–A–
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Small–B, IMH–A–Large–B, and IMH–
W–Small–B equipment classes. These
curves were used in the LCC and NIA
analyses in the evaluation of efficiency
levels for classes for which 22-inch
ACIMs are an important category. The
LCC and NIA analyses were also revised
to more carefully consider the impact of
size restrictions in applications for 30inch units—this is discussed in greater
detail in section IV.G.2. Ultimately these
revisions in the analyses led to selection
of less stringent efficiency levels for
some of the affected classes.
b. Large-Capacity Batch Ice Makers
In the November 2010 Framework
document for this rulemaking, DOE
requested comments on whether
coverage should be expanded from the
current covered capacity range of 50 to
2,500 lb ice/24 hours to include ice
makers producing up to 10,000 lb ice/
24 hours. All commenters agreed with
expanding the harvest capacity
coverage, and all but one of the
commenters supported or accepted an
upper harvest capacity cap of 4,000 lb
ice/24 hours, which would be consistent
with the current test procedure, AHRI
Standard 810–2007. Most commenters
categorized ice makers with harvest
capacities above 4,000 lb ice/24 hours as
industrial rather than commercial. Since
the publication of the framework
analysis, DOE revised the test
procedure, with the final rule published
in January 2012, to include all batch and
continuous type ice makers with
capacities between 50 and 4,000 lb ice/
24 hours. 77 FR 1591, 1613–14. In the
2012 test procedure final rule, DOE
noted that 4,000 lb ice/24 hours
represented a reasonable limit for
commercial ice makers, as larger-sized
ice makers were generally used for
industrial applications and testing
machines up to 4,000 lb was consistent
with AHRI 810–2007. 77 FR 1591 (Jan.
11, 2012). To be consistent with the
majority of the framework comments,
during the preliminary analysis DOE
discussed setting the upper harvest
capacity limit to 4,000 lb ice/24 hours,
even though there are few ice makers
currently produced with capacities
ranging from 2,500 to 4,000 lb ice/24
hours. 77 FR 3404 (Jan. 24, 2012) DOE
proposed in the March 2014 NOPR to
set efficiency standards that include all
ice makers in this extended capacity
range and has maintained this position
in this final rule.
PG&E and SDG&E commented that
they support the inclusion of previously
unregulated equipment classes into the
scope of this rulemaking, including
equipment with a capacity range up to
4,000 lb/24 hour. (PG&E and SDG&E,
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No. 89 at p. 1) However, Hoshizaki,
NAFEM, and AHRI commented that
DOE should refrain from regulating
products with capacities above 2,500 lb
ice/24 hours, if there are not enough
models in this category for DOE to
directly evaluate. (Hoshizaki, No. 86 at
p. 9; Hoshizaki, No. 124 at p. 2; AHRI,
No. 93 at p. 16; NAFEM, No. 123 at
p. 2) Hoshizaki commented that large
units perform differently than small
units in the ways that their compressors
and condensers interact. Hoshizaki
requested that DOE not add higher
levels to the standard extended beyond
2,000 lb ice/24 hours, but have a flat
level no more stringent than the
standard at 2,000 lb ice/24 hours for
higher capacity equipment. (Hoshizaki,
No. 124 at p. 2)
DOE acknowledges that there are
currently few automatic commercial ice
makers with harvest capacities above
2,500 lb ice/24 hours. However, AHRI
has extended the applicability of its test
standard, AHRI Standard 810–2007 with
Addendum 1, ‘‘Performance Rating of
Automatic Commercial Ice Makers,’’ to
ice makers up to 4,000 lb ice/24 hours.
Likewise, DOE extended the
applicability of its test procedure to the
same range. 77 FR 1591 (January 11,
2012). Stakeholders have not cited
reasons that ice makers with capacities
greater than 2,000 lb ice/24 hours would
not be able to achieve the same
efficiency levels as those producing
2,000 lb ice/24 hours. Because it is
possible that batch-type ice makers with
harvest capacities from 2,500 to 4,000 lb
ice/24 hours will be manufactured in
the future, DOE does not find it
unreasonable to set standards in this
rulemaking for batch type ice makers
with harvest capacities in the range up
to 4,000 lb ice/24 hours. Therefore, DOE
maintains its position to include largecapacity batch type ice makers in the
scope of this rulemaking. In response to
Hoshizaki’s comment, DOE notes that
each product class has flat levels, i.e.
efficiency levels that do not vary with
harvest capacity, beyond 2,000 lb ice/24
hours.
c. Regulation of Potable Water Use
Under EPACT 2005, water used for
ice—referred to as potable water—was
not regulated for automatic commercial
ice makers.
The amount of potable water used
varies significantly among batch type
automatic commercial ice makers (i.e.,
cube, tube, or cracked ice machines).
Continuous type ice makers (i.e., flake
and nugget machines) convert
essentially all of the potable water to
ice, using roughly 12 gallons of water to
make 100 lb ice. Batch type ice makers
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use an additional 3 to 38 gallons of
water in the process of making 100 lb
ice. This additional water is referred to
as ‘‘dump or purge water’’ and is used
to cleanse the evaporator of impurities
that could interfere with the ice-making
process.
As indicated in the preliminary
analysis and NOPR, DOE is not setting
potable water limits for automatic
commercial ice makers.
The Natural Resource Defense
Council (NRDC) commented that they
previously urged the Department to
propose standards for potable water use
in batch type ice makers and that failure
to do so is short-sighted, given the
increasing severity of drought
conditions in many states, and may
cause states to consider their own water
use standards for ice makers. (NRDC,
No. 90 at p. 54–1) NRDC urged DOE to
reconsider its decision not to evaluate
and set standards for potable water use.
NRDC noted that EPCA was amended in
1992 explicitly to include water
conservation as one of its purposes.
(NRDC, No. 90 at p. 1)
PG&E and SDG&E also recommended
that DOE establish a maximum potable
water use requirement. PG&E and
SDG&E also added that in the event that
DOE maintains that there is ambiguity
in EPACT 2005 on whether DOE is
required to regulate water usage and
uses its discretion not to mandate a
potable water standard PG&E and
SDG&E request that DOE comment
whether states are preempted from
establishing such a standard. (PG&E and
SDG&E, No. 89 at p. 4)
In response to comments from NRDC,
and PG&E and SDG&E, DOE was not
given a specific mandate by Congress to
regulate potable water. EPCA, as
amended, explicitly gives DOE the
authority to regulate water use in
showerheads, faucets, water closets, and
urinals (42 U.S.C. 6291(6), 6295(j) and
(k)), clothes washers (42 U.S.C.
6295(g)(9)), dishwashers (42 U.S.C.
6295(g)(10)), commercial clothes
washers (42 U.S.C. 6313(e)), and batch
(cube) commercial ice makers. (42
U.S.C. 6313(d)) With respect to batch
commercial ice makers (cube type
machines), however, Congress explicitly
set standards in EPACT 2005 at 42
U.S.C. 6313(d)(1) only for condenser
water and noted in a footnote to the
table setting the standards that potable
water use was not included.24 Congress
thereby recognized both types of water,
and did not provide direction to DOE
with respect to potable water standards.
This ambiguity gives the DOE
considerable discretion to regulate or
24 Footnote
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Frm 00024
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not regulate potable water. The U.S.
Supreme Court has determined that,
when legislative intent is ambiguous, a
government agency may use its
discretion in interpreting the meaning of
a statute, so long as the interpretation is
reasonable.25 In the case of ice makers,
EPACT 2005 is ambiguous on the
subject of whether DOE must regulate
water usage for purposes other than
condenser water usage in cube-making
machines, and DOE has chosen to use
its discretion not to mandate a standard
in this case. Pursuant to 42 U.S.C.
6297(b) and (c), preemption applies
with respect to covered products and no
State regulation concerning energy
efficiency, energy use, or water use of
such covered product shall be effective
with respect to such product unless the
State regulation meets the specified
criteria under these provisions.
DOE elected to not set potable water
limits for automatic commercial ice
makers in order to allow manufacturers
to retain flexibility in this aspect of ice
maker design. The regulation of ice
maker energy use does in itself make
high levels of potable water use
untenable because energy use does
increase as potable water use increases,
since the additional water must be
cooled down, diverting refrigeration
capacity from the primary objective of
cooling and freezing the water that will
be delivered from the machine as ice.
DOE notes that ENERGY STAR has
adopted potable water limits for
ENERGY STAR-compliant ice makers at
15 gal/100 lb ice for continuous
equipment classes, 20 gal/100 lb ice for
IMH and RCU batch classes, and 25 gal/
100 lb ice for SCU batch classes.26
d. Regulation of Condenser Water Use
As previously noted in section II.B.1,
EPACT 2005 prescribes maximum
condenser water use levels for watercooled cube type automatic commercial
ice makers. (42 U.S.C. 6313(d)) 27 For
units not currently covered by the
standard (continuous machines of all
harvest rates and batch machines with
harvest rates exceeding 2,500 lb ice/24
hours), there currently are no limits on
condenser water use.
25 Nat’l Cable & Telecomms. Ass’n v. Brand X
Internet Servs., 545 U.S. 967, 986 (2005) (quoting
Chevron U.S.A. Inc. v. Natural Res. Def. Council,
Inc., 467 U.S. 837, 845 (1984)).
26 https://www.energystar.gov/index.cfm?c=comm_
ice_machines.pr_crit_comm_ice_machines.
27 The table in 42 U.S.C. 6313(d)(1) states
maximum energy and condenser water usage limits
for cube type ice machines producing between 50
and 2,500 lb of ice per 24 hour period (lb ice/24
hours). A footnote to the table states explicitly the
water limits are for water used in the condenser and
not potable water used to make ice.
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In the preliminary analysis and the
NOPR, DOE indicated its intent to
primarily focus the automatic
commercial ice maker rulemaking on
energy use. DOE also noted that DOE is
not bound by EPCA to comprehensively
evaluate and propose reductions in the
maximum condenser water
consumption levels, and likewise has
the option to allow increases in
condenser water use, if this is a costeffective way to improve energy
efficiency.
In the preliminary analysis, DOE
stated that EPCA’s anti-backsliding
provision in section 325(o)(1), which
lists specific products for which DOE is
forbidden from prescribing amended
standards that increase the maximum
allowable water use, does not include
ice makers. However in response to the
preliminary analysis, Earthjustice
asserted that DOE lacks the authority to
relax condenser water limits for watercooled ice makers. Earthjustice argued
that the failure of section 325(o)(1) to
specifically call out ice maker
condenser water use as a metric that is
subject to the statute’s prohibition
against the relaxation of a standard is
not determinative. On the contrary,
Earthjustice maintained that the plain
language of EPCA shows that Congress
intended to apply the anti-backsliding
provision to ice makers. Earthjustice
commented that section 342(d)(4)
requires DOE to adopt standards for
ice-makers ‘‘at the maximum level that
is technically (DOE interprets the
comment to mean technologically)
feasible and economically justified, as
provided in [section 325(o) and (p)].’’
(42 U.S.C. 6313(d)(4)) Earthjustice stated
that, by referencing all of section 325(o),
the statute pulls in each of the distinct
provisions of that subsection, including,
among other things, the anti-backsliding
provision, the statutory factors
governing economic justification, and
the prohibition on adopting a standard
that eliminates certain performance
characteristics. By applying all of
section 325(o) to ice-makers, section
342(d)(4) had already made the
anti-backsliding provision applicable to
condenser water use, according to
Earthjustice. Finally, Earthjustice stated
that even if DOE concludes that the
plain language of EPCA is not clear on
this point, the only reasonable
interpretation is that Congress did not
intend to grant DOE the authority to
relax the condenser water use standards
for ice makers. Earthjustice added that
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the anti-backsliding provision is one of
EPCA’s most powerful tools to improve
the energy and water efficiency of
appliances and commercial equipment,
and Congress would presumably speak
clearly if it intended to withhold its
application to a specific product.
(Earthjustice, No. 47 at pp. 4–5)
In the NOPR DOE maintained that the
42 U.S.C. Sec. 6295(o)(1) antibacksliding provisions apply to water in
only a limited set of residential
appliances and fixtures. Therefore, an
increase in condenser water use would
not be considered backsliding under the
statute. Nevertheless, the DOE did not
include increases in condenser water
use as a technology option for the
NOPR, NODA, and final rule.
In response to the NOPR, NRDC stated
that they disagree that DOE may
lawfully relax water use standards.
NRDC added that even if DOE were
correct in stating that EPCA’s antibacksliding provision does not apply, as
explored in EarthJustice’s comment,
DOE cannot relax the water efficiency
levels set by Congress itself. (NRDC, No.
90 at p. 1)
In this rule, DOE is not revising its
NOPR position regarding the
application of anti-backsliding to ACIM
condenser water use. Nevertheless, DOE
did not consider design options that
would represent increase in condenser
water use in its final rule analysis.
e. Continuous Models
The EPACT 2005 amendments to
EPCA did not set standards for
continuous type ice makers. Pursuant to
EPCA, DOE is required to set new or
amended energy conservation standards
for automatic commercial ice makers to:
(1) Achieve the maximum improvement
in energy efficiency that is
technologically feasible and
economically justified; and (2) result in
significant conservation of energy. (42
U.S.C. 6295(o)(2)(A) and (o)(3)(B);
6313(d)(4))
Hoshizaki stated that due to their
small market share, continuous models
should be considered separately from
batch machines. (Hoshizaki, No, 124 at
p. 1)
DOE notes that it has conducted
analysis for continuous models as part
of separate equipment classes than
batch type models and has set different
energy standards for them.
f. Gourmet Ice Machines
AHRI stated that this rulemaking has
ignored the niche market of gourmet ice
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4669
cubes. AHRI stated that gourmet ice
cubes are two to three times larger than
standard ice cubes. They are also harder
and denser than conventional machinemade ice and require more energy to
produce. AHRI noted that this issue
impacts small business manufacturers.
(AHRI, No. 128 at p. 5)
In response to AHRI’s comment
regarding gourmet ice makers, DOE has
not conducted separate analysis for such
equipment. DOE has, however,
considered small business impacts, as
discussed in section IV.J.3.f. DOE notes
that the ACIM rulemaking has provided
stakeholders many opportunities to
provide comment on the issues that
would be important to consider in the
analysis, including potential equipment
classes associated with different types of
ice, whether different types of ice
provide specific utility that would be
the basis of considering separate
equipment classes, and any other issues
associated with such ice that might
affect the analysis. DOE does not have
nor did it receive in response to requests
for comments sufficient specific
information to evaluate whether larger
ice has specific consumer utility, nor to
allow separate evaluation for such
equipment of costs and benefits
associated with achieving the efficiency
levels considered in the rulemaking. In
the absence of information, DOE cannot
conclude that this type of ice has unique
consumer utility justifying
consideration of separate equipment
classes. DOE notes that manufacturers of
this equipment have the option seeking
exception relief pursuant to 41 U.S.C.
7194 from DOE’s Office of Hearings and
Appeals.
2. Technology Assessment
As part of the market and technology
assessment, DOE developed a
comprehensive list of technologies to
improve the energy efficiency of
automatic commercial ice makers,
shown in Table IV.3. Chapter 3 of the
final rule TSD contains a detailed
description of each technology that DOE
identified. DOE only considered in its
analysis technologies that would impact
the efficiency rating of equipment as
tested under the DOE test procedure.
The technologies identified by DOE
were carried through to the screening
analysis, which is discussed in section
IV.C.
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The section below addresses the
potential consideration of another
technology option.
a. Alternative Refrigerants
The Environmental Investigation
Agency (EIA Global) urged DOE to
include hydrocarbon refrigerants as an
ACIM technology option. EIA Global
expressed their concern that DOE’s
analysis will be incomplete without the
inclusion of hydrocarbon refrigerants
and that the high global warming
potential (GWP) of current ACIM
refrigerants will further damage the
stability of the climate, thus offsetting
the efficiency gains associated with
standards. (EIA Global, No. 80 at p. 1)
EIA Global commented that it is likely
that EPA will include hydrocarbons as
acceptable ACIM refrigerants in the near
future and urged DOE to bring a SNAP
petition to do so. EIA Global added that
accepting hydrocarbons for use in
ACIMs with charge sizes of 150g or less
is highly likely and that according to a
United Nations Environment
Programme (UNEP) report, such
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refrigerants have lower viscosity,
resulting in improved cooling efficiency
and reducing energy consumption by 18
percent. (EIA Global, No. 80 at p. 2) EIA
Global noted that DOE should set
standards that anticipate future
alternatives, rather than being limited to
what is available today. (EIA Global, No.
80 at p. 4–5)
EIA Global stated that including
hydrocarbon refrigerants in the analysis
will be of little burden to DOE because
Scotsman, Hoshizaki, and Manitowoc
already sell hydrocarbon machines
throughout Europe and other
international markets and noted that
these three manufacturers have
observed energy savings associated with
use of these refrigerants. (EIA Global,
No. 80 at p. 1–4)
In response to EIA Global’s
comments, DOE notes that hydrocarbon
refrigerants have not yet been approved
by the EPA SNAP program and hence
cannot be considered as a technology
option in DOE’s analysis. DOE also
notes that, while it is possible that HFC
refrigerants currently used in automatic
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commercial ice makers may be
restricted by future rules, DOE cannot
speculate on the outcome of a
rulemaking in progress and can only
consider in its rulemakings rules that
are currently in effect. Therefore, DOE
has not included possible outcomes of
a potential EPA SNAP rulemaking. This
position is consistent with past DOE
rulings, such as in the 2014 final rule for
commercial refrigeration equipment. 79
FR 17725 (March 28, 2014) DOE notes
that recent proposals by the EPA to
allow use of hydrocarbon refrigerants or
to impose new restrictions on the use of
HFC refrigerants do not address
automatic commercial ice maker
applications. 79 FR 46126 (August 6,
2014) 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
other relevant agencies, will continue to
work with industry and other
stakeholders to identify safer and more
sustainable alternatives to HFCs while
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evaluating energy efficiency standards
for this equipment. As mentioned in
section IV.A.4, if a manufacturer
believes that its design is subjected to
undue hardship by regulations, the
manufacturer may petition DOE’s Office
of Hearing and Appeals (OHA) for
exception relief or exemption from the
standard pursuant to OHA’s authority
under section 504 of the DOE
Organization Act (42 U.S.C. 7194), as
implemented at subpart B of 10 CFR
part 1003. OHA has the authority to
grant such relief on a case-by-case basis
if it determines that a manufacturer has
demonstrated that meeting the standard
would cause hardship, inequity, or
unfair distribution of burdens.
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C. Screening Analysis
In the technology assessment section
of this final rule, DOE presents an initial
list of technologies that can improve the
energy efficiency of automatic
commercial ice makers. The purpose of
the screening analysis is to evaluate the
technologies that improve equipment
efficiency to determine which of these
technologies is suitable for further
consideration in its analyses. To do this,
DOE uses four screening criteria—
design options will be removed from
consideration if they are not
technologically feasible; are not
practicable to manufacture, install, or
service; have adverse impacts on
product utility or product availability;
or have adverse impacts on health or
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4671
safety. 10 CFR part 430, subpart C,
appendix A, section (4)(a)(4). See
chapter 4 of the final rule TSD for
further discussion of the screening
analysis. Another consideration is
whether a design option provides a
unique pathway towards increasing
energy efficiency and that pathway is a
proprietary design that a manufacturer
can only get from one source. In this
instance, such design option would be
eliminated from consideration because
it would require manufacturers to
procure it from a sole source. Table IV.4
shows the EPCA criteria and additional
criteria used in this screening analysis,
and the design options evaluated using
the screening criteria.
BILLING CODE 6450–01–P
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.
T a ble IV 4 J us tifi f lOB fior Elimmaf mg T ech no Iogy Of
.
ICa
'P'IODS f rom F urther Consideration
Not Considered in the
Analysis for Other
Reasons
EPCA Criteria for
Screening
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Operation
Enhanced Fin Surfaces
Brazed Plate Condenser
Microchannel Condenser
Technology Options to Reduce
Evaporator Thermal Cycling
Technology Options Which
Reduce Harvest Meltage or
Reduce Harvest Time
Tube Evaporator
Configuration
Improved or Thicker
Insulation
Larger Diameter Suction Line
Smart Technologies
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Table IV.5 contains the list of technologies that remained after the screening analysis.
Table IV.S Technology Options for Automatic Commercial Ice Makers that were Screened
In
Batch Ice
Makers
Continuous
Ice Makers
Improved compressor efficiency
Increased surface area
..j
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Increased air flow
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Compressor
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Condenser
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Air-cooled
only
Water-cooled
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Technology Options
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
mstockstill on DSK4VPTVN1PROD with RULES2
a. General Comments
Manitowoc expressed its agreement
with the screening analysis.
(Manitowoc, No. 92 at p. 3) However,
Scotsman requested that the following
additional criteria be used in the
screening analysis: Impact on end-user
facility and operations, impact on enduser profit-generating beverage sales,
impact on machine footprint, impact on
end-user ‘‘repair existing’’ or ‘‘purchase
new’’ decision hierarchy, impact on
ACIM service and installation network
support capability, and impact on
manufacturer component tooling/fixture
obsolescence prior to depreciation.
(Scotsman, No. 85 at p. 3b–4b)
In response to Scotsman comment,
DOE notes that while DOE’s screening
analysis specifically focuses on the four
criteria identified in the process rule
(see 10 CFR part 430, subpart C,
appendix A, section (4)(a)(4)), some of
the suggested screening criteria outlined
in Scotsman’s comment are taken into
account in other parts of the analysis.
Specifically, impacts to end user facility
and operations, including installations
costs, are considered in the life cycle
cost analysis described in section IV.G.
Impacts regarding manufacturing
tooling are examined in the
manufacturing impact analysis
described in section IV.J.
b. Drain Water Heat Exchanger
Batch ice makers can benefit from
drain water thermal exchange that cools
the potable water supply entering the
sump, thereby reducing the energy
required to cool down and freeze the
water. Technological feasibility is
demonstrated by one commercially
available drain water thermal heat
exchanger that is currently sold only for
aftermarket installation. This product is
designed to be installed externally to the
ice maker, and both drain water and
supply water are piped through the
device.
Drain water heat exchangers, both
internally mounted and externally
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mounted, are design options that can
increase the energy efficiency of
automatic commercial ice makers. The
current test procedures would give
manufacturers credit for efficiency
improvement of drain water heat
exchangers, including externally
mounted drain water heat exchangers as
long as they are provided with the
machine and the installation
instructions for the machine indicate
that the heat exchangers are part of the
machine and must be installed as part
of the overall installation.
In response to the NODA, Manitowoc
stated that drain water heat exchangers
have not been proven in the industry
(DOE assumes that this comment
addresses issues such as their reliability
rather than their potential for energy
savings) and their use is likely to result
in lower reliability due to issues with
fouling and clogging associated with
mineral particles that naturally
accumulate in the dump water for batch
cycle machines. Manitowoc also added
that the high costs for drain water heat
exchangers are not justified by their
efficiency gains. (Manitowoc, No. 126 at
p. 2) AHRI stated that a drain water heat
exchanger cannot reasonably be
implemented in a 22-inch IMH–A–
Small–B unit. (AHRI, No. 128 at p. 2)
DOE notes that drain water heat
exchangers have been discussed as a
possible technology option from the
framework stage of this rulemaking.
DOE has investigated the feasibility of
drain water heat exchangers through
review of product literature, patents,
reports on installations, and product
teardowns, and has also conducted
testing to evaluate the claims of
efficiency improvement for the
technology. While fouling of the heat
exchanger is a potential concern based
on the higher mineral concentration in
dump water, heat exchangers designed
for use with ice makers have been
designed with electrically insulated
gaskets to substantially reduce
deposition of particulates on heat
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exchanger surfaces.28 Moreover, drain
water heat exchangers would also
benefit from typical maintenance of ice
machines that includes dissolution of
such mineral deposits on all
components that come into contact with
potable water. DOE is not aware of data
showing that the units sold have
substantial reliability issues as a
consequence of fouling in retrofit
applications. Further, Manitowoc has
not provided information or test data
showing that they would reduce
reliability. DOE also notes that
answering the question of whether the
inclusion of a drain water heat
exchanger is cost-effective is a goal of
the DOE analyses and is not considered
during the screening analysis. DOE has
examined the added cost of a drain
water heater along with the energy
savings resulting from its use and has
found drain water heat exchangers to be
cost justified for certain equipment
classes.
In response to AHRI’s comment
suggesting that drain water heat
exchangers may not fit in a 22-inch
IMH–A–Small–B cabinet, DOE notes
that the heat exchanger would be
mounted outside the unit, rather than
enclosed within the cabinet. If AHRI’s
comment did not mean to indicate that
the objection was to placement of the
heat exchanger within the unit, the
comment also did not make clear why
such a component could not be
implemented specifically for a 22-inch
wide unit.
In response to AHRI’s comment
suggesting that drain water heat
exchangers may not fit in a 22-inch
IMH–A–Small–B cabinet, DOE notes
that the heat exchanger would be
mounted outside the unit, rather than
enclosed within the cabinet. If AHRI’s
comment did not mean to indicate that
the objection was placement of the heat
exchanger within the unit, the comment
also did not make clear why such a
component could not be implemented
28 Welch, D.L., et al., U.S. Patent No. 5,555,734,
Sep. 17, 1996.
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specifically for a 22-inch wide unit.
DOE did screen in this technology.
c. Tube Evaporator Design
Among the technologies that DOE
considered were tube evaporators that
use a vertical shell and tube
configuration in which refrigerant
evaporates on the outer surfaces of the
tubes inside the shell, and the freezing
water flows vertically inside the tubes to
create long ice tubes that are cut into
smaller pieces during the harvest
process. Some of the largest automatic
commercial ice makers in the RCU–
NRC–Large–B and the IMH–W–Large–B
equipment classes use this technology.
However, DOE concluded that
implementation of this technology for
smaller capacity ice makers would
significantly impact equipment utility,
due to the greater weight and size of
these designs, and to the altered ice
shape. DOE noted that available tube ice
makers (for capacities around 1,500 lb
ice/24 hours and 2,200 lb ice/24 hours)
were 150 to 200 percent heavier than
comparable cube ice makers. Based on
the impacts to utility of this technology,
DOE screened out tube evaporators from
consideration in this analysis.
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d. Low Thermal Mass Evaporator Design
DOE’s analysis did not consider low
thermal mass evaporator designs.
Reducing evaporator thermal mass of
batch type ice makers reduces the heat
that must be removed from the
evaporator after the harvest cycle, and
thus decreases refrigeration system
energy use. DOE indicated during the
preliminary analysis that it was
concerned about the potential
proprietary status of such evaporator
designs, since DOE is aware of only one
manufacturer that produces equipment
with such evaporators. DOE has not
altered its decision to screen out this
technology in its analysis.
e. Microchannel Heat Exchangers
Through discussions with
manufacturers, DOE has determined
that there are no instances of energy
savings associated with the use of
microchannel heat exchangers in ice
makers. Manufacturers also noted that
the reduced refrigerant charge
associated with microchannel heat
exchangers can be detrimental to the
harvest performance of batch type ice
makers, as there is not enough charge to
transfer heat to the evaporator from the
condenser.
DOE contacted microchannel
manufacturers to determine whether
there were energy savings associated
with use of microchannel heat
exchangers in automatic commercial ice
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makers. These microchannel
manufacturers noted that investigation
of microchannel was driven by space
constraints rather than efficiency.
Because the potential for energy
savings is inconclusive, based on DOE
analysis as well as feedback from
manufacturers and heat exchanger
suppliers, and based on the potential
utility considerations associated with
compromised harvest performance in
batch type ice makers associated with
this heat exchanger technology’s
reduced refrigerant charge, DOE
screened out microchannel heat
exchangers as a design option in this
rulemaking.
f. Smart Technologies
While there may be energy demand
benefits associated with use of ‘‘smart
technologies’’ in ice makers in that they
reduce energy demand (e.g., shift the
refrigeration system operation to a time
of utility lower demand), DOE is not
aware of any commercialized products
or prototypes that also demonstrate
improved energy efficiency in automatic
commercial ice makers. Demand savings
alone do not impact energy efficiency,
and DOE cannot consider technologies
that do not offer energy savings as
measured by the DOE test procedure.
Since the scope of this rulemaking is to
consider energy conservation standards
that increase the energy efficiency of
automatic commercial ice makers this
technology option has been screened
out because it does not save energy as
measured by the test procedure.
g. Motors
Manufacturers Follett and Manitowoc
provided comment regarding the use of
higher efficiency motors in ACIMs.
Follett stated that they are not aware of
gear motors more efficient than the
hypoid motors they use. (Follett, No. 84
at p. 5) Manitowoc stated that they do
not consider brushless direct-current
(DC) fan motors to be cost effective.
(Manitowoc, Public Meeting Transcript,
No. 70 at p. 157–159)
In response to Follett’s comment, DOE
notes that its consideration of motor
efficiency applies to the prime mover
portion of the motor, not the gear drive.
Gear motor assemblies include both a
motor which converts electricity to shaft
power and a gear drive, which converts
the high rotational speed of the motor
shaft to the rotational speed required by
the auger. DOE screened in higher
efficiency options for the motor, but did
not consider higher-efficiency gear
drives. In response to Manitowoc, the
cost-effectiveness of a given technology,
such as DC fan motors, is not a factor
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that is considered when screening
technologies.
D. Engineering Analysis
The engineering analysis determines
the manufacturing costs of achieving
increased efficiency or decreased energy
consumption. DOE historically has used
the following three methodologies to
generate the manufacturing costs
needed for its engineering analyses: (1)
The design-option approach, which
provides the incremental costs of adding
to a baseline model design options that
will 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.
As discussed in the Framework
document, preliminary analysis, and
NOPR analysis, DOE conducted the
engineering analyses for this rulemaking
using an approach that combines the
efficiency level, design option, and
reverse engineering approaches to
develop cost-efficiency curves for
automatic commercial ice makers. DOE
established efficiency levels defined as
percent energy use lower than that of
baseline efficiency products. DOE’s
engineering analysis is based on
illustrating a typical design path to
achieving the specified percentage
efficiency improvements at each level
through the incorporation of a group of
design options. Finally, DOE developed
manufacturing cost models based on
reverse engineering of products to
develop baseline manufacturer
production costs (MPCs) and to
supplement incremental cost estimate
associated with efficiency
improvements.
DOE directly analyzed 19 ice maker
configurations representing different
classes, capacities, and physical sizes.
To develop cost-efficiency curves, DOE
collected information from multiple
sources to characterize the
manufacturing cost and energy use
reduction of each of the design options
or grouping of design options. DOE
conducted an extensive review of
product literature on hundreds of ice
makers and selected 50 of them for
testing and reverse engineering.
To gather cost and performance
information of different ice maker
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design strategies, DOE conducted
interviews with ice maker
manufacturers and component vendors
of compressors and fan motors during
the preliminary, NOPR, NODA, and
final phases of the rulemaking Cost
information from the vendor interviews
and discussions with manufacturers
provided input to the manufacturing
cost model. DOE determined
incremental costs associated with
specific design options from vendor
information, discussion with
manufacturers, and the cost model. DOE
calculated energy use reduction based
on test data, data provided in
comments, data provided in
manufacturer interviews, and using the
FREEZE program, The reverse
engineering, equipment testing, vendor
interviews, and manufacturer interviews
provided input for the energy analysis.
Information about specific ice makers
also provided equipment examples
against which the modeling results
could be calibrated. The final
incremental cost estimates and the
energy modeling results together
constitute the energy efficiency curves
presented in the final rule TSD
chapter 5.
The cost-efficiency relationships were
derived from current market designs so
that efficiency calculations could be
verified by ratings or testing. Another
benefit of using market designs is that
the efficiency performance can be
associated with the use of particular
design options or design option
groupings. The cost of these design
option changes can then be isolated and
also verified. In earlier stages of the rule
DOE had limited information on current
market designs and relied on the
FREEZE model to supplement and
extend its design-option energy
modeling analysis. For the NODA and
Final Rule, DOE has expanded its
knowledge base of market designs
through its own program of testing and
reverse engineering, but also received
test and design information from ice
maker manufacturers. The costefficiency curves are now based on
these market designs, test data obtained
both through DOE testing and from
manufacturers, specific information
about component performance (e.g.
motor efficiency) on which stakeholders
have been able to comment, and in some
instances use of the FREEZE model.
DOE limited the projected efficiency
levels for groups of design options
found in available equipment to the
maximum available efficiency levels
associated with the specific classes. The
groups of design options that DOE’s
analysis predicted would be required to
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attain these maximum efficiency levels
were consistent with those of the
maximum available ice makers or were
found to provide a conservative estimate
of cost compared to the market designs
of equal efficiency employing different
design option groups to attain the level.
Additional details of the engineering
analysis are available in chapter 5 of the
final rule TSD.
1. Representative Equipment for
Analysis
In performing its engineering analysis,
DOE selected representative units
within specific equipment types to serve
as analysis points in the development of
cost-efficiency curves. DOE selected
models that were representative of the
typical offerings within a given
equipment class. DOE sought to select
models having features and technologies
typically found in both the minimum
and maximum efficiency equipment
currently available on the market.
DOE received several comments from
interested parties regarding those
equipment classes not directly analyzed
in the NOPR. Follett commented that
they object to the fact that only one
RCU–Large–C was purchased for testing,
given that it represents nearly half of
Follett’s sales. Follett added that they
also object to the fact that DOE did not
analyze IMH–W–Small–C, IMH–W–
Large–C, RCU–Small–C, and RCU–
Large–C, which comprise a significant
portion of Follett’s revenue. Follett
expressed its fear that DOE’s approach
could require Follett to enact design
changes that are neither technologically
feasible nor economically justified.
(Follett, No. 84 at p. 7–8) Follett added
that all manufacturers have unique
designs that should be noted during
reverse engineering analyses. (Follett,
No. 84 at p. 8) Similarly, Hoshizaki
commented that DOE only analyzed less
than 1% of available units and that
analysis did not include testing to
validate proposed design changes.
(Hoshizaki, No. 86 at
p. 1)
Ice-O-Matic noted that half cube
machines represent a significant portion
of the industry and expressed concern
that DOE did not attempt to analyze half
cube machines. (Ice-O-Matic, No. 121 at
p. 3)
In response to Ice-o-Matic, DOE notes
that it focused its analysis on full cube
machines based on the observation that
half cube machines may have an
efficiency advantage over full cube
machines. For some models that are
available in both versions, the energy
use ratings are different, and generally
the half-dice version has lower energy.
This is consistent with the fact that the
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additional copper strips that divide the
full-cube cells into two half-cube cells
also provide additional heat transfer
surface area that can enhance ice maker
performance.
In response to Follett and Hoshizaki’s
comments, DOE is limited in time and
resources, and as such, cannot directly
analyze all models. DOE responded to
NOPR comments regarding lack of
analysis of continuous RCU units by
adding direct analysis of a continuous
RCU configuration with capacity of 800
lb ice/24 hours. This capacity is near the
border between the small and large RCU
continuous classes, hence it provides
representation for both capacity ranges.
DOE reviewed Follett’s available
continuous RCU ice maker data, as
listed in the ENERGY STAR© database,
and found that nearly all of the models
meet the standard set in this rule. Of the
two that don’t, one has adjusted energy
use within 1 percent of the standard,
and one has energy use within 6
percent.
DOE disagrees with Hoshizaki’s
statement that DOE analyzed less than
one percent of available units and
believes it mischaracterizes DOE’s
analysis. DOE identified 656 current ice
maker models in its research of
available databases and Web sites. DOE
did not analyze Hoshizaki batch ice
makers, due to their proprietary
evaporator design—hence the 91
Hoshizaki batch models would not have
been considered in DOE’s analysis for
this reason. DOE developed 19 analyses,
3.4 percent of the remaining 565
models. Moreover, DOE asserts that the
range of models analyzed provides a
good representation of ice maker
efficiency trends. DOE carefully selected
the analyzed units to represent 13 of the
25 ice maker equipment classes listed in
Table IV.2 representing roughly 93
percent of ice maker shipments.
DOE does not generally conduct
prototype testing to verify the energy
savings projections associated with
specific design changes. For this, DOE
has requested data from stakeholders
who have done such work. DOE
received such test data, some of it
through confidential information
exchange with its contractor, and
considered this data in the analysis.
Further, DOE also considered test data
and design details of commercially
available ice makers, which it used to
calibrate its projections of energy
reductions associated with groups of
design options.
In many cases, DOE leveraged
information found by directly analyzing
similar product classes to supplement
the analysis of those secondary
equipment classes which were not
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directly analyzed. These similar
equipment classes are listed in Table
IV.6. The details of why these
equipment classes were chosen can be
found in chapter 5 of the final rule TSD.
TABLE IV.6—DIRECTLY ANALYZED
EQUIPMENT CLASSES USED TO DEVELOP STANDARDS FOR SECONDARY
CLASSES
Secondary equipment
class
Analyzed equipment
class associated with
efficiency level for
secondary equipment
class
RCU–NRC–Small–B
RCU–RC–Small–B ...
RCU–RC–Large–B ...
SCU–W–Small–B .....
IMH–W–Small–C ......
IMH–W–Large–C ......
RCU–NRC–Large–C
RCU–RC–Small–C ...
RCU–RC–Large–C ...
SCU–W–Small–C .....
SCU–W–Large–C .....
SCU–A–Large–C ......
RCU–NRC–Large–B.
RCU–NRC–Large–B.
RCU–NRC–Large–B.
SCU–W–Large–B.
IMH–A–Small–C.
IMH–A–Large–C.
RCU–NRC–Small–C.
RCU–NRC–Small–C.
RCU–NRC–Small–C.
SCU–A–Small–C.
SCU–A–Small–C.
SCU–A–Small–C.
2. Efficiency Levels
a. Baseline Efficiency Levels
EPCA, as amended by the EPACT
2005, prescribed the following
standards for batch type ice makers,
shown in Table IV.7, effective January 1,
2010. (42 U.S.C. 6313(d)(1)) For the
engineering analysis, DOE used the
existing batch type equipment standards
as the baseline efficiency level for the
equipment types under consideration in
this rulemaking. Also, DOE applied the
standards for equipment with harvest
capacities up to 2,500 lb ice/24 hours as
baseline efficiency levels for the larger
batch type equipment with harvest
capacities between 2,500 and 4,000 lb
ice/24 hours, which are currently not
regulated. DOE applied two exceptions
to this approach, as discussed below.
For the IMH–W–Small–B equipment
class, DOE slightly adjusted the baseline
energy use level to close a gap between
the IMH–W–Small–B and the IMH–W–
Medium–B equipment classes. For
equipment in the IMH–A–Large–B
equipment class with harvest capacity
above 2,500 lb ice per 24 hours, DOE
chose a baseline efficiency level equal to
the current standard level at the 2,500
lb ice per 24 hours capacity. In its
analysis, DOE is treating the constant
portion of the IMH–A–Large–B
equipment class as a separate
equipment class, IMH–A–Extended–B.
As noted in section IV.B.1.d DOE is
not proposing adjustment of maximum
condenser water use standards for batch
type ice makers. The section also
generally discusses DOE regulation of
condenser water. First, DOE’s authority
does not extend to regulation of water
use, except as explicitly provided by
EPCA. Second, DOE determined that
increasing condenser water use
standards to allow for more water flow
in order to reduce energy use is not costeffective. The details of this analysis are
available in chapter 5 of the final rule
TSD.
For water-cooled batch equipment
with harvest capacity less than 2,500 lb
ice per 24 hours, the baseline condenser
water use is equal to the current
condenser water use standards for this
equipment.
For water-cooled equipment with
harvest capacity greater than 2,500 lb
ice per 24 hours, DOE set maximum
condenser water standards equal to the
current standard level for the same type
of equipment with a harvest capacity of
2,500 lb ice per 24 hours—the proposed
standard level would not continue to
drop as harvest capacity increases, as it
does for equipment with harvest
capacity less than 2,500 lb ice per 24
hours.
TABLE IV.7—BASELINE EFFICIENCY LEVELS FOR BATCH ICE MAKERS
Equipment type
Type of cooling
Ice—Making Head ....................................................
Water ................
Air .....................
Remote Condensing (but not remote compressor) ..
Air .....................
Remote Condensing and Remote Compressor .......
Air .....................
Self—Contained ........................................................
Water ................
Air .....................
Harvest rate
lb ice/24 hours
Maximum energy use
kWh/100 lb ice
<500
≥500 and <1,436
≥1,436
<450
≥450 and <2,500
≥2,500
<1,000
≥1,000
<934
≥934
<200
≥200
7.80—0.0055H **
5.58—0.0011H
4.0
10.26—0.0086H
6.89—0.0011H
4.1
8.85—0.0038H
5.10
8.85—0.0038H
5.30
11.4—0.019H
7.60
<175
≥175
18.0—0.0469H
9.80
Maximum
condenser
water use *
gal/100 lb ice
200—0.022H.
200—0.022H.
145.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
191—0.0
For <2,500: 191—
0.0315H.
For ≥2,500: 112.
Not Applicable.
Not Applicable.
mstockstill on DSK4VPTVN1PROD with RULES2
* Water use is for the condenser only and does not include potable water used to make ice.
** H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.
Source: 42 U.S.C. 6313(d).
Currently there are no DOE energy
standards for continuous type ice
makers. During the preliminary
analysis, DOE developed baseline
efficiency levels using energy use data
available from several sources, as
discussed in chapter 3 of the
preliminary TSD. DOE chose baseline
efficiency levels that would be met by
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nearly all ice makers represented in the
databases, using ice hardness
assumptions of 70 for flake ice makers
and 85 for nugget ice makers, since ice
hardness data was not available at the
time. For the NOPR analysis, DOE used
available information published in the
AHRI Directory of Certified Product
Performance, the California Energy
PO 00000
Frm 00032
Fmt 4701
Sfmt 4700
Commission, the ENERGY STAR
program, and vendor Web sites, to
update its icemaker ratings database
(‘‘DOE icemaker ratings database’’). The
AHRI published equipment ratings
including ice hardness data, measured
as prescribed by ASHRAE 29–2009,
which is incorporated by reference in
the DOE test procedure. DOE recreated
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its baseline efficiency levels for
continuous type ice makers based on the
available AHRI data, considering
primarily the ice makers for which ice
hardness data were available. DOE also
adjusted the harvest capacity break
points for the continuous equipment
classes based on the new data.
The baseline efficiency levels used in
the NOPR analysis for continuous type
ice makers are presented in Table IV.8.
For the remote condensing equipment,
4677
the large-capacity remote compressor
and large-capacity non-remote
compressor classes have been separated
and are different by 0.2 kWh/100 lb,
identical to the batch equipment
differential for the large batch classes.
TABLE IV.8—NOPR BASELINE EFFICIENCY LEVELS FOR CONTINUOUS ICE MAKER EQUIPMENT CLASSES
Equipment type
Type of cooling
Ice-Making Head .......................................................
Water ................
Air .....................
Remote Condensing (Remote Compressor) ............
Air .....................
Remote Condensing (Non-remote Compressor) ......
Air .....................
Self-Contained ..........................................................
Water ................
Air .....................
Maximum energy use
kWh/100 lb ice *
Maximum condenser
water use *
gal/100 lb ice
Small (<900)
Large (≥900)
8.1–0.00333H
5.1
Small (<700)
Large (≥700)
Small (<850)
Large (≥850)
Small (<850)
Large (≥850)
Small (<900)
Large (≥900)
11.0–0.00629H
6.6
10.2–0.00459H
6.3
10.0–0.00459H
6.1
9.1–0.00333H
6.1
160–0.0176H.
≤2,500: 160–0.0176H.
>2,500: 116.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
153–0.0252H.
≤2,500:
153–0.0252H.
>2,500: 90.
Small (<700)
Large (≥700)
11.5–0.00629H
7.1
Harvest rate
lb ice/24 hours
mstockstill on DSK4VPTVN1PROD with RULES2
* H = harvest capacity in lb ice/24 hours
After the publication of the NOPR and
the NOPR public meeting, DOE received
two comments from interested parties
regarding its establishment of baseline
models.
In response to the NOPR, Scotsman
commented that there is not sufficient
historical data (greater than 1 year) to
establish continuous type baselines with
statistical confidence. Scotsman added
that the current ASHRAE standard is
biased against low-capacity machines,
and therefore does not accurately
represent the energy usage of the
machine when corrected for hardness
factor. (Scotsman, No. 85 at p. 3b)
DOE has found multiple sources of
information regarding the energy
efficiency of continuous ice machines
on the market. As noted previously,
DOE investigated information published
in the AHRI Directory of Certified
Product Performance, the California
Energy Commission, the ENERGY STAR
program, and vendor Web sites to
inform the establishment of a baseline
for continuous models. In regards to
Scottsman’s comment that the standard
is biased against low capacity machines,
DOE has set its baseline levels while
considering continuous model energy
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use that has been adjusted using the
current ASHRAE test standard. If the
test is biased against low-capacity
machines, this bias should be reflected
in the data and already be accounted for
in the selected baseline levels.
Hoshizaki stated that they believe the
baseline levels presented in the NOPR
are too harsh for continuous equipment
as it leaves many ENERGY STAR units
unable to meet the minimum energy
efficiency baseline. Hoshizaki noted that
DOE based its analysis on the 2012
AHRI listing. Hoshizaki requested that
DOE reassess the baseline data for all
current continuous models as many
more units have since been listed on
AHRI’s Web site. (Hoshizaki, No. 86 at
p. 2–3) Similarly, Follett commented
that some of the data on continuous
type ice makers were not available in
2012, since they were not a part of the
ENERGY STAR program until 2013, and
that the baseline line might move up if
recent data was added to the plot.
(Follet, Public Meeting Transcript, No.
70 at p. 76–78) PGE/SDG&E commented
that they support DOE’s updating their
database with new data from all sources,
including the CEC, AHRI, and NRCan
databases. (PG&E and SDG&E, No. 89 at
p. 3)
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Fmt 4701
Sfmt 4700
In response to Hoshizaki’s comment
about ENERGY STAR-rated continuous
models, for which there are currently no
federal standard levels that would
clearly represent the baseline efficiency
levels, DOE revised its continuous class
baselines so that no ENERGY STARrated continuous models have energy
use higher than the baseline. The
revised baseline efficiency levels for the
continuous SCU classes are shown in
Table IV.9 below. However, DOE notes
that baseline efficiency levels are not
required to be set at a level with which
all commercially available equipment
would be compliant. There are some
IMH–W models and some IMH–A
models that have energy use higher than
the selected baseline levels—this is
illustrated in the comparison of
equipment data and efficiency levels in
Chapter 3 of the TSD. DOE selected
baseline efficiency levels that provide a
good representation of the highest
energy use exhibited by models
available on the market with the
exclusion of a few outliers (i.e. models
exhibiting very different energy use than
the majority of models).
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE IV.9—MODIFIED BASELINE EFFICIENCY LEVELS FOR SCU CONTINUOUS ICE MAKER EQUIPMENT CLASSES
Maximum
energy use
kWh/100 lb ice *
Harvest rate
lb ice/24 hours
Maximum
condenser
water use *
gal/100 lb ice
Equipment type
Type of cooling
Self-Contained ..........................................................
Water ................
Small (<900)
Large (≥900)
9.5—0.00378H
6.1
Air .....................
Small (<200)
Large (≥200 and
< 700)
Extended (≥ 700)
16.3—0.03H
11.84—0.0078H
153—0.0252H.
≤2,500:
153—0.0252H
>2,500: 90.
Not Applicable.
Not Applicable.
6.38
Not Applicable.
* H = harvest capacity in lb ice/24 hours.
In response to the comments related
to data sources DOE notes that it has
continued to update the analysis with
new data as it becomes available. This
includes new information published in
the AHRI Directory of Certified Product
Performance, the California Energy
Commission and the ENERGY STAR
program.
In response to the NODA analysis,
Hoshizaki again stated that DOE has not
conducted enough analysis to accurately
portray the baseline efficiency levels of
continuous models (Hoshizaki, No. 124
at p. 1) NAFEM also stated that the
NODA continuous unit baselines do not
reflect the current models in the
marketplace. (NAFEM, No. 123 at p. 2)
DOE has evaluated all available data
sources in its determination of the
baseline efficiency levels for continuous
units. However, as stated above, DOE
notes that the baseline level selected is
not necessarily the least efficient
equipment on the market. As part of this
review of data sources, DOE has
modified the baseline condenser water
use levels for IMH–W continuous
classes such that they are 10 percent
below the IMH–W batch baseline water
use levels.
b. Incremental Efficiency Levels
For each of the 11 analyzed batch type
ice-maker equipment classes and the
four analyzed continuous ice maker
equipment classes, DOE established a
series of incremental efficiency levels
for which it has calculated incremental
costs. DOE chose these classes to be
representative of all ice-making
equipment classes, and grouped nonanalyzed equipment classes with similar
analyzed equipment classes accordingly
in the downstream analysis. Table IV.10
shows the selected incremental
efficiency levels considered in the final
rule analysis for batch ice makers, and
Table IV.11 shows the incremental
efficiency levels considered for
continuous ice makers.
TABLE IV.10—INCREMENTAL EFFICIENCY LEVELS FOR BATCH ICE MAKER EQUIPMENT CLASSES CONSIDERED IN THE FINAL
RULE ANALYSIS
Harvest capacity rate
lb ice/24 hours
Equipment type *
Representative
capacity
Range
EL 2 **
(%)
EL 3
EL 3A ***
(%)
EL 4
EL 4A ***
(%)
EL 5
(%)
EL 6
(%)
EL 7
(%)
20
22
18
..................
..................
20
24
..................
..................
..................
..................
25
..................
..................
..................
..................
..................
26
..................
..................
..................
..................
..................
..................
20
23
..................
..................
..................
..................
..................
..................
..................
..................
..................
..................
30
30
..................
33
<500
300
10
15
IMH–W–Med–B ............
IMH–W–Large–B ..........
IMH–W–Large–B ..........
IMH–A–Small–B ...........
≥500 and <1,436
≥1,436
≥1,436
<450
850
1,500
2,600
300
10
8
7
10
IMH–A–Large–B ...........
≥450
800
10
IMH–A–Large–B ...........
≥450
1,500
10
15
..................
..................
15
18
15
16
12
RCU–NRC–Small–B ....
................................
RCU–NRC–Large–B ....
RCU–NRC–Large–B ....
≥1,000
≥1,000
RCU–RC–Small–B .......
mstockstill on DSK4VPTVN1PROD with RULES2
IMH–W–Small–B ..........
<934
Not Directly Analyzed
RCU–RC–Large–B .......
≥934
Not Directly Analyzed
SCU–W–Small–B .........
>200
Not Directly Analyzed
SCU–W–Small–B .........
SCU–A–Small–B ..........
≥200
<175
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Not Directly Analyzed
1,500
2,400
10
10
300
110
Frm 00034
10
10
Fmt 4701
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15
14
15
15
17
..................
..................
..................
20
20
E:\FR\FM\28JAR2.SGM
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25
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE IV.10—INCREMENTAL EFFICIENCY LEVELS FOR BATCH ICE MAKER EQUIPMENT CLASSES CONSIDERED IN THE FINAL
RULE ANALYSIS—Continued
Harvest capacity rate
lb ice/24 hours
EL 2 **
(%)
Equipment type *
Representative
capacity
Range
≥175
SCU–A–Large–B ..........
200
EL 3
EL 3A ***
(%)
10
EL 4
EL 4A ***
(%)
15
EL 5
(%)
20
EL 6
(%)
25
EL 7
(%)
29
..................
* See Table III.1 for a description of these abbreviations.
** EL = efficiency level; EL 1 is the baseline efficiency level, while EL 2 through EL 7 represent increased efficiency levels.
*** DOE considered intermediate efficiency levels 3A and 4A for some equipment classes.
TABLE IV.11—INCREMENTAL EFFICIENCY LEVELS FOR CONTINUOUS TYPE ICE MAKER EQUIPMENT CLASSES CONSIDERED
IN THE FINAL RULE ANALYSIS
Harvest capacity
lb ice/24 hours
Equipment Type *
Representative
capacity
Range
EL 2 **
(%)
EL 3
(%)
EL 4
(%)
EL 5
(%)
IMH–W–Small–C ................................
<900
Not Directly Analyzed
IMH–W–Large–C ...............................
≥900
Not Directly Analyzed
IMH–A–Small–C .................................
IMH–A–Large–C ................................
RCU–Small–C ....................................
<700
≥700
<850
RCU–Large–C ....................................
≥850
Not Directly Analyzed
SCU–W–Small–C ...............................
<900
Not Directly Analyzed
SCU–W–Large–C ..............................
≥900
No existing products on the market
SCU–A–Small–C ................................
<700
SCU–A–Large–C ...............................
≥700
EL 6
(%)
310
820
800
220
10
10
10
15
15
15
10
20
20
20
15
25
23
25
25
20
26
..................
27
27
No existing products on the market
* See Table III.1 for a description of these abbreviations.
** EL 1 is the baseline efficiency level, while EL 2 through EL 6 represent increased efficiency levels.
In response to the NODA, Hoshizaki
stated that ‘‘there are no models that
achieve the NODA levels in SCU–A,
IMH–W large, or RCU–A large’’
equipment classes. Hoshizaki added
that these same levels were not analyzed
for cost curves. (Hoshizaki, No. 124 at
p. 1)
As discussed above in section IV.D.1,
DOE’s analysis for the RCU class was at
a representative capacity of 800 lb ice/
24 hours, intended to provide
representation for both small and large
classes, by being at a capacity level in
the large range but within 100 lb ice/24
hours of the small range. Continuous ice
maker data that DOE collected from
publicly available sources does show
that nearly all ice makers meet the
baseline efficiency levels considered in
the analysis. Not all meet the efficiency
levels eventually designated as TSL 3
for the final rule, but some ice makers
over a broad capacity range in each of
the cited classes (SCU–A–C, IMH–W–C,
RCU–RC–C, and RCU–NRC–C) do meet
this level, shown in Table IV.12 through
Table IV.15. A comparison of the levels
achieved by commercially available ice
makers with the considered TSL levels
is shown graphically in Chapter 3 of the
TSD.
TABLE IV.12—AIR-COOLED, SELF-CONTAINED, CONTINUOUS UNITS MEETING THE FINAL RULE STANDARD
Harvest capacity
(lb ice/24 hours)
mstockstill on DSK4VPTVN1PROD with RULES2
Manufacturer
Model
Hoshizaki ..........................
Hoshizaki ..........................
Manitowoc .........................
Scotsman ..........................
Hoshizaki ..........................
F–330BAH–C ...................
F–330BAH ........................
RNS0385A–161 ................
MDT5N25WS–1# .............
DCM–751BWH .................
VerDate Sep<11>2014
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222
238
248
455
631
Fmt 4701
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Adjusted energy
use
(kWh/100 lb ice)
Standard
(kWh/100 lb ice)
7.99
7.56
7.75
4.99
5.21
E:\FR\FM\28JAR2.SGM
8.08
7.98
7.92
6.63
5.53
28JAR2
Hardness factor
84.5
69.8
86
75
88.9
4680
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE IV.13—WATER-COOLED, ICE MAKING HEAD, CONTINUOUS UNITS MEETING THE FINAL RULE STANDARD
Harvest capacity
(lb ice/24 hours)
Manufacturer
Model
Ice-O-Matic .......................
Follet .................................
Ice-O-Matic .......................
Ice-O-Matic .......................
Hoshizaki ..........................
Ice-O-Matic .......................
Ice-O-Matic .......................
Ice-O-Matic .......................
Ice-O-Matic .......................
Ice-O-Matic .......................
Ice-O-Matic .......................
Follet .................................
Ice-O-Matic .......................
Ice-O-Matic .......................
Follet .................................
GEM0450W ......................
HC *700W ** ......................
GEM0655W ......................
MFI0805W ........................
F–801MWH ......................
GEM0650W ......................
MFI0800W ........................
GEM0956W ......................
GEM0955W ......................
MFI1256W ........................
MFI1255W ........................
HCE1400W** ....................
RN–1409W .......................
RN1409W–261 .................
HCC1400W *** ..................
Adjusted energy
use
(kWh/100 lb ice)
429
535
578
604
635
633
740
877
927
959
1000
1150
1318
1318
1374
Standard
(kWh/100 lb ice)
4.66
4.43
4.2
4.26
4.48
3.86
3.93
3.54
3.71
3.54
3.41
4.31
4.27
4.15
4.28
Hardness factor
5.33
5.05
4.94
4.87
4.78
4.79
4.50
4.34
4.34
4.34
4.34
4.34
4.34
4.34
4.34
(*)
(*)
(*)
(*)
75.1
(*)
(*)
(*)
(*)
(*)
(*)
(*)
(*)
88
(*)
* Ice hardness factor assumed to be 70 for flake ice makers and 85 for nugget ice makers.
TABLE IV.14—REMOTE CONDENSING, NOT REMOTE COMPRESSOR, CONTINUOUS UNITS MEETING THE FINAL RULE
STANDARD
Harvest capacity
(lb ice/24 hours)
Manufacturer
Model
Ice-O-Matic .......................
Ice-O-Matic .......................
Ice-O-Matic .......................
Scotsman ..........................
Scotsman ..........................
GEM0650R .......................
GEM0956R .......................
MFI1256R .........................
N1322R–32# ....................
F1222R–32# .....................
Adjusted energy
use
(kWh/100 lb ice)
550
825
950
1030
1050
Proposed standard
(kWh/100 lb ice)
6.41
4.77
4.79
5.04
4.97
6.51
4.915
5.06
5.06
5.06
Hardness factor
(*)
(*)
(*)
74
60
* Ice hardness factor assumed to be 70 for flake ice makers and 85 for nugget ice makers.
TABLE IV.15—REMOTE CONDENSING, REMOTE COMPRESSOR, CONTINUOUS UNITS MEETING THE FINAL RULE STANDARD
Harvest capacity
(lb ice/24 hours)
Manufacturer
Model
Follet .................................
Manitowoc .........................
Follet .................................
Follet .................................
Follet .................................
Follet .................................
Manitowoc .........................
Ice-O-Matic .......................
Scotsman ..........................
HCD700RBT .....................
RFS1278C–261 ................
HCD1400R *** ..................
HCF1400RBT ...................
HCD1650R *** ..................
HCF1650RBT ...................
RFS2378C–261 ................
MFI2406LS .......................
FME2404RLS ...................
Adjusted energy
use
(kWh/100 lb ice)
566
958
1184
1195
1284
1441
1702
2000
2000
Standard
(kWh/100 lb ice)
5.44
5.11
4.87
4.59
5.24
4.14
5.18
4.27
3.54
6.62
5.26
5.26
5.26
5.26
5.26
5.26
5.26
5.26
Hardness factor
88
72
(*)
89.4
(*)
89.9
68
(*)
(*)
* Ice hardness factor assumed to be 70 for flake ice makers and 85 for nugget ice makers.
mstockstill on DSK4VPTVN1PROD with RULES2
c. IMH–A–Large–B Treatment
The existing DOE energy conservation
standard for large air-cooled IMH cube
type ice makers is represented by an
equation for which maximum allowable
energy usage decreases linearly as
harvest rate increases from 450 to 2,500
lb ice/24 hours. In the NOPR, DOE
proposed efficiency levels for this class
that maintain a constant energy use in
kwh per 100 pounds of ice at large
capacities to the extent that this
approach does not violate EPCA’s antibacksliding provision. 79 FR at 14877
(March 17, 2014).
VerDate Sep<11>2014
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Jkt 235001
DOE did not receive any comments on
the approach described in the NOPR.
Therefore, DOE maintained this
approach for the final rule.
d. Maximum Available Efficiency
Equipment
DOE considered the most-efficient
equipment available on the market,
known as maximum available
equipment. For many batch equipment
classes, the maximum available
equipment uses proprietary or screenedout technology options that DOE did not
consider in its engineering analysis,
such as low thermal-mass evaporators
and tube evaporators for batch type ice
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Fmt 4701
Sfmt 4700
makers. Hence, DOE considered only
batch maximum available equipment
that does not include these
technologies. These maximum available
efficiency levels are shown in Table
IV.16. This information is based on
DOE’s icemaker ratings database (see
data in chapter 3 of the final rule TSD).
The efficiency levels are represented as
an energy use percentage reduction
compared to the energy use of baselineefficiency equipment. For some batch
equipment classes, DOE has presented
maximum available efficiency levels at
different capacity levels or for 22-inch
wide ice makers.
E:\FR\FM\28JAR2.SGM
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE IV.16—EFFICIENCY LEVELS FOR
MAXIMUM AVAILABLE EQUIPMENT
WITHOUT SCREENED TECHNOLOGIES
IN BATCH ICE MAKER EQUIPMENT
CLASSES
Equipment class
Energy use lower than
baseline
IMH–W–Small–B
19.2%, 16.9% (22-inch
wide).
14.3%.
5% (at 1,500 lb ice/24
hours), 2.5% (at 2,600
lb ice/24 hours).
19.3%, 16.6% (22-inch
wide).
16.1% (at 800 lb ice/24
hours) 5.5% (at 590 lb
ice/24 hours, 22-inch
wide) 6.0% (at 1,500 lb
ice/24 hours).
25.8%.
15.7% (at 1,500 lb ice/24
hours), 14.9% (at 2,400
lb ice/24 hours).
26.2%.
27.6%.
24.9%.
26.4%.
IMH–W–Med–B ...
IMH–W–Large–B
IMH–A-Small–B ...
IMH–A–Large–B ..
RCU–Small–B .....
RCU–Large–B .....
SCU–W–Small–B
SCU–W–Large–B
SCU–A–Small–B
SCU–A–Large–B
Efficiency levels for maximum
available equipment in the continuous
type ice-making equipment classes are
shown in Table IV.17. This information
is based on a survey of product
4681
databases and manufacturer Web sites
(see data in chapter 3 of the final rule
TSD). The efficiency levels are
represented as an energy use percentage
reduction compared to the energy use of
baseline-efficiency equipment.
In response to the maximum available
efficiency levels presented in the NODA
AHRI suggested that DOE review the
max available unit for the 22-inch IMH–
A–Small–B equipment class which is
cited at 17% as they believe the unit
may contain proprietary design options.
TABLE IV.17—EFFICIENCY LEVELS FOR (AHRI, No. 128 at p. 3)
MAXIMUM AVAILABLE EQUIPMENT
DOE maintains that the representative
FOR CONTINUOUS TYPE ICE MAKER 22-inch unit for the IMH–A–Small–B
EQUIPMENT CLASSES
equipment class did not contain any
proprietary designs—specifically, the
Energy use lower than
Equipment class
model analyzed does not include any
baseline
proprietary or screened options such as
low-thermal-mass evaporators or tubeIMH–W–Small–C
16.5%.
IMH–W–Large–C
12.2% (at 1,000 lb ice/24 ice evaporators. Table IV.18 lists 22hours), 8.6% (at 1,800
inch ice makers of this class that are in
lb ice/24 hours).
DOE’s ice maker database. DOE
IMH–A–Small–C .. 28.0%.
calculated an efficiency level equal to
IMH–A–Large–C
35.7% (at 820 lb ice/24
12.3% for such a unit with design
hours), lb ice.
options included in maximum available
RCU–Small–C ..... 18.4%.
equipment. There are three available
RCU–Large–C ..... 18.5%.
units with higher efficiency level.
SCU–W–Small–C 18.7% *.
SCU–W–Large–C No equipment on the
Therefore, DOE has maintained the
market *.
maximum available level for this
SCU–A–Small–C
29.3%.
equipment class in the final rule
SCU–A–Large–C
No equipment on the
engineering analysis.
market *.
* DOE’s inspection of currently available
equipment revealed that there are no available
products in the defined SCU–W–Large–C and
SCU–A–Large–C equipment classes at this
time.
TABLE IV.18—22-INCH IMH–A–SMALL–B MODELS
Harvest capacity rate
(lb ice/24 hours)
249
290
225
335
360
310
305
230
278
214
370
255
324
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
.....................................................................................................
e. Maximum Technologically Feasible
Efficiency Levels
mstockstill on DSK4VPTVN1PROD with RULES2
Rated energy use
(kWh/100 lb ice)
When DOE adopts an amended or
new energy conservation standard for a
type or class of covered equipment such
as automatic commercial ice makers, it
determines the maximum improvement
in energy efficiency that is
technologically feasible for such
equipment. (See 42 U.S.C. 6295(p)(1)
and 6313(d)(4)) DOE determined
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0.2
6.9
10.0
10.0
10.0
10.5
11.0
11.6
12.3
14.5
16.6
18.2
22.4
No.
No.
No.
No.
No.
No.
No.
No.
Yes.
No.
No.
No.
Yes.
8.10
7.23
7.49
6.64
6.45
6.80
6.80
7.32
6.90
7.20
5.90
6.60
5.80
maximum technologically feasible
(‘‘max-tech’’) efficiency levels for
automatic commercial ice makers in the
engineering analysis by considering
efficiency improvement beyond the
maximum available levels associated
with two design options that are
generally not used in commercially
available equipment, brushless DC
motors and drain water heat exchangers.
DOE has not screened out these design
options—cost-effectiveness is not one of
PO 00000
Percent efficiency level
Contains
proprietary or
screened technology
(e.g., low-thermal-mass
or tube
evaporators)?
Sfmt 4700
the screening criteria (see section IV.C).
Table IV.19 and Table IV.20 show the
max-tech levels determined in the
NOPR engineering analysis for batch
and continuous type automatic
commercial ice makers, respectively.
These max-tech levels do not consider
use of screened technology, specifically
low-thermal-mass evaporators and tube
ice evaporators.
E:\FR\FM\28JAR2.SGM
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4682
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE IV.19—FINAL RULE MAX-TECH
LEVELS FOR BATCH AUTOMATIC
COMMERCIAL ICE MAKERS
Equipment type *
IMH–W–Small–B
IMH–W–Med–B ...
IMH–W–Large–B
IMH–A–Small–B ..
IMH–A–Large–B ..
RCU–Small–B .....
RCU–Large–B .....
Percent energy use lower
than baseline
23.9%, 21.5% (22 inch
wide).
18.1%.
8.3% (at 1,500 lb ice/24
hours), 7.4% (at 2,600
lb ice/24 hours).
25.5%, 18.1% (22 inch
wide).
23.4% (at 800 lb ice/24
hours), 15.8% (at 590
lb ice/24 hours, 22 inch
wide), 11.8% (at 1,500
lb ice/24 hours).
Not directly analyzed.
17.3% (at 1,500 lb ice/24
hours), 13.9% (at 2,400
lb ice/24 hours).
Not directly analyzed.
29.8%.
32.7%.
29.1%.
TABLE IV.20—FINAL RULE MAX-TECH
LEVELS FOR CONTINUOUS AUTOMATIC COMMERCIAL ICE MAKERS—
Continued
Equipment type
SCU–W–Small–C
SCU–W–Large–
C *.
SCU–A–Small–C
SCU–A–Large–C *
Percent energy use lower
than baseline
Not directly analyzed.
No units available.
26.6% †.
No units available.
* DOE’s investigation of equipment on the
market revealed that there are no existing
products in either of these two equipment
classes (as defined in this NOPR).
** For equipment classes that were not analyzed, DOE did not develop specific cost-efficiency curves but attributed the curve (and
maximum technology point) from one of the
analyzed equipment classes
† Percent energy use lower than baseline.
Several stakeholders provided
comment regarding the maximum
technological efficiency levels presented
in the NOPR.
PG&E recommended that DOE
* IMH is ice-making head; RCU is remote
condensing unit; SCU is self-contained unit; W continue to update its product database
is water-cooled; A is air-cooled; Small refers to to ensure that max-tech levels are set
the lowest harvest category; Med refers to the appropriately. (PG&E and SDG&E, No.
Medium category (water-cooled IMH only); 89 at p. 3–4) Manitowoc stated that
Large refers to the large size category; RCU
units were modeled as one with line losses examples of currently available models
that are near the max-tech levels are not
used to distinguish standards.
Note: For equipment classes that were not generally representative of the full range
analyzed, DOE did not develop specific cost- of models in each equipment class,
efficiency curves but attributed the curve (and
maximum technology point) from one of the explaining that small-capacity ice
makers can attain higher efficiency
analyzed equipment classes.
levels than large-capacity ice makers
TABLE IV.20—FINAL RULE MAX-TECH built using the same package size.
LEVELS FOR CONTINUOUS AUTO- (Manitowoc, No. 92 at p. 3) AHRI
commented that the maximum
MATIC COMMERCIAL ICE MAKERS
technologically feasible efficiency levels
Percent energy use lower presented in the NOPR analysis were
Equipment type
than baseline
overestimated by up to 13% for at least
10 equipment classes. AHRI added that
IMH–W–Small–C
Not directly analyzed.
the FREEZE energy model has been
IMH–W–Large–C
Not directly analyzed.
proven invalid through testing, citing
IMH–A–Small–C .. 25.7% †.
two examples of testing to evaluate the
IMH–A–Large–C
23.3% (at 820 lb ice/24
efficiency improvement associated with
hours).
switching to a higher-EER compressor in
RCU–Small–C ..... 26.6% †.
RCU–Large–C ..... Not directly analyzed.
which the observed efficiency
SCU–W–Small–B
SCU–W–Large–B
SCU–A–Small–B
SCU–A–Large–B
improvement was significantly less than
the NOPR projections of efficiency
improvement associated with
compressor switching. (AHRI, No. 93 at
p. 5–6)
In response to the comment provided
by PGE DOE notes that it has continued
to update the product database with
new data as it becomes available.
In response to Manitowoc, DOE notes
that its analysis has considered multiple
capacity levels for key classes. Also,
although DOE agrees that higher
efficiency levels may be more difficult
to attain by higher-capacity ice makers,
DOE has investigated the trend of
efficiency level as a function of harvest
capacity and package size and
concluded that there are no consistent
trends in the available data that would
indicate which capacities should be
analyzed for each specific package size.
79 FR at 14871–3 (March 17, 2014). DOE
notes that while Manitowoc’s comment
indicates that higher efficiency levels
may be easier to attain for a smallercapacity unit in a given package size,
the comment does not indicate which
classes and capacities in DOE’s analysis
represent capacities for which attaining
higher efficiency would be so much
easier that equipment with these
characteristics would not be
representative of their classes. An
example review of the relationship of
harvest capacity rate, efficiency level,
and package size in volume (cubic feet)
is shown in Table IV.21 for IMH aircooled batch ice makers. The data
shown does not include ice makers with
proprietary evaporator technology, nor
does it include ice makers that produce
large-size (gourmet) ice cubes. The data
show that higher efficiency levels do not
necessarily correlate either with larger
package sizes or the smallest harvest
capacity rates—the maximum 20.7%
efficiency level is associated with a
relatively small 8.3 cubic foot volume
and a 530 lb ice/24 hour capacity rate.
TABLE IV.21—RELATIONSHIP BETWEEN HARVEST CAPACITY RATE, EFFICIENCY LEVEL, AND VOLUME FOR IMH AIRCOOLED BATCH ICE MAKERS BETWEEN 300 AND 600 LB ICE/24 HOURS
Energy use
(kWh/100 lb
ice)
mstockstill on DSK4VPTVN1PROD with RULES2
Harvest capacity rate
(lb ice/24 hours)
305
310
335
360
370
380
404
357
358
368
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
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6.80
6.80
6.64
6.45
5.90
6.70
6.10
6.30
5.95
6.10
28JAR2
Percent
efficiency
level *
(%)
11.0
10.5
10.0
10.0
16.6
4.2
10.1
12.4
17.1
14.0
Volume
(cu ft)
6.7
6.7
6.7
6.7
7.0
7.0
7.3
8.3
8.3
8.3
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
4683
TABLE IV.21—RELATIONSHIP BETWEEN HARVEST CAPACITY RATE, EFFICIENCY LEVEL, AND VOLUME FOR IMH AIRCOOLED BATCH ICE MAKERS BETWEEN 300 AND 600 LB ICE/24 HOURS—Continued
Energy use
(kWh/100 lb
ice)
Harvest capacity rate
(lb ice/24 hours)
448
448
530
530
366
459
590
300
316
320
335
370
388
390
405
410
485
490
538
555
300
380
400
528
486
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
...............................................................................................................................................
Percent
efficiency
level *
(%)
6.10
6.10
5.00
5.00
6.00
5.80
5.90
6.20
6.36
6.20
5.97
5.94
6.00
5.79
5.80
5.73
6.00
5.41
6.00
5.29
6.50
5.80
6.40
6.00
5.30
Volume
(cu ft)
4.8
4.8
20.7
20.7
15.6
9.2
5.5
19.3
15.7
17.4
19.1
16.1
13.3
16.2
14.4
14.9
5.6
14.8
4.7
15.8
15.4
17.0
6.2
4.9
16.6
8.3
8.3
8.3
8.3
8.5
8.5
8.9
9.1
9.1
9.1
9.1
9.1
9.1
9.1
9.1
9.1
9.1
9.1
9.1
9.1
9.6
9.6
9.6
9.6
17.6
* Percent energy use less than baseline energy use.
mstockstill on DSK4VPTVN1PROD with RULES2
In response to AHRI, DOE notes that
modifications have been made to the
engineering analysis to incorporate new
data provided by interested parties
regarding the expected energy savings
resulting from the incorporation of
design options. These modifications
have resulted in a reevaluation of maxtech levels for several equipment
classes. See chapter 5 of the final rule
TSD for the results of the analyses and
a list of technologies included in maxtech equipment. Table IV.22 below
compares the max-tech levels of AHRI’s
NOPR comment to DOE’s NOPR phase
max-tech levels, the maximum available
efficiency levels, and the max-tech
levels of DOE’s final rule analysis. The
final-rule max-tech levels are higher
than the AHRI max-tech levels in only
three classes, IMH–W–Small–B, IMH–
A–Small–B, and RCU–NRC–Large–B1
(1,500 lb ice/24 hour representative
capacity). AHRI’s comment mentions
that certain design options were
removed from consideration as part of
AHRI’s ‘‘correction’’ of the DOE
analysis. These design option changes
are described in Exhibit 3 of the
comment. (AHRI, No. 93 at p. 24).
For IMH–A–Small–B, AHRI
eliminated ‘‘increase in evaporator area
by 51% (with chassis growth)’’.
Efficiency improvement of 12.8 percent
is attributed to this design option in the
final rule analysis, accounting for more
than the 7 percent difference between
the DOE and AHRI max-tech
projections. For IMH–W–Small–B, AHRI
similarly eliminated design options
involving increase in chassis size. AHRI
indicated that design options that
increase package size should not be
considered for these classes because
they include 22-inch units, which AHRI
claimed to be space-constrained. DOE
retained consideration of these design
options for the final rule analysis,
conducting additional analysis for 22inch wide models, and considering the
installation cost impacts of the larger
chassis size for a representative
population of units where some
rebuilding of the surrounding space
would be required to accommodate the
larger size (see section IV.G.2) DOE
considers package size increase a
potential for added cost, rather than a
reduction in utility that must be
screened out of the analysis, since
added cost is not one of the four
screening criteria. (see 10 CFR 430,
subpart C, appendix A, section (4)(a)(4))
For RCU–NRC–Large–B1, DOE’s final
rule max-tech efficiency level is only 1
percent higher than the AHRI max-tech
level, and the maximum available
efficiency levels is equal to the AHRI
max-tech level. For this class, AHRI
modified the performance improvement
associated with higher-EER
compressors. DOE’s analysis uses ice
maker efficiency improvement
attributable to compressor improvement
slightly better than assumed by AHRI—
DOE’s estimate is based on a larger
dataset of test data, evaluating the ice
maker efficiency improvement possible
by using improved compressors.
TABLE IV.22—COMPARISON OF AHRI MAX TECH LEVELS WITH DOE NOPR AND FINAL RULE MAX TECH LEVELS
Representative
capacity
(lb ice/24 hours)
Equipment class
IMH–W–Small–B ....................................
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(% below
baseline)
300
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tech
(% below
baseline)
18
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29
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DOE final rule
max tech
(% below
baseline)
Max available
(% below
baseline)
19
28JAR2
24
4684
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE IV.22—COMPARISON OF AHRI MAX TECH LEVELS WITH DOE NOPR AND FINAL RULE MAX TECH LEVELS—
Continued
Representative
capacity
(lb ice/24 hours)
Equipment class
IMH–W–Med–B ......................................
IMH–W–Large–B–1 ...............................
IMH–W–Large–B–2 ...............................
IMH–A–Small–B .....................................
IMH–A–Large–B–1 ................................
IMH–A–Large–B–2 ................................
RCU–NRC–Large–B–1 ..........................
RCU–NRC–Large–B–2 ..........................
SCU–W–Large–B ...................................
SCU–A–Small–B ....................................
SCU–A–Large–B ...................................
IMH–A–Small–C ....................................
IMH–A–Large–C ....................................
SCU–A–Small–C ....................................
AHRI max tech
(% below
baseline)
850
1500
2600
300
800
1500
1500
2400
300
110
200
310
820
110
DOE NOPR max
tech
(% below
baseline)
18
15
14
19
25
18
16
18
30
39
35
26
30
28
Max available
(% below
baseline)
21
17
15
31
29
20
21
21
30
39
35
31
30
28
14
5
2.5
19
16
6
16
15
28
31
26
28
36
24
DOE final rule
max tech
(% below
baseline)
18
8
7
26
16
12
17
14
30
33
29
26
23
27
provided confidentially by
manufacturers to DOE’s contractor.
Based on the data DOE reviewed, the ice
maker energy use reduction associated
with improvement in compressor EER
averages 57 percent of the compressor
energy use reduction expected based on
the EER improvement—DOE used this
ratio for its analysis of batch ice makers
for the final rule. Hence, this particular
issue with the engineering analysis has
been addressed through changes in
DOE’s approach in both the NODA and
final rule analyses.
3. Design Options
a. Design Options That Need Cabinet
Growth
assessment could require an increased
cabinet size. Examples of such design
options include increasing the surface
area of the evaporator or condenser, or
both. Larger heat exchangers would
enable the refrigerant circuit to operate
with an increased evaporating
temperature and a decreased
Some of the design options
considered by DOE in its technology
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After conducting the screening
analysis and removing from
consideration the technologies
described above, DOE considered the
inclusion of the remaining technologies
as design options in the final rule
engineering analysis. The technologies
that were considered in the engineering
analysis are listed in Table IV.23, with
indication of the equipment classes to
which they apply.
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mstockstill on DSK4VPTVN1PROD with RULES2
In response to AHRI’s comment that
the FREEZE model has been proven to
be invalid, DOE notes that this comment
is based on tests illustrating the ice
maker efficiency improvement
associated with two examples of switch
to higher-EER compressors. AHRI points
to only one of the design options
considered in the DOE’s analysis, for
which DOE updated its analysis. DOE
has modified its treatment of
compressors in the analysis, basing the
calculation of ice maker efficiency
improvement on test data provided both
by the AHRI comment and other data
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
condensing temperature, thus reducing
the temperature lift imposed on the
refrigeration system and hence the
compressor power input. In some cases
the added refrigerant charge associated
with increasing heat exchanger size
could also necessitate the installation of
a refrigerant receiver to ensure proper
refrigerant charge management in all
operating conditions for which the unit
is designed, thus increasing the need for
larger cabinet size.
In the preliminary analysis, DOE did
not consider design options that
increase cabinet size. However, in the
NOPR DOE changed the approach and
considered design options that increase
cabinet size for certain equipment
classes: IMH–W–Small–B, IMH–A–
Small–B, IMH–A–Large–B (800 lb ice/24
hours representative capacity), and
IMH–A–Small–C. DOE only applied
these design options for those
equipment classes where the
representative baseline unit had space
to grow relative to the largest units on
the market. DOE also considered size
increase for the remote condensers of
RCU classes.
In response to the March 2014 NOPR,
several manufacturers noted that the
size of icemakers is limited in certain
applications. Manitowoc commented
that not all end users can accept larger
or taller ice-making cabinets.
(Manitowoc, Public Meeting Transcript,
No. 70 at p. 133) Ice-O-Matic
commented that customers want ice
machines that are able to produce more
ice in a smaller physical space and that
such ice makers will be difficult to make
if standards necessitate design options
that require cabinet growth. (Ice-OMatic, Public Meeting Transcript, No.
70 at p. 29–31)
Scotsman and AHRI both noted that
cabinet size increases would require
users to either enlarge the space in the
kitchen to accommodate a larger unit or
to repair older ice makers rather than
buying new ones or to make due with
a smaller capacity ice maker. (AHRI, No.
93 at p. 7–8; Scotsman, Public Meeting
Transcript, No. 70 at p. 126–127)
Manitowoc, Ice-O-Matic, and AHRI each
stated that incorporating design options
that may increase the size of automatic
commercial ice makers will increase the
likelihood that consumers refurbish
rather than replace their existing units.
(Manitowoc, Public Meeting Transcript,
No. 70 at p. 129–130; Ice-O-Matic,
Public Meeting Transcript, No. 70 at p.
32–33; AHRI, No. 93 at p. 7–8)
Scotsman, Manitowoc and Follett all
agreed that large ice makers would have
an impact in installation costs.
(Scotsman, No. 85 at p. 5b–6b;
Manitowoc, No. 92 at p. 3; Follett, No.
84 at p. 6) Follett commented that
maintenance costs will increase because
larger components will reduce
serviceability and energy-efficient
components, such as a lower
horsepower auger motor, may not be as
robust. (Follet, No. 70 at p. 132–133)
AHRI commented that design options
which increase chassis size should not
be considered for IMH–A–Small–B,
IMH–A–Large–B, IMH–W–Small–B, and
IMH–W–Med–B classes, as 22-inch
units wide units account for 18% of all
ice makers sold in the US. AHRI added
that if design options which increase
cabinet size are not screened out for
these product classes, there will likely
be an adverse impact on product
availability. (AHRI, No. 93 at p. 4)
In contrast, PGE/SDG&E commented
that they support DOE’s decision to
include in the engineering analysis
4685
design options that increase chassis
size. (PG&E and SDG&E, No. 89 at p. 3)
The Joint Commenters expressed their
belief that DOE has appropriately
considered size increases in their
engineering analysis and that those
customers who have smaller units today
could purchase a taller unit with the
same capacity, a smaller-capacity unit,
or two smaller-capacity units. (Joint
Commenters, No. 87 at p. 3)
In response to the NODA analysis, CA
IOU stated their support of DOE
including technically (DOE interprets
this to mean technologically) feasible
design options that may increase chassis
sizes in certain cases. (CA IOU, No. 129
at p. 2)
DOE recognizes that the size of ice
makers is limited in certain
applications. DOE notes that many of
the equipment classes analyzed do not
require any cabinet growth to reach
higher efficiency levels. DOE considered
design options involving package size
increase for IMH–A–Large–B, IMH–A–
Small–B, and IMH–W–Med units. For
the final rule analyses, DOE did not
consider design options which
necessitate a cabinet size increase for
IMH–A–Small–C units. DOE adjusted
the analysis of installation costs to
consider the impact of added costs
associated with renovation to
accommodate size increase for the few
equipment classes for which DOE did
consider size increase. The life cycle
cost analysis, described in section
IV.G.2 details how these added
installation costs were considered in the
analysis.
Table IV.24 lists the equipment
classes for which DOE considered
design options that involve increase in
chassis size in the final rule analysis.
TABLE IV.24—ANALYZED EQUIPMENT CLASSES WHERE DOE ANALYZED SIZE-INCREASING DESIGN OPTIONS IN THE FINAL
RULE ANALYSIS
Harvest capacity
lb ice/24 hours
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Unit
IMH–A–Small–B .......................................................................
IMH–A–Large–B (med) ............................................................
IMH–A–Large–B (large) ...........................................................
IMH–W–Small–B ......................................................................
IMH–W–Med–B ........................................................................
IMH–W–Large–B .....................................................................
RCU–XXX–Large–B (med) ......................................................
RCU–XXX–Large–B (large) .....................................................
SCU–A–Small–B ......................................................................
SCU–A–Large–B .....................................................................
SCU–W–Large–B ....................................................................
IMH–A–Small–C ......................................................................
IMH–A–Large–C (med) ............................................................
SCU–A–Small–C .....................................................................
300
800
1,500
300
850
2,600
1,500
2,400
110
200
300
310
820
110
Used design options that increased size?
Yes.
Yes.
No.
Yes.
No.
No.
For the remote condenser, but not for the ice-making head.
For the remote condenser, but not for the ice-making head.
No.
No.
No.
No.
No.
No.
Note: ‘‘XXX’’ refers to ‘‘RC’’ or ‘‘NRC’’ for each of the entries with ‘‘XXX’’.
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b. Improved Condenser Performance
During the NOPR analysis, DOE
considered size increase for the
condenser to reduce condensing
temperature and compressor power
input. DOE requested comment on use
of this design option and on the
difficulty of implementing it in ice
makers with size constraints.
Follet commented that 10 °F is the
practical limit for the temperature
difference between the ambient air and
the hot gas in the condenser. Follet
added that it is possible to increase the
surface area, but either no meaningful
efficiency is gained, or the size of the
condenser would have to increase to the
point that it would not fit into tight
spaces. (Follet, No. 84 at p. 5)
DOE did not consider any condenser
sizes that would result in condensing
temperatures as close as 10 °F to the
ambient temperatures for air-cooled
icemakers.
Stakeholders AHRI, Hoshizaki, Follet,
and Ice-O-Matic noted that improved
condenser performance would likely
require an increase in cabinet size.
(AHRI, No. 93 at p. 4; Hoshizaki, Public
Meeting Transcript, No. 70 at p. 128–
129; Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 32–33; Follet,
No. 84 at p. 5)
In response to concerns about the
potential need to increase cabinet size to
make space for larger condensers, DOE
agrees that increasing condenser size
may require also increasing cabinet size.
DOE has limited cabinet size increases
to just three equipment classes, IMH–A–
Large–B, IMH–A–Small–B, and IMH–
W–Small–B. Furthermore, the specific
size increases considered for these ice
makers do not involve size increase
beyond the size of ice makers that are
currently being sold. The specific size
increases considered are presented in
Chapter 5 of the TSD. In addition, the
life cycle cost analysis considers
additional installation cost associated
with a proportion of ice makers sold as
replacements that, with the new larger
sizes, will not fit in the existing spaces
where the old ice makers are located
(see section IV.G.2.a).
Manitowoc commented regarding
condenser size increase for water-cooled
ice makers that increasing water-cooled
surface area can reduce the condensing
temperature and cause the ice machine
to be unable to harvest the ice at low
inlet water temperature conditions,
which affects the performance of models
in northern regions. (Manitowoc, Public
Meeting Transcript, No. 70 at p. 108–
110)
DOE is aware that increasing
condenser surface area may have an
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impact on the ice machine’s ability to
harvest ice. As discussed in the NOPR,
DOE generally avoided consideration of
very low condensing temperatures in its
analysis, using 101 °F as a guideline
lower limit. The analysis also
considered the increase in harvest cycle
energy use—Section IV.D.4 describes
how the longer harvest times were
addressed in the engineering analysis.
Manitowoc noted that the NODA EL3
level for the RCU–NRC–B2 equipment
class assumes a 19-inch increase in
condenser width with an additional
condenser row. Manitowoc asserted that
an increase this large could lead to
significant refrigerant charge issues.
Therefore, Manitowoc suggested that
NODA EL2 be selected for this
equipment class. (Manitowoc, No. 126
at p. 2)
In the final rule DOE modified the
engineering analysis for this class and
has eliminated one of the two condenser
size increase steps in the final rule
engineering analysis. DOE notes that the
final condenser size is still smaller on
the basis of refrigerant volume per
harvest capacity rate than the largest
remote condenser for an RCU ice maker
observed in DOE’s review of units
purchased for reverse engineering.
Therefore, DOE has confidence that the
refrigerant management challenges are
manageable for the maximum condenser
size considered in the analysis.
Manitowoc also noted that adding a
condenser row in the SCU–A–Small–B
class may not be possible due to the
small volume available in the compact
chassis required for these models.
Similarly, a 9’’ increase in condenser
width for the SCU–A–Large–B may be
unrealistic. (Manitowoc, No. 126 at p. 2)
In selecting these design options, DOE
reviewed the spatial constraints and
condenser sizes within both reverseengineered units used as the basis for
energy use calculations for these classes.
While the space underneath the ice
storage bins of these units is limited in
height, there is sufficient room for the
width and depth increases that DOE
considered. Based on data gathered from
these teardowns, DOE concluded that
these condenser size design options
were feasible for these units.
c. Compressors
Several interested parties provided
comment regarding the feasibility of
incorporating more efficient
compressors in ACIMs. AHRI urged
DOE to reevaluate the feasibility of
implementing more efficient
compressors into the IMH–A–Small–C
product class, which Follett has found
are too small to fit larger compressors.
(AHRI, No. 93 at p. 4) Follett also
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individually commented that they
independently evaluated a more
efficient compressor for IMH–A–Small–
C and that its size made it infeasible
given the restrictions of the Follett
chassis. (Follet, No. 84 at p. 8)
In response to AHRI and Follet’s
assertion that higher efficiency
compressors may not fit within the
chassis of IMH–A–Small–C, DOE’s
analysis of this class was based on use
of a Copeland RST45C1E–CAV
compressor, which is no larger than the
compressor used in the model upon
which DOE based the analysis. Hence,
DOE concluded that use of this higherefficiency compressor would not require
an increase in the package size. DOE
notes that it did avoid consideration of
the highest-efficiency compressors for
22-inch wide classes when these
compressors clearly are physically
larger than the available space allows. In
particular, DOE did not consider use of
high-efficiency Bristol compressor in
these cases, because Bristol compressors
are generally larger than other available
compressors.
Several commenters, including AHRI,
NEEA, Danfoss, and Ice-O-Matic each
noted that the harvest process of
automatic commercial ice makers needs
to be considered when evaluating
increased compressor efficiency as a
design option. (AHRI, No. 93 at p. 4;
NEEA, No. 91 at p.1; Danfoss, Public
Meeting Transcript, No. 70 at p. 152–
153; Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 160–161)
Danfoss and Ice-O-Matic commented
that ice machines differ significantly
from other compressor-based
applications in that, when harvesting
ice, it is desirable to have a less efficient
compressor because the waste heat
helps harvest the ice. (Danfoss, Public
Meeting Transcript, No. 70 at p. 152–
153; Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 160–161)
In response, DOE has adjusted its
calculation of energy savings associated
with improved compressor efficiency in
the NODA and final rule analyses.
Specifically, DOE considered all
available data for tests involving
compressor replacement for batch ice
makers. This included the two examples
provided in AHRI’s NOPR comment.
(AHRI, No. 93 at pp. 25–30) It also
included information provided
confidentially to DOE’s contractor. DOE
reviewed the data to determine if it
could be used to robustly predict any
trends of ice maker performance
impacts compared with compressor EER
improvements that might vary as a
function of key parameters such as ice
maker class, capacity, compressor
manufacturer, but no such trends were
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evident. DOE used the data to develop
an estimate of ice maker energy use
reduction as a fraction of compressor
energy use reduction—this value
averaged 0.57 for the data set. DOE used
this factor to calculate ice maker energy
use reduction for all of the batch
analyses for the NODA and final rule.
Applying this approach significantly
reduced the energy savings associated
with improved-EER compressors for
batch ice makers in the NODA and final
rule analyses.
Howe commented that variable-speed
compressors are most effective at saving
energy under part-load conditions,
which is not taken into account in the
DOE test procedure. Therefore, such
components would be operating at or
near maximum capacity during DOE
tests, thus canceling their positive
measurable benefit. (Howe, No. 88 at p.
1)
In response to Howe’s comment
regarding variable speed compressors,
DOE did not consider the use of
variable-speed compressors in the
analysis.
Several interested parties submitted
additional concerns about the feasibility
of implementing design options
involving increases in compressor
efficiency. NAFEM commented that
high-efficiency compressor motors for
automatic commercial ice makers will
not be available for the foreseeable
future and that the investment required
was not available for products with
shipments as low as automatic
commercial ice makers (150,000/year)
and that DOE must account for their
unavailability in its analysis. (NAFEM,
No. 82 at p. 10)
In response, DOE considered only
compressors that are currently offered
for use by compressor manufacturers.
All of the compressors considered in the
analysis are currently commercially
available and are acceptable for use in
ice makers as indicated by
manufacturers in confidential
discussions with DOE’s contractor.
Hence, DOE does not need to consider
the development of new compressors
with higher-efficiency motors. The
compressors considered in the analysis
are listed in the compressor database.
(Compressor Database, No. 135)
In response to the NODA, Manitowoc
noted that the RCU–NRC–B1 equipment
class assumes an increase in compressor
EER of 20% which Manitowoc stated
could not be achieved without resorting
to radical design changes and possibly
the use of permanent magnet motor
technology. (Manitowoc, No. 126 at p. 3)
Additionally, Manitowoc stated that for
SCU–A–Small–B and SCU–Large–B,
increases in compressor EER of 40%
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and 25%, respectively, are unlikely to
be achieved. (Manitowoc, No. 126 at p.
2)
For the RCU–NRC–Large–B–1 class,
DOE based the analysis on a unit with
a compressor having a rated EER of 7.16
Btu/Wh. In order to represent baseline
performance, a less-efficient available
compressor was used in the analysis.
For the final rule, DOE modified its
analysis to reflect a lower efficiency
level for the unit which is the basis of
the analysis. Hence, DOE has reduced
the compressor EER improvement
considered for this class from 20 percent
to 10.7 percent.
For the SCU–A–Small–B class, DOE
based the analysis on an ice maker
having a compressor with a rated EER
of 3.3 Btu/Wh. The analysis considered
use of an available compressor having a
rated EER of 4.6 Btu/Wh, a 39 percent
improvement. Compressors having both
these levels of EER exist, and hence the
39 percent improvement in EER from
3.3 to 4.6 can be achieved.
For the SCU–A–Large–B class, DOE
based the analysis on an ice maker
model having a compressor with a rated
EER of 4.68 Btu/Wh. DOE modeled the
baseline by considering a lower EER of
4.23 Btu/Wh. Compressors within the
appropriate capacity range at this EER
level do exist. The highest-EER
considered for this analysis is 5.2 Btu/
Wh, which is achieved by an available
compressor of appropriate capacity—
this represents 23 percent improvement
in EER, slightly less than the cited 25
percent. Compressors having both these
levels of EER considered in the analysis
exist, and hence the 23 percent
improvement in EER from 4.23 to 5.2
can be achieved.
In response to the NODA analysis for
equipment class SCU–A–Small–C, AHRI
noted that DOE increased the ‘‘percent
energy use reduction’’ from 8.5% in the
NOPR to 10.91% in the NODA for the
same design option, ‘‘Changed
compressor EER from 4.7 to 5.5’’. AHRI
requested that DOE provide justification
for this change. (AHRI, No. 128 at p.3)
In the NODA, DOE had calculated
continuous ice maker percentage
savings as 75% of the compressor
energy savings (0.75 × (1¥4.7/5.5) =
0.109), rather than using the results of
the FREEZE model to represent the
compressor energy savings. However,
the ice maker upon which the SCU–A–
Small–C analysis was based has a
greater proportion of auger and fan
energy use than typical continuous
units. Hence, DOE agrees that an
increase in the savings projection to
10.9% is unrealistic, and has changed
the projection.
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For the final rule analysis, DOE also
did not use the FREEZE model, and
instead assumed that the compressor
energy use reduction would be 5% less
than would be expected, based on the
EER increase. The compressor energy
use for the unit started at 72% of unit
energy use, and the design options
considered prior to consideration of the
improved-EER compressor already
reduced energy use to 90.7% of baseline
energy use. Hence, DOE recalculated the
savings for this design option as 0.95 ×
(1¥4.7/5.5) × 0.72 × 0.907 = 0.09 = 9%.
d. Evaporator
Follett commented that increasing the
length or width of continuous type
evaporators would increase cabinet size.
(Follet, Public Meeting Transcript, No.
70 at p. 90–91) Follett also commented
that increasing the height of the
continuous type evaporator is not
feasible because, in 75% of Follett’s
automatic commercial ice makers, the
evaporator is horizontal. Therefore, any
evaporator growth would increase the
icemaker footprint so that it could no
longer fit on standard beverage
dispensers. (Follett, No. 84 at p. 5–6)
DOE notes that it did not consider
evaporator size increase as a design
option for continuous ice makers in the
final rule engineering analysis.
In response to the NODA, AHRI noted
that IMH–W–Small–C units typically
use the same chassis as their IMH–A–
Small–B counterparts and should also
be considered as space constrained
units. Specifically, AHRI recommended
screening out the increased evaporator
size for this product class on the basis
that the chassis could not withstand the
corresponding 4-inch increase in width.
AHRI added that if evaporator size
increase option is kept for IMH–W–
Small–C units, a more realistic cost
must be associated with this design
option. (AHRI, No. 128 at p. 2)
In response to AHRI’s comment, DOE
notes that the typical use of the same
cabinet as IMH–A–Small–B does not
mean there is no possible cabinet size
increase. Nevertheless DOE has
eliminated this design option step from
the analysis for the IMH–A–Small–C.
The evaporator size increase was
considered in the NOPR analysis in
conjunction with a condenser size
increase. In the final rule analysis, this
step in the analysis now considers only
the condenser size increase.
AHRI stated in its NODA comments
that an 18 percent size increase in
evaporator area cannot reasonably be
implemented in 22-inch IMH–A–Small–
B units. (AHRI, No. 128 at p. 2). DOE
developed its 22-inch IMH–A–Small–B
analysis by removing from the 30-inch
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chassis analysis for IMH–A–Small–B
those design options that would not fit
in a 22-inch chassis. The baseline
evaporator used in the model upon
which DOE based this analysis has a
plate area that is relatively small. Hence,
the 18 percent size increase can fit
within the chassis of a 22-inch unit. In
fact, the maximum-available 22-inch
unit of this class has an evaporator that
is somewhat larger than the largest
evaporator size considered for the
analysis. Hence, DOE concludes that it
did not consider excessive increase in
evaporator size for the 22-inch IMH–A–
Small–B analysis.
In response to the NODA, Manitowoc
stated that for IMH–A–Small–B units, a
51% increase in evaporator surface area
is not always possible in the chassis
sizes used in the industry and
concluded that the max efficiency level
that should be considered is EL3.
(Manitowoc, No. 126 at p. 1)
DOE agrees that the design option
mentioned by Manitowoc, a 51%
increase in evaporator surface area for
IMH–A–Small–B units would require a
growth in cabinet size. Consequently,
DOE considered such a growth in the
engineering analysis. DOE notes that the
NODA TSL 3 efficiency level for this
class, 18% less energy than baseline,
can be achieved with an evaporator
growth less than 51%—DOE estimates
that this would require evaporator size
growth of 38%.
Manitowoc stated that the IMH-small
class would likely require chassis
growth to add evaporator area.
(Manitowoc, No. 126 at p. 2). DOE
assumes that this refers to the IMH–W–
Small–B class and agrees that some
increase in chassis size may be required
to support increases in evaporator size.
DOE notes that IMH–W–Small–B is one
of the classes for which DOE considered
increase in chassis size.
e. Interconnectedness of Automatic
Commercial Ice Maker System
Several commenters noted that the
addition of a certain design option may
necessitate an alteration in the
remaining automatic commercial ice
maker components. AHRI stated their
concern with DOE’s component
analysis, noting that a change in one
component impacts other components
and therefore the entire price and
efficiency of the entire automatic
commercial ice maker system. (AHRI,
No. 128 at p. 2) Similarly, Scotsman
stated that the manufacture product cost
increase estimates do not account for
system impacts when components are
changed. In most cases it is inaccurate
to estimate product cost changes by
specific component as changing any
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component within the refrigeration
system will require changes to other
components in order to optimize
performance efficiency. (Scotsman, No.
125 at p. 2) Similarly, Howe commented
that component efficiency increases are
not additive and not necessarily
proportional when used in combination.
(Howe, No. 88 at p. 2)
As explained in the NOPR, DOE had
attempted to conduct an efficiency-level
analysis rather than a design-option
approach. However, the efficiency-level
analysis did not produce consistent
results, in some cases indicating that
higher-efficiency units are less
expensive. Therefore, DOE went
forward with the design option
approach and solicited comments from
interested parties regarding the impact a
specific design option may have on the
entire system. DOE’s contractor received
some information regarding the
potentially higher costs associated with
change of some components, for which
it may have underestimated overall cost
increase in the NOPR phase—this
information has been incorporated into
the final rule analysis. However, absent
more specific information regarding
these interactions, DOE cannot
speculate on other changes that may
have been appropriate to address this
issue.
Manitowoc commented that putting a
larger evaporator in an ice machine
would increase refrigerant charge, thus
necessitating an accumulator, or
rendering a compressor unreliable
during harvest. Such a change would
also increase the mass of the evaporator,
thus requiring more energy to heat it up
and cool it back down. (Manitowoc,
Public Meeting Transcript, No. 70 at p.
142–143)
DOE has not considered evaporator
sizes (on the basis of evaporator size per
ice maker capacity in lb ice/24 hours)
larger than those of ice makers on the
market. DOE has not observed use of
accumulators and hence concludes that
the evaporator sizes considered would
not require one. While Manitowoc
commented in the NOPR public meeting
on the potential for added harvest time
or harvest energy use for larger
evaporators, they did not provide details
in written comments showing how this
effect might impact savings associated
with larger evaporators. DOE notes that
a larger evaporator would operate with
warmer evaporating temperature during
the freeze cycle, and this effect would
reduce the heat required to warm the
evaporator during the harvest cycle.
Without data to quantify this effect,
DOE’s analysis assumed that harvest
energy use would scale proportionally
with evaporator area. Hence, the
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increase in mass of the evaporator has
been accounted for in the estimation of
the energy use reduction associated
with the design option.
Follett commented that the
evaporator, auger motor, and
compressor must all be sized to balance
one another and that these components
cannot easily be swapped out for other
off-the-shelf components. (Follett, No.
84 at p. 5) Follett noted that increasing
evaporator diameter is not feasible
because it will increase the required
torque, necessitating a larger motor that
will draw more power and negate any
efficiency gains. (Follet, No. 84 at p. 6)
DOE is no longer considering
evaporator size increase as a design
option for continuous ice makers.
However, DOE notes that the
engineering analysis has attempted to
consider the interconnectedness of the
system components wherever possible.
For example, for air cooled condenser
growth, fan power was increased to
maintain a constant airflow through a
larger condenser.
Hoshizaki commented that there is a
lot of trial and error involved in pairing
compressors with condensers while
maintaining machine reliability.
(Hoshizaki, Public Meeting Transcript,
No. 70 at p. 159–160)
DOE realizes that there may be trial
and error when pairing components.
DOE solicited feedback from
manufactures regarding the
appropriateness of the use of specific
compressors in the analysis. DOE did
not identify any specific limitations in
compressor/condenser pairings that it
considered in its analysis in any
comments or in interviews with
manufacturers.
4. Cost Assessment Methodology
In this rulemaking, DOE has adopted
a combined efficiency level, design
option, and reverse engineering
approaches to develop cost-efficiency
curves. To support this effort, DOE
developed manufacturing cost models
based heavily on reverse engineering of
products to create a baseline MPC. DOE
estimated the energy use of different
design configurations using an energy
model with input data based on reverse
engineering, automatic commercial ice
maker performance ratings, and test
data. DOE combined the manufacturing
cost and energy modeling to develop
cost-efficiency curves for automatic
commercial ice maker equipment based
to the extent possible on baselineefficiency equipment selected to
represent their equipment classes (in
some cases, analyses were based on
equipment with efficiency levels higher
than baseline). Next, DOE derived
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manufacturer markups using publicly
available automatic commercial ice
maker industry financial data, in
conjunction with manufacturer
feedback. The markups were used to
convert the MPC-based cost-efficiency
curves into Manufacturer Selling Price
(MSP)-based curves.
The engineering analyses are
summarized in an ‘‘Engineering
Results’’ spreadsheet, developed
initially for the NOPR phase (NOPR
Engineering Results Spreadsheet, No.
59). This document was modified for
the NODA (Engineering Analysis
Spreadsheet—NODA, No. 112) and
subsequently for the final rule (Final
Rule Engineering Analysis Spreadsheet,
No. 134)
Stakeholder comments regarding
DOE’s NOPR and NODA engineering
analyses addressed the following broad
areas:
1. Estimated costs in many cases were
lower than manufacturers’ actual costs.
2. Estimated efficiency benefits of
many modeled design options were
greater than the actual benefits,
according to manufacturers’ experience
with equipment development.
3. DOE should validate its energy use
model based on comparison with actual
equipment test data.
These topics are addressed in greater
detail in the sections below.
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a. Manufacturing Cost
In response to the manufacturer costs
presented in the NOPR, several
stakeholders indicated that the
incremental costs presented in the
NOPR were optimistic. Specifically,
AHRI, Follet, Manitowoc, and Danfoss
stated the belief that DOE
underestimated the incremental costs of
its proposed design options. (AHRI, No.
93 at p. 4; Follet, No. 84 at p. 5; Danfoss,
No. 72 at p. 3; Manitowoc, No. 98 at p.
1–2)
Scotsman commented that their data
on the efficiency and costs associated
with compressor upgrade, BLDC motors,
larger heat exchangers, and drain water
heat exchangers do not match the
assumptions used by DOE in its
analysis. (Scotsman, No. 85 at p. 4b)
Manitowoc commented that DOE
significantly underestimates the cost
associated with heat exchanger growth,
higher compressor EER, and highefficiency fan and pump motors.
(Manitowoc, No. 98 at p. 1–2)
Manitowoc also noted that their costs
were not consistent with those found in
the TSD, particularly in cases involving
evaporator or cabinet growth
(Manitowoc, Public Meeting Transcript,
No. 70 at p. 116–117)
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DOE has revised and updated its
analysis based on data provided in
comments and made available through
non-disclosure agreements. These
updates included changes in its
approach to calculating the energy use
associated with groups of design
options, changes in inputs for
calculations of energy use, and changes
in calculated equipment manufacturing
cost. Comments related to the
manufacturing costs of specific design
options are described in the sections
below.
NAFEM and Hoshizaki stated that the
cost curves were not analyzed to
demonstrate what can be achieved in
five years. (NAFEM, No. 123 at p. 2;
Hoshizaki, No. 123 at p. 1)
In response to NAFEM and
Hoshizaki’s comment, DOE notes that
the costs in the cost curves are intended
to be representative of today’s
technology and current market prices.
Compressor Costs
AHRI, Danfoss, and Hoshizaki stated
that DOE’s assumption that a 10%
compressor efficiency increase could be
achieved for a 5% price increase is
flawed. (AHRI, Public Meeting
Transcript, No. 70 at p. 20–21; Danfoss,
No. 72 at p. 3; Hoshizaki, No. 86 at p.
9) AHRI and Danfoss stated that a more
realistic assumption would be a 1–2%
efficiency improvement for a 5% price
increase. (Danfoss, No. 72 at p. 3; AHRI,
Public Meeting Transcript, No. 70 at p.
20–21) AHRI and NAFEM both
requested that the relationship between
cost and compressor EER should be
corrected to reflect the approach
adopted by the final CRE rulemaking.
(AHRI, No. 93 at p. 15; NAFEM, No. 82
at p. 4–5) Follet also asserted that it is
unrealistic to assume that the full
efficiency gain of a more efficient
compressor will be realized at the costs
assumed by DOE in the NOPR. (Follet,
No. 84 at p. 5) In response to the NODA,
AHRI stated that there was no
explanation as to why the compressor
costs changed as compared to the
NOPR. AHRI noted that the NODA
compressor costs were still not
consistent with the approach used in
the CRE rulemaking. (AHRI, No. 128 at
p. 2)
DOE maintains its position that the
cost-EER relationship used in the CRE
rulemaking was based on future
improvements over existing EER levels.
For example, the CRE final rule
indicates that ‘‘manufacturers and
consumers expressed concern over
DOE’s assumptions regarding the
advances in compressor technology
anticipated before the compliance date.’’
79 FR 17726, 17760 (March 28, 2014).
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Compressor suppliers and OEMs
commented that, ‘‘if a 10% compressor
efficiency improvement were possible
for a 5% cost increase, then it is most
likely that manufacturers would have
already adopted this technology’’. Id.
The statement implies that
manufacturers have not adopted the
technology. In the automatic
commercial ice maker NOPR public
meeting, Danfoss, a compressor
supplier, commented, ‘‘these are mature
technologies. They’ve been around 50 or
60 years. If that sort of efficiency
improvement could be made available,
it would have . . . we would have
already done it.’’ The comments
insinuate that DOE was contemplating
use of a technology that is not available
and that the compressor manufacturers
have not used. For the automatic
commercial ice maker analysis, DOE did
not consider future technologies. Rather,
it considered only compressor options
that are currently being offered by
compressor suppliers. In some cases,
baseline ice makers are using
compressors with relatively low
efficiencies compared to the levels that
are available. It is for these cases that
DOE has been projecting the possibility
of large potential for compressor
efficiency improvements. DOE has
requested compressor cost data that
would allow evaluation of the
relationship between actual prices paid
by automatic commercial ice maker
manufacturers for the compressors and
the EER levels of the compressors,
indicating that this data might be
provided confidentially to DOE’s
contractor. However, sufficient cost data
to allow a regression analysis to
determine the efficiency-cost
relationship has not been made
available. Based on limited data
supplied confidentially to DOE’s
contractor during the NOPR phase, DOE
initially concluded that cost does not
vary significantly with EER. In addition,
DOE received some feedback during
interviews with manufacturers that the
10% improvement for 5% cost
relationship is reasonable. DOE at that
time adopted this relationship in order
to avoid projecting zero cost increase
associated with EER increase.
Nevertheless, DOE has modified its
approach to calculating improvement in
compressor efficiency to consider the
stakeholders’ comments. The analysis
calculates the cost associated with
compressor EER improvement in two
ways and uses the higher of these costs.
The first approach is the 10%
improvement for 5% cost used in the
NOPR analysis. The second approach
applies the 5% cost associated with the
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2% improvement that the commenters
cited, which DOE applied to the
analysis as if the last 2% of compressor
efficiency improvement is future
efficiency improvement that would cost
the cited 5%. For example, if the
compressor efficiency improvement is
10%, this approach treated the first 8%
of efficiency improvement to be
associated with currently available
compressors with no cost differences,
and the last 2% (from 8% to 10%
improvement) as being associated with
future compressor improvement with a
5% cost premium.
Follett disputed the NOPR
engineering result that showed a 20%
decrease in energy use at a cost of $61
for the IMH–A–Large–C class. Follet
noted that at an incremental cost of $60,
they tested a unit utilizing an ECM
motor and a compressor with a 5%
increase in efficiency, but were only
able to achieve a 9% decrease in energy
use. (Follet, No. 84 at p. 8) AHRI also
noted this work, indicating that Follett
experienced less than half the efficiency
gain predicted by DOE in the NOPR
when switching from an SPM to an ECM
motor and using a compressor with a
5% higher EER. AHRI further noted
that, while DOE’s analysis considered a
24% improvement in compressor EER,
the best compressor that Follett was able
to find improved the EER only 5%.
(AHRI, No. 93 at p. 4)
DOE notes that these comments do
not indicate the initial energy use of the
tested unit, only that the 9 percent
efficiency improvement was insufficient
to attain the NOPR-proposed efficiency
level. Further, the comments do not
indicate the initial EER of the
compressor used in the Follett product.
Since the NOPR phase, DOE has
adjusted both its energy modeling as
well as its cost estimates, so as to
mitigate this issue. Based on new data
collected through the NODA and final
rule phases, DOE has completed new
cost efficiency curves, such that the
MSP increase for the final rule analysis
associated with a 20% decrease in
energy use for the IMH–A–Large–C class
is $488. The increase is so large because,
for the final rule analysis, use of design
options other than a permanent magnet
gear motor to power the auger increase
efficiency less than 20% (roughly 18%),
and the estimated cost of the higherefficiency auger motor is very high.
While it is difficult to determine
whether the analysis is fully consistent
with Follett’s test data, DOE believes
that its revised analysis sufficiently
addresses this issue (the cost per
percent improvement for the analysis is
now $24/% ($488/20%), whereas the
cost per percent improvement for
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Follett’s cited experience is $7/% ($60/
9%)). DOE does note that this Follett
example does show that continuous ice
machines experience energy use
reductions at least consistent with the
compressor efficiency improvements—
Follett did not indicate the reduction in
motor input wattage when switching
from the shaded pole to the ECM motor,
but if the ice maker energy use
reduction for the motor change was 5%,
one would conclude that the energy use
reduction for the compressor change
was 4%, or 80% of the 5% improvement
in compressor EER—this contrasts
markedly with some of the information
provided in stakeholder comments
about the relationship between batch ice
maker energy use and compressor EER
improvement. (see, e.g., AHRI, No. 93 at
pp. 25–30)
Evaporator Costs
Hoshizaki and Manitowoc stated the
DOE underestimated the cost of
increasing the evaporator size in the
NOPR analysis, for both batch and
continuous ice makers. Specifically,
regarding the 50% evaporator size
increase considered for the IMH–A–
Small–B analysis, Hoshizaki
commented that a 50% increase in
evaporator height would result in a 50%
MPC increase. (Hoshizaki, No. 86 at p.
9) For this design option, DOE
calculated a $48 cost increase to the
initial evaporator cost of $88 in the
NOPR analysis. Manitowoc stated that
the cost presented in the NOPR for a
50% larger evaporator is half of what
they would see as a manufacturer.
Manitowoc noted that this is partially
because they only make 4000–5000
models per year of a particular cabinet
size and thus do not have as much
purchasing power as an appliance
manufacturer. (Manitowoc, Public
Meeting Transcript, No. 70 at p. 171–
174)
In the NODA and final rule analyses,
DOE adjusted the costs related to
increasing the size of the evaporator.
DOE received information from
manufacturers through non-disclosure
agreements regarding the expected costs
associated with increasing the size of
the evaporator and has adjusted the
analysis to reflect the new data. DOE’s
MPC increase projection for the same
evaporator size increase for the IMH–A–
Small–B class is now $101.
As noted in section IV.D.3.d, AHRI
commented that a more realistic cost
estimate is required for the evaporator
increase design option for IMH–W–
Small–C units as they often use the
same chassis as their IMH–A–Small
counterparts. Specifically, AHRI stated
that manufacturers have conservatively
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estimated that a 17% increase in
evaporator size should be 117% percent
of the original evaporator’s cost. (AHRI,
No. 128 at p. 2) DOE believes this
comment may apply to the IMH–A–
Small–C class rather than IMH–W–
Small–C, since the 17% evaporator
growth was considered in the NOPR
analysis for the air-cooled class. In the
NOPR phase, DOE calculated an MPC
increase of $153 for the evaporator size
increase and a condenser size increase
considered in the same step of the
analysis. Seventeen percent of the
$1,252 contribution to MPC of the initial
evaporator is $213.
DOE acknowledges that the 17%
evaporator growth would require
chassis size increase for the specific
model upon which the IMH–A–Small–
C analysis is based, if implemented by
increasing the length of the auger/
evaporator. As noted previously, DOE
modified the analysis and is no longer
considering evaporator size increases as
a design option for any continuous
units, including IMH–W–Small–C.
In response to the NODA analysis,
Hoshizaki, AHRI, Manitowoc, and
NAFEM stated that increasing the
evaporator by 18% with no chassis
growth is not possible for 22-inch IMH–
A–Small–B machines. (Hoshizaki, No.
124 at p. 2; AHRI, No. 128 at p. 2;
Manitowoc, No. 126 at p. 2; NAFEM,
No. 123 at p. 2) Hoshizaki added that
such a change would require tooling,
panel changes, and kits to fit on the
machine. Hoshizaki and NAFEM noted
that these changes would cost more than
the $34 stated in the NODA. (Hoshizaki,
No. 124 at p. 2; NAFEM, No. 123 at p.
2)
DOE reviewed the cabinet size of the
representative 22-inch IMH–A–Small–B
unit and found that it had space for an
18% evaporator increase. DOE notes
that the final size of the 18% larger
evaporator considered in the analysis is
still smaller than evaporators found in
some 22-inch units of the same
equipment class. Hence, DOE believes
that an 18% growth in evaporator size
is possible and has maintained this
design option in the final rule.
Condenser Costs
Commenting on the NODA analysis
for the IMH–W–Small–B, Hoshizaki and
NAFEM stated that increasing the watercooled condenser length by 48% would
require a larger cost increase than $40
stated in the NODA. (Hoshizaki, No. 124
at p. 2; NAFEM, No. 123 at p. 2)
Hoshizaki noted that they currently are
using the largest condenser offered by
their supplier, and increasing its size
would necessitate a special design.
(Hoshizaki, No. 124 at p. 2)
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In the NODA phase, DOE evaluated a
48% condenser size increase for the
representative IMH–W–Small–B unit of
22-inch width—based on a review of
typical coaxial water-cooled condenser
offerings from typical suppliers of these
units, DOE has concluded that this
might be a non-standard size watercooled condenser. In the final rule
analysis for this unit, DOE has adjusted
its water-cooled condenser options to be
more consistent with standard
condenser sizes, based on review of
commercially available components.
Therefore, for the IMH–W–Small–B, 22
inch wide unit, DOE adjusted the
analysis to instead utilize a 59% larger
condenser. The estimated MPC increase
for this design option in the final rule
analysis is $58.
Regarding the NODA analysis for the
IMH–A–Small–C, Hoshizaki stated that
cost of increasing the evaporator area by
17% and the condenser height by 4
inches would be much higher than the
$150 presented in the NODA. Hoshizaki
added that 22-inch wide machines
could not accommodate 4 inches of
height growth and would require a
change in chassis. Hoshizaki noted that
condensers are standard parts from the
catalogs of suppliers and there are no
condensers that would match this
change. (Hoshizaki, No. 124 at p. 2)
DOE is no longer considering
evaporator growth for continuous units.
The representative unit for this
equipment class has a condenser with
core height of 10 inches, width of 12
inches and a depth of 3 inches. The
chassis height is 217⁄8 inches and the
chassis width is 22 inches. The
representative unit has space for the
condenser size increases considered in
the analysis. Based on discussions with
manufacturers and heat exchanger
suppliers, DOE has found that there is
flexibility in the design of air-cooled
condensers, as long as the design
conforms to the use of standard tube
pitch (distances between the tubes)
patterns, fin style, and fin densities. The
analysis considered no change in these
design parameters that would make the
condenser a non-standard design.
In response to the NODA analysis for
the SCU–W–Large–B class, AHRI
commented on the changes in
condenser size and the associated
efficiency improvement as compared to
the NOPR analysis. AHRI noted that in
the NOPR analysis, DOE considered a
size increase of 39%, which was
estimated to reduce energy us use
11.2%, while in the NODA a condenser
size increase of 112% led to estimated
energy savings of 16.7%. AHRI stated
that such an increase in condenser size
would cause issues with performance
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outside of rating conditions due to the
large increase in refrigerant charge.
AHRI recommended that DOE
reconsider this design option. (AHRI,
No. 128 at p. 3)
In response, DOE modified the
analysis for the SCU–W–Large–B for the
final rule analysis, in which DOE
considers a condenser size increase of
50%, with associated energy savings of
5.5%.
Purchasing Power and Component Costs
Several commenters noted that the
scale of the ice maker industry is too
small to qualify for the price discounts
seen by the appliance markets on
specialized parts. (Hoshizaki, No. 86 at
p. 7–8; Danfoss, Public Meeting
Transcript, No. 70 at p. 175–176)
Danfoss stated that the small scale of the
industry is a barrier to implementing
new technologies and that the
investment necessary to produce highefficiency compressors in these volumes
is not feasible in the foreseeable future.
(Danfoss, No. 72 at p. 3–4)
Scotsman commented that their
vendors provide ECM motors at 200–
300% over the cost of baseline motors
and high-efficiency compressors at up to
30% over the cost of baseline
compressors. Scotsman added that they
have not successfully proven the
performance and reliability of such
components in different applications.
(Scotsman, No. 85 at p. 2)
Joint Commenters urged DOE to
determine whether fan, pump, and
auger motors use ‘‘off-the-shelf’’ or
custom motors if the former, this would
suggest that permanent magnet motor
availability should not be a concern.
(Joint Commenters, No. 87 at p. 2–3)
In response to these comments DOE
notes that it considers the purchasing
power of manufacturers in its estimation
of component cost pricing. DOE has
significantly revised its component cost
estimates for the engineering analysis
for the NODA and ultimately final rule
phase based on additional information
obtained in discussions with
manufacturers as well as in stakeholder
comments. DOE used the detailed
feedback to update its cost estimates for
all ice maker components.
b. Energy Consumption Model
As part of the preliminary analysis,
DOE worked with the developer of the
FREEZE energy consumption model to
adapt the model to updated correlations
for refrigerant heat exchanger
performance correlations and operation
in a Windows computer environment.
Analysis of ice maker performance
during the preliminary analysis was
primarily based on the model. During
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the course of the rulemaking, DOE has
received numerous comments
describing some of the shortcomings of
the model. In response, DOE has
modified its energy use analysis to rely
less on the FREEZE model and more on
direct calculation of energy use and
energy reductions, based on test data
and on assumptions about the efficiency
of components such as motors. DOE
requested that stakeholders provide
information and data to guide the
analysis, and also requested comments
on the component efficiency
assumptions. DOE received additional
information through comments and
confidential information exchange with
DOE’s contractor that helped guide
adjustments to the analysis.
After the NOPR and NODA
publications, stakeholders continued to
express concerns about the FREEZE
model. AHRI questioned the accuracy of
the FREEZE model. (AHRI, No. 93 at
p. 5–6, 16) Scotsman noted that the
FREEZE simulation program may not be
able to model performance of automatic
commercial ice makers upon revision of
the EPA SNAP initiative, which may
result in use of different refrigerants
than are currently used in ice makers.
(Scotsman, No. 125 at p. 2)
Ice-O-Matic commented that the
analysis is based on faulty assumptions
from unrelated rulemakings such as
commercial refrigeration, and that the
cycles of ice machines do not resemble
the cycles of commercial refrigeration
products. (Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 32) Scotsman
and Manitowoc stated that the energy
model may yield unrealistic efficiency
gains for some of the design options.
(Manitowoc, Public Meeting Transcript,
No. 70 at p. 154–156; Scotsman, No. 125
at p. 2). Specifically, Manitowoc noted
that the energy use model significantly
over-predicts the efficiency gains
associated with design options, due to
its inability to account for the harvest
portion of the icemaking cycle.
Manitowoc added that many design
options that reduce freeze-cycle energy
use increase harvest-cycle energy use.
(Manitowoc, No. 92 at p. 1; Manitowoc,
No. 126 at p. 1)
Ice-O-Matic noted that that the
FREEZE model was designed for fullsize ice cubes and does not work for
half-size ice cube machines. (Ice-OMatic, No. 121 at p. 2) Full-size cubes
of the ice maker models primarily
considered in the analysis generally are
cubes with dimensions 7⁄8 x 7⁄8 x 7⁄8
inches. Half-size cubes have dimensions
7⁄8 x 7⁄8 x 3⁄8 inches.
Howe and Hoshizaki both stated that
DOE should test its component design
options in actual units in order to
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validate the FREEZE model. (Howe, No.
88 at p. 2; Hoshizaki, No. 86 at p. 6)
AHRI also expressed its concern that
DOE has not conducted thorough testing
to validate the efficiency gains
associated with design options and
requested that DOE prove the claims
made in the engineering analysis.
(AHRI, Public Meeting Transcript, No.
70 at p. 20–21)
DOE used the FREEZE energy model
as a basis to estimate energy savings
potential associated with design options
in the early stages of the analysis when
DOE had limited information. As more
information was made available to DOE
through public comments as well as
non-disclosure agreements with
manufacturers, DOE modified or
replaced the results garnered from the
FREEZE energy model to better reflect
the new data collected.
In response to Scotsman’s comment
regarding the FREEZE model’s ability to
model the performance of automatic
commercial ice makers which use
alternative refrigerants, DOE notes that,
as described in section IV.A.4, it has not
conducted analysis on the use of
alternative refrigerants in this rule.
In response to comments regarding
the FREEZE model’s ability to model the
harvest cycle, DOE notes that while the
FREEZE model does not simulate the
harvest period analytically, the harvest
energy is an input for the program that
DOE adjusted consistent with test data.
In short, the model’s ability to
accurately calculate the energy use
associated with harvest is limited only
by the availability of data showing the
trends of harvest cycle energy use as
different design options are considered.
DOE requested information regarding
this aspect of ice maker performance,
received some information through
comments and information exchange
with manufacturers, and modified the
energy use calculations accordingly.
DOE notes that the harvest cycle
energy use issue associated with the
calculation of energy use for batch ice
makers does not apply to continuous ice
makers, which do not have a harvest
cycle. DOE concludes that the inability
to measure harvest cycle energy use
cannot be a reason to question the
energy use calculations made for
continuous ice makers. DOE notes that
stakeholders have not identified similar
aspects of continuous ice maker
operation that could potentially be cited
as reasons for inaccuracies in the energy
use calculations associated with these
ice makers.
In response to Ice-O-matic’s comment
regarding the FREEZE model’s ability to
model half cube ice machines, DOE
notes that the FREEZE model is capable
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of modeling such units. However, as
indicated in section IV.D.1 DOE has
chosen to base the analysis on full-cube
ice machines which, as explained in
section IV.D.1, may have an efficiency
disadvantage as compared to half- dice
machines. Hence, focus on full-cube ice
makers makes the analysis more
conservative.
Expected Savings for Specific Design
Options
Several commenters questioned the
energy model’s assumptions regarding
the relationship between compressor
EER improvement and ice maker
efficiency improvement. AHRI stated
that the assumed relationship should be
verified with laboratory tests. (AHRI,
No. 93 at p. 15)
Manitowoc and Hoshizaki each stated
that they tested a compressor with 12%
higher EER compared to baseline and
that it yielded a 3% efficiency
improvement. (Manitowoc, Public
Meeting Transcript, No. 70 at p. 138–
142; Hoshizaki, Public Meeting
Transcript, No. 70 at p. 152) Ice-O-Matic
commented that they tested a
compressor with 10% higher EER and
that it yielded only a 2% improvement
in efficiency. Ice-O-Matic noted that this
is due to the unique circumstances of
the harvest cycle, which removes a lot
of the improvements that are typically
seen with compressor efficiency gains in
other refrigeration equipment. (Ice-OMatic, Public Meeting Transcript, No.
70 at p. 148–149) Follett noted that they
observed a 9% efficiency gain with a
compressor that was 5% more efficient
and an ECM fan in an IMH–A–Large–C
ice maker. Follett indicated that these
design options would increase cost $60,
a cost for which the DOE NOPR analysis
predicted 20% improvement. (Follet,
No. 84 at p. 8)
AHRI stated that the FREEZE energy
model results during the June 19th
public meeting did not support the
findings DOE published in the NOPR
when swapping an upgraded
compressor. Rather the model
simulation predicted that the unit with
the upgraded compressor would
produce more ice and consume more
energy. AHRI stated that they submitted
actual test data for this unit which
showed modest efficiency savings for
upgrading the compressor. AHRI noted
that this finding is contradictory to the
significant energy savings DOE claimed
would be possible in the NOPR. (AHRI,
No. 128 at p. 6–7) DOE responds that
accurate modeling with any analysis
requires careful validation of the input
data and that no conclusions can be
drawn regarding the results that
emerged during the meeting because
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there was no time to ensure consistency
of the input and to review the output to
understand whether there was a valid
reason for any unexpected results. One
could argue, contrary to the AHRI
position, that the results showed that
the FREEZE model predicts higher
energy use than would actually be
consumed—DOE realizes that such a
conclusion would be meaningless. The
only real conclusion is that the program
is not easy to operate and requires
careful review of both input and output
in order to ensure that results are
meaningful.
To address the stakeholder concerns
that the FREEZE model cannot
adequately model the effects of
increased compressor efficiency on
ACIM energy consumption, DOE
modified the outputs of the energy
model based on data received in the
comments as well as from
manufacturers under non-disclosure
agreements. DOE also performed testing
on several ice-making units and used
the test data to further inform the
relationship between increased
compressor efficiency and ACIM
efficiency.
Operating Conditions
NAFEM, Emerson, Manitowoc,
Scotsman commented that DOE’s
engineering analysis is flawed because it
only examines compressor ratings at
AHRI conditions, rather than over the
wide range of operating conditions
experienced by ACIMs in the field.
(NAFEM, No. 82 at p. 10, Emerson,
Public Meeting Transcript, No. 70 at
p. 144; Manitowoc, Public Meeting
Transcript, No. 70 at p. 144–146;
Scotsman, No. 85 at p. 2) Emerson noted
that the AHRI rating point for
compressors is not typically where an
ice machine operates which may
contribute to the issues with DOE’s
modeling. (Emerson, Public Meeting
Transcript, No. 70 at p. 144) Manitowoc
stated that they typically use a 10–105
condition for compressors, whereas the
cost curves used a 15/95 condition,29
which does not match operating
conditions that occur in ice machines.
Manitowoc also noted that the
29 Compressor performance depends on suction
(inlet) and discharge (outlet) pressures. These
pressures are often represented as the saturated
refrigerant temperatures that correspond to the
pressures. For the 15/95 conditions, the saturated
evaporator temperature is 15 °F and the saturated
condensing temperature is 95 °F (to be technically
correct, these are represented as dew point
temperatures for the refrigerant in question, R–
404A—because there is a range of temperatures at
a given pressure over which the refrigerant can
coexist in equilibrium in both liquid and vapor
phases, the temperature at the high end of this
range often used).
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compressor maps cannot model what
happens during the harvest event or the
pre-chill time and that the coefficient
models do not include these operating
regions. (Manitowoc, Public Meeting
Transcript, No. 70 at p. 144–146)
Danfloss also stated that compressor
maps are not useful in developing
assumptions about ice maker
compressor performance. (Danfoss,
Public Meeting Transcript, No. 70 at
p. 152–153)
AHRI noted that DOE did not take
operation changes into account, such as
different batch times or energy use,
when upgrading to a more efficient
compressor. (AHRI, No. 128 at p. 2)
In response to the comment that
compressors operate under a wide range
of conditions in the field, DOE
requested information that could be
used to guide the analysis with respect
in regards to what compressors are not
suitable for use in ice makers, and/or
what other guidelines could be used to
avoid consideration of ice maker
designs that are not viable in the field.
DOE did not receive from stakeholders
specific guidelines that could be used to
limit the degree to which a design
option might be applied for a given ice
maker model in its analysis. In response
to Emerson’s comment about
compressor rating conditions not being
the typical operating conditions during
ice maker testing, DOE notes that the
calculation of compressor performance
during the test was done at more typical
compressor operating conditions during
ice maker testing, based on the full set
of performance data for the
compressor—not at the compressor
rating conditions. In response to the
comment regarding the 15/95 conditions
associated with the cost curves, the
performance calculations for the
compressors had nothing to do with the
15/95 conditions—the 15/95 conditions
were simply an intermediate step in
assigning a representative cost for a
given compressor. This assignment of
cost involved converting the rated AHRI
20/120 capacity for the compressor into
a 15/95 condition by multiplying the
capacity by 1.29. DOE then used this
result as described in Chapter 5 of the
TSD to determine an initial nominal
cost using the relationship described in
the TSD. DOE further increased the cost
based on feedback obtained about
compressor costs from manufacturers
throughout the rulemaking.
DOE received data showing the trends
in ice maker energy use reduction with
improved compressor EER, including
data received as part of the AHRI NOPR
comment, as well as additional data
received by DOE’s contractor under
non-disclosure agreement. The data
showed that for batch ice makers, the
ice maker energy use reduction is a
fraction of the expected energy use
reduction when considering just the
compressor EER improvement. DOE
applied this reduction in efficiency
improvement to its NODA and final rule
analyses.
Analysis Calibration
DOE calibrated the engineering
analysis by comparing the energy use
predictions associated with given sets of
design options with energy usage and
design data collected from existing ice
maker models. DOE revisited these
calibrations in the final rule phase. In
general, DOE’s analysis for a given ice
maker class is based on an existing ice
maker model with an efficiency level at
or near baseline. Hence, the analysis is
calibrated to this particular ice maker
model at its efficiency level, which is
based on either its rating or a
combination of its rating and the results
of DOE testing. The analysis considers
the energy use impact of adding design
options to improve efficiency. In order
to represent the baseline, the analysis
may consider removing a design option
(or more than one if necessary) to allow
representation of a design that is at the
baseline efficiency level.
DOE also calibrated its analysis using
units at maximum available efficiency
levels (or in some cases, efficiency
levels less than the maximum available),
specifically equipment without
proprietary technologies, such as lowthermal-mass or tube-type evaporators
for batch ice makers. DOE chose design
options to reach the maximum available
4693
efficiency levels of existing equipment.
Importantly design options involving
electronically commutate motors and
drain water heat exchangers were
excluded from calibration, as these were
not considered to be commonly used in
current ice makers. In some cases, the
set of design options chosen to represent
the maximum efficiency level matched
the designs of the maximum available
efficiency level equipment. In other
cases, the designs did not match exactly,
and the design of the DOE analysis may
have had more improvement in one
component, while the maximum
available ice maker had more
improvement in another component. In
order to ensure that DOE was not
underestimating the costs associated
with the overall design improvements,
DOE estimated the cost differential
between changing the major
components of the analyzed max
efficiency unit to match those of the
maximum available equipment. Major
components considered in this estimate
were the compressor, evaporator,
condenser, and condenser fan. Table
IV.25 shows this calibration, listing: The
maximum efficiency reached by each
directly analyzed equipment class,
without considering ECM or drain water
heat exchanger (DWHX) design options;
the efficiency of the maximum available
unit; and the cost difference associated
with modifying the major components
of to match those in the maximum
available. A negative cost differential
indicates that the DOE analysis
predicted a higher cost at that efficiency
level compared with the maximum
available unit. The computed cost
differentials are zero or negative in all
but one case, showing that the DOE
analysis does not underestimate the cost
of reaching these higher efficiency
levels. For the one case in which the
differential is positive, $4 for the IMH–
A–Small–B 22-Inch ice maker, the
maximum available efficiency level is
5% higher than the level predicted by
DOE’s energy use analysis for a
comparable set of design options. The
calibration is presented in more detail
in Chapter 5 of the TSD.
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TABLE IV.25—MAXIMUM AVAILABLE CALIBRATION
Representative
capacity
(lb ice/24
hours)
Equipment class
DOE Analysis
maximum
efficiency level
(% below
baseline)
Maximum
available
efficiency level
(% below
baseline)
300
300
300
300
19.2
16.9
19.3
11.6
19.2
16.9
19.3
16.6
IMH–W–Small–B ..............................................................................................
IMH–W–Small–B (22-inch wide) ......................................................................
IMH–A–Small–B ...............................................................................................
IMH–A–Small–B (22-inch wide) .......................................................................
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Cost
differential
moving from
analyzed to
maximum
available
($)
¥29
¥34
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+4
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TABLE IV.25—MAXIMUM AVAILABLE CALIBRATION—Continued
Representative
capacity
(lb ice/24
hours)
Equipment class
DOE Analysis
maximum
efficiency level
(% below
baseline)
Maximum
available
efficiency level
(% below
baseline)
800
590
1500
850
2600
1500
2400
110
200
300
310
820
220
610
16.1
5.5
6.2
10.4
2.5
15.7
14.9
26.6
23.5
27.6
19.8
17.0
21.8
17.9
16.1
5.5
6.0
14.3
2.5
15.7
14.9
24.9
26.4
27.6
28.0
35.7
30.1
18.4
IMH–A–Large–B–Medium ................................................................................
IMH–A–Large–B (22-inch wide) .......................................................................
IMH–A–Large–B–Large ...................................................................................
IMH–W–Med–B ................................................................................................
IMH–W–Large–B–2 .........................................................................................
RCU–NRC–Large–B–Med ...............................................................................
RCU–NRC–Large–B–Large .............................................................................
SCU–A–Small–B ..............................................................................................
SCU–A–Large–B .............................................................................................
SCU–W–Large–B ............................................................................................
IMH–A–Small–C ..............................................................................................
IMH–A–Large–C ..............................................................................................
SCU–A–Small–C .............................................................................................
RCU–NRC–Small–C ........................................................................................
c. Revision of NOPR and NODA
Engineering Analysis
DOE developed the final engineering
analysis by updating the NOPR and
NODA analyses. This included making
adjustments to the manufacturing cost
model as described in section IV.D.4.a.
It also included adjustments to energy
modeling as described in section IV.D.4.
DOE made several changes to the
engineering analysis throughout the
course of this rulemaking. Specifically,
in response to the concerns raised by
stakeholders, DOE adjusted its analysis
to rely more on test data based on input
received in manufacturers’ public and
confidential comments than on
theoretically analysis. These changes
included:
• Based on new data, DOE made
changes to the energy use reductions
associated with individual design
options;
• Based on new cost data, DOE made
changes to the costs associated with
individual design options. Design
options were changed as a result of new
data obtained through non-disclosure
agreements with DOE’s engineering
contractor and comments made during
Cost
differential
moving from
analyzed to
maximum
available
($)
the NOPR comment period developing
an approach based on test data to
determine the condensing temperature
reductions associated with use of larger
water-cooled condensers;
• Based on comments made during
the NOPR period, DOE added additional
cost-efficiency curves for 22-inch width
units in the IMH–A–Small–B, IMH–A–
Large–B, and IMH–W–Small–B
equipment classes, and an additional
cost-efficiency curve for the RCU–
Small–C equipment class.
DOE calibrated the results of its
calculations with maximum available
ice makers that are available in the
market and which do not incorporate
proprietary technologies. This
calibration at the maximum available
levels shows that the costs DOE
assigned to the maximum available level
is generally higher than suggested by the
compared maximum available
equipment.
DOE believes that these changes help
ensure that analysis accurately reflect
technology behavior in the market.
Further details on the analyses are
available in chapter 5 of the final rule
TSD.
¥74
¥13
¥130
¥240
0
¥62
¥329
¥61
¥28
0
¥30
¥11
¥62
¥40
E. Markups Analysis
DOE applies multipliers called
‘‘markups’’ to the manufacturer selling
price (MSP) to calculate the customer
purchase price of the analyzed
equipment. These markups are in
addition to the manufacturer markup
(discussed in section IV.J.2.b) and are
intended to reflect the cost and profit
margins associated with the distribution
and sales of the equipment between the
manufacturer and customer. DOE
identified three major distribution
channels for automatic commercial ice
makers, and markup values were
calculated for each distribution channel
based on industry financial data. Table
IV.26 shows the three distribution
channels and the percentage of the
shipments each is assumed to reflect.
The overall markup values were then
calculated by weighted-averaging the
individual markups with market share
values of the distribution channels. See
chapter 6 of the TSD for more details on
DOE’s methodology for markups
analysis.
TABLE IV.26—DISTRIBUTION CHANNEL MARKET SHARES
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National account channel:
Manufacturer direct to customer (1-party)
Wholesaler channel:
Manufacturer to distributor
to customer (2-party)
Contractor channel:
Contractor purchase from
distributor for installation
(3-party)
0%
38%
62%
levels, manufacturer rebates to
distributors based on sales volume,
newer versions of the same equipment
model introduced into the market by the
manufacturers, and availability of
cheaper or more technologically
advanced alternatives. Based on market
data, DOE divided distributor costs into
In general, DOE has found that
markup values vary over a wide range
based on general economic outlook,
manufacturer brand value, inventory
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
(1) direct cost of equipment sales; (2)
labor expenses; (3) occupancy expenses;
(4) other operating expenses (such as
depreciation, advertising, and
insurance); and (5) profit. DOE assumed
that, for higher efficiency equipment
only, the ‘‘other operating costs’’ and
‘‘profit’’ scale with MSP, while the
remaining costs stay constant
irrespective of equipment efficiency
level. Thus, DOE applied a baseline
markup through which all estimated
distribution costs are collected as part of
the total baseline equipment cost, and
the baseline markups were applied as
multipliers only to the baseline MSP.
Incremental markups were applied as
multipliers only to the MSP increments
(of higher efficiency equipment
compared to baseline) and not to the
entire MSP. Taken together the two
markups are consistent with economic
behavior in a competitive market—the
participants are only able to recover
costs and a reasonable profit level.
DOE received a number of comments
regarding markups after the publication
of the NOPR.
In written comments, Manitowoc,
Hoshizaki, NAFEM, Follett and AHRI
commented that baseline and
incremental markups should be equal,
set at the level of the baseline markups.
(Manitowoc, No. 92 at p. 2; Hoshizaki,
No. 86 at p. 3; NAFEM, No. 82 at p. 5;
Follett, No. 84 at p. 6; and AHRI, No. 93
at p. 6–7)
Some stakeholders at the NOPR
public meeting commented that DOE
should not use incremental markups for
incremental equipment costs arising
from the imposition of new standards
and that DOE should instead use one set
of markups, that corresponds to the
baseline markups. Danfoss commented
that wholesalers did not ask which part
of prices were baseline and which were
incremental. (Danfoss, Public Meeting
Transcript, No. 70 at p. 197–198)
Manitowoc stated that if they change list
prices, their channel partners simply
add a markup, and Manitowoc was not
sure they would adopt another approach
because a regulatory change drove up
costs. (Manitowoc, Public Meeting
Transcript, No. 70 at p. 192–193)
Danfoss suggested DOE go back and
review the results of earlier rulemakings
and identify how markups worked in
those equipment markets. Doing so
could add some credibility to the DOE
markups methodology, maybe not in
time for the ACIM rulemaking but in
time for later rulemakings. (Danfoss,
Public Meeting Transcript, No. 70 at p.
195) AHRI agreed that DOE should go
back and try to verify the numbers at
some point, maybe not for this
rulemaking but for the next one. (AHRI,
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Public Meeting Transcript, No. 70 at p.
199–200) NAFEM and Manitowoc also
suggested validation studies. (NAFEM,
Public Meeting Transcript, No. 70 at p.
198; Manitowoc, Public Meeting
Transcript, No. 70 at p. 190)
ASAP stated that DOE implemented
markups where every dollar spent got
the same markup in rulemakings before
the year 2000. ASAP argued that the real
world does not work that way because
businesses cover fixed costs in a certain
fashion, and variable costs in a certain
fashion. ASAP has done some work
examining the question of how good
DOE’s methods are at predicting prices.
ASAP found that DOE’s predicted prices
tend to be higher than they should be,
based on retrospective analysis. ASAP
welcomes more retrospective analysis
but notes that such analysis won’t help
this docket. (ASAP, Public Meeting
Transcript, No. 70 at p. 195–197)
Scotsman provided suggestions for
price estimation services, and
commented that the cumulative impact
on the supply chain of training, store
design modifications, maintenance,
costs associated with passing along
manufacturer adjusted pricing, and
retrofit of existing locations would add
significantly to the costs of the
standards. (Scotsman, No. 95 at page 5)
DOE acknowledges that a detailed
review of results following compliance
with prior rulemakings could provide
information on wholesaler and
contractor pricing practices, and agrees
that such results would not be timely for
this rulemaking. In the absence of such
information, DOE has concluded that its
approach, which is consistent with
expected business behavior in
competitive markets, is reasonable to
apply. If the cost of goods sold increases
due to efficiency standards, DOE
continues to assume that markups
would decline slightly, leaving profit
unchanged, and, thus, it uses lower
markups on the incremental costs of
higher-efficiency products. This
approach is consistent with behavior in
competitive markets wherein market
participants are expected to be able to
recover costs and reasonable levels of
profit. If the markup remains constant
while the cost of goods sold increases,
as Manitowoc, Hoshizaki, NAFEM,
Follett, and AHRI suggest, the
wholesalers’ profits would also increase.
While this might happen in the short
run, DOE believes that the wholesale
market is sufficiently competitive that
there would be pressure on margins.
DOE recognizes that attempting to
capture the market response to changing
cost conditions is difficult. However,
DOE’s approach is consistent with the
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mainstream understanding of firm
behavior in a competitive market.
With respect to Manitowoc and
Danfoss comments related to differential
pricing based on efficiency
improvements, DOE’s approach for
wholesaler markups does not imply that
wholesalers differentiate markups based
on the technologies inherently present
in the equipment. Rather, it assumes
that the average markup declines as the
wholesalers’ cost of goods sold increases
due to the higher cost of more-efficient
equipment for the reasons explained in
the previous paragraph.
With respect to Scotsman’s
comments, DOE reviewed the suggested
price quote services and, while
appreciative of the information, found
them to not provide the type of
information needed for estimating
markups on a national or state average
basis. As for the costs mentioned, DOE
believes costs such as passing along the
manufacturer pricing and personnel
training are already embodied in
markups as such costs would be
included in the data used to estimate
markups and no evidence has been
entered into the record to demonstrate
that the costs caused by the proposed
standards would be extraordinary. Other
costs such as building renovation and
retrofit costs were included in
installation costs, as appropriate.
F. Energy Use Analysis
DOE estimated energy usage for use in
the LCC and NIA models based on the
kWh/100 lb ice and gal/100 lb ice values
developed in the engineering analysis in
combination with other assumptions.
For the NOPR, DOE assumed that ice
makers on average are used to produce
one-half of the ice the machines could
produce (i.e., a 50 percent capacity
factor). DOE also assumed that when not
making ice, on average ice makers
would draw 5 watts of power. DOE
modeled condenser water usage as
‘‘open-loop’’ installations, or
installations where water is used in the
condenser one time (single pass) and
released into the wastewater system.
Hoshizaki asked about the basis for
the 50 percent usage factor. (Hoshizaki,
Public Meeting Transcript, No. 70 at p.
204) NEEA referred to the usage factor
as a best estimate, and noted that the 50
percent factor had not been improved
upon in response to earlier rulemaking
stages. (NEEA, Public Meeting
Transcript, No. 70 at p. 204–205)
With its written comments, AHRI
supplied monitored results collected by
two manufacturers and recommended
that DOE revise the utilization factor to
38%, based on the average of the data
collected from stores, cafeterias, and
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restaurants in a variety of states. (AHRI,
No. 93 at p. 2–3) Follett commented that
its data shows that ice makers run an
average of 38% of the time and that DOE
should modify its analysis accordingly.
(Follett, No. 84 at p. 3) Manitowoc
commented that a more accurate average
duty cycle for ACIMs is 40% based on
data it had collected. (Manitowoc, No.
92 at p. 3)
NEEA recommended that DOE adjust
the energy use on a weighted sales
average to reflect a higher duty cycle for
ice makers that are replacements as
compared to new units, where ice
demand may not be accurately known.
(NEEA, No. 91 at p. 2)
Based on the monitored results
submitted by AHRI and similar
monitored results found in a report
posted online,30 DOE utilized a 42
percent capacity factor to estimate
energy usage for the LCC and NIA
models. With respect to NEEA’s
comment, given that DOE has no
information on new versus replacement
units and that the sample of monitored
results does not include all relevant
business types, DOE used the factor
based on monitored results for new and
replacement shipments for all business
types.
G. Life-Cycle Cost and Payback Period
Analysis
In response to the requirements of
EPCA in (42 U.S.C. 6295(o)(2)(B)(i) and
6313(d)(4)), DOE conducts a LCC and
PBP analysis to evaluate the economic
impacts of potential amended energy
conservation standards on individual
commercial customers—that is, buyers
of the equipment. This section describes
the analyses and the spreadsheet model
DOE used. TSD chapter 8 details the
model and all the inputs to the LCC and
PBP analyses.
LCC is defined as the total customer
cost over the lifetime of the equipment,
and consists of installed cost (purchase
and installation costs) and operating
costs (maintenance, repair, water,31 and
energy costs). DOE discounts future
operating costs to the time of purchase
and sums them over the expected
lifetime of the unit of equipment. PBP
is defined as the estimated amount of
time it takes customers to recover the
higher installed costs of more-efficient
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30 Karas,
A. and D. Fisher. A Field Study to
Characterize Water and Energy Use of Commercial
Ice-Cube Machines and Quantify Saving Potential.
December 2007. Fisher-Nickel, Inc. San Ramon, CA.
31 Water costs are the total of water and
wastewater costs. Wastewater utilities tend to not
meter customer wastewater flows, and base billings
on water commodity billings. For this reason, water
usage is used as the basis for both water and
wastewater costs, and the two are aggregated in the
LCC and PBP analysis.
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equipment through savings in operating
costs. DOE calculates the PBP by
dividing the increase in installed costs
by the savings in annual operating costs.
DOE measures the changes in LCC and
in PBP associated with a given energy
and water use standard level relative to
a base-case forecast of equipment energy
and water use (or the ‘‘baseline energy
and water use’’). The base-case forecast
reflects the market in the absence of
new or amended energy conservation
standards.
The installed cost of equipment to a
customer is the sum of the equipment
purchase price and installation costs.
The purchase price includes MPC, to
which a manufacturer markup (which is
assumed to include at least a first level
of outbound freight cost) is applied to
obtain the MSP. This value is calculated
as part of the engineering analysis
(chapter 5 of the TSD). DOE then
applies additional markups to the
equipment to account for the costs
associated with the distribution
channels for the particular type of
equipment (chapter 6 of the TSD).
Installation costs are varied by state
depending on the prevailing labor rates.
Operating costs for automatic
commercial ice makers are the sum of
maintenance costs, repair costs, water,
and energy costs. These costs are
incurred over the life of the equipment
and therefore are discounted to the base
year (2018, which is the proposed
effective date of the amended standards
that will be established as part of this
rulemaking). The sum of the installed
cost and the operating cost, discounted
to reflect the present value, is termed
the life-cycle cost or LCC.
Generally, customers incur higher
installed costs when they purchase
higher-efficiency equipment, and these
cost increments will be partially or
wholly offset by savings in the operating
costs over the lifetime of the equipment.
Usually, the savings in operating costs
are due to savings in energy costs
because higher-efficiency equipment
uses less energy over the lifetime of the
equipment. Often, the LCC of higherefficiency equipment is lower compared
to lower-efficiency equipment.
The PBP of higher-efficiency
equipment is obtained by dividing the
increase in the installed cost by the
decrease in annual operating cost. For
this calculation, DOE uses the first-year
operating cost decreases as the estimate
of the decrease in operating cost, noting
that some of the repair and maintenance
costs used in the analysis are
annualized estimates of costs. DOE
calculates a PBP for each efficiency
level of each equipment class. In
addition to the energy costs (calculated
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using the electricity price forecast for
the first year), the first-year operating
costs also include annualized
maintenance and repair costs.
Apart from MSP, installation costs,
and maintenance and repair costs, other
important inputs for the LCC analysis
are markups and sales tax, equipment
energy consumption, electricity prices
and future price trends, expected
equipment lifetime, and discount rates.
As part of the engineering analysis,
design option levels were ordered based
on increasing efficiency (decreased
energy and water consumption) and
increasing MSP values. DOE developed
two to seven energy use levels for each
equipment class, henceforth referred to
as ‘‘efficiency levels,’’ through the
analysis of engineering design options.
For all equipment classes, efficiency
levels were set at specific intervals—
e.g., 10 percent improvement over base
energy usage, 15 percent improvement,
20 percent improvement. The max-tech
efficiency level is the only exception. At
the max-tech level, the efficiency
improvement matched the specific
levels identified in the engineering
analysis.
The base efficiency level (level 1) in
each equipment class is the least
efficient and the least expensive
equipment in that class. The higher
efficiency levels (level 2 and higher)
exhibit progressive increases in
efficiency and cost with the highest
efficiency level corresponding to the
max-tech level. LCC savings and PBP
are calculated for each selected
efficiency level of each equipment class.
Many inputs for the LCC analysis are
estimated from the best available data in
the market, and in some cases the inputs
are generally accepted values within the
industry. In general, each input value
has a range of values associated with it.
While single representative values for
each input may yield an output that is
the most probable value for that output,
such an analysis does not give the
general range of values that can be
attributed to a particular output value.
Therefore, DOE carried out the LCC
analysis in the form of Monte Carlo
simulations 32 in which certain inputs
were expressed as a range of values and
probability distributions that account
32 Monte Carlo simulation is, generally, a
computerized mathematical technique that allows
for computation of the outputs from a mathematical
model based on multiple simulations using
different input values. The input values are varied
based on the uncertainties inherent to those inputs.
The combination of the input values of different
inputs is carried out in a random fashion to
simulate the different probable input combinations.
The outputs of the Monte Carlo simulations reflect
the various probable outputs that are possible due
to the uncertainties in the inputs.
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for the ranges of values that may be
typically associated with the respective
input values. The results or outputs of
the LCC analysis are presented in the
form of mean LCC savings, percentages
of customers experiencing net savings,
net cost and no impact in LCC, and
median PBP. For each equipment class,
10,000 Monte Carlo simulations were
carried out. The simulations were
conducted using Microsoft Excel and
Crystal Ball, a commercially available
Excel add-in used to carry out Monte
Carlo simulations.
LCC savings and PBP are calculated
by comparing the installed costs and
LCC values of standards-case scenarios
against those of base-case scenarios. The
base-case scenario is the scenario in
which equipment is assumed to be
purchased by customers in the absence
of the proposed energy conservation
standards. Standards-case scenarios are
scenarios in which equipment is
assumed to be purchased by customers
after the amended energy conservation
standards, determined as part of the
current rulemaking, go into effect. The
number of standards-case scenarios for
an equipment class is equal to one less
than the total number of efficiency
levels in that equipment class because
each efficiency level above efficiency
level 1 represents a potential amended
standard. Usually, the equipment
available in the market will have a
distribution of efficiencies. Therefore,
for both base-case and standards-case
scenarios, in the LCC analysis, DOE
assumed a distribution of efficiencies in
the market, and the distribution was
assumed to be spread across all
efficiency levels in the LCC analysis (see
TSD chapter 10).
Recognizing that different types of
businesses and industries that use
automatic commercial ice makers face
different energy prices and apply
different discount rates to purchase
decisions, DOE analyzed variability and
uncertainty in the LCC and PBP results
by performing the LCC and PBP
calculations for seven types of
businesses: (1) Health care; (2) lodging;
(3) foodservice; (4) retail; (5) education;
(6) food sales; and (7) offices. Different
types of businesses face different energy
prices and also exhibit differing
discount rates that they apply to
purchase decisions.
Expected equipment lifetime is
another input for which it is
inappropriate to use a single value for
each equipment class. Therefore, DOE
assumed a distribution of equipment
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lifetimes that are defined by Weibull
survival functions.33
Equipment lifetime is a key input for
the LCC and PBP analysis. For
automatic commercial ice maker
equipment, there is a general consensus
among industry stakeholders that the
typical equipment lifetime is
approximately 7 to 10 years with an
average of 8.5 years. There was no data
or comment to suggest that lifetimes are
unique to each equipment class.
Therefore, DOE assumed a distribution
of equipment lifetimes that is defined by
Weibull survival functions, with an
average value of 8.5 years.
Using monitored data on the
percentage of potential ice-making
capacity that is actually used in real
world installations (referred herein as
utilization factor, but also referred to as
duty cycle), the electricity and water
usage of ice makers were also varied in
the LCC analysis.
Another factor influencing the LCC
analysis is the physical location in
which the automatic commercial ice
maker is installed. Location is captured
by using state-level inputs, including
installation costs, water and energy
prices, and sales tax (plus the associated
distribution chain markups). At the
national level, the spreadsheets
explicitly modeled variability in the
model inputs for water price, electricity
price, and markups using probability
distributions based on the relative
populations in all states.
Detailed descriptions of the
methodology used for the LCC analysis,
along with a discussion of inputs and
results, are presented in chapter 8 and
appendices 8A and 8B of the TSD.
1. Equipment Cost
To calculate customer equipment
costs, DOE multiplied the MSPs
developed in the engineering analysis
by the distribution channel markups,
described in section IV.E. DOE applied
baseline markups to baseline MSPs and
incremental markups to the MSP
increments associated with higher
efficiency levels.
In the NOPR analysis, DOE developed
a projection of price trends for
automatic commercial ice maker
equipment, indicating that based on
historical price trends the MSP would
be projected to decline by 0.4 percent
from the 2012 estimation of MSP values
through the 2018 assumed start date of
new or amended standards. The NOPR
analysis also indicated an
33 A Weibull survival function is a continuous
probability distribution function that is commonly
used to approximate the distribution of equipment
lifetimes.
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4697
approximately 1.7 percent decline from
the MSP values estimated in 2012 to the
end of the 30-year NIA analysis period
used in the NOPR.
AHRI questioned where the price
trend data came from and asked how
confident DOE was of the numbers.
(AHRI, Public Meeting Transcript, No.
70 at p. 216) In written comments, AHRI
expressed concern with the experiential
learning analysis and use of a producer
price index and urged DOE to assume
the MSP remain constant. (AHRI, No. 93
at p. 16–17)
PG&E and SDG&E expressed their
support of DOE’s use of experiential
price learning in life-cycle cost analysis.
(PG&E and SDG&E, No. 89 at p. 4)
DOE acknowledges the PG&E and
SDG&G comment. In response to the
AHRI comments that the data do not
support the price trends, DOE agrees
that it would be better to have data very
specific to automatic commercial ice
maker price trends. However, such is
not available. The PPI used in the
analysis of price trends embodies the
price trends of automatic commercial
ice makers as well as related
technologies, including those used as
inputs to the manufacturing process.
DOE would also note that a sensitivity
analysis was performed with price
trends held constant, and doing such
would not have impacted the selection
of efficiency levels for TSLs. (See
appendix 10B of the final rule TSD.)
Because DOE believes there is evidence
that price learning exists, DOE
continued to use price learning for the
final rule.
As is customary between phases of a
rulemaking, DOE re-examined the data
available and updated the price trend
analysis. DOE continued to use a subset
of the air-conditioning, refrigeration,
and forced air heating equipment
Producer Price Index (PPI) that includes
only commercial refrigeration and
related equipment, and excludes
unrelated equipment. Using this PPI for
the automatic commercial ice maker
price trends analysis yields a price
decline of roughly 2.4 percent over the
period of 2013 (the year for which MSP
was estimated) through 2047. For the
LCC model, between 2013 and 2018, the
price decline is 0.5 percent.
2. Installation, Maintenance, and Repair
Costs
a. Installation Costs
Installation cost includes labor,
overhead, and any miscellaneous
materials and parts needed to install the
equipment. Most automatic commercial
ice makers are installed in fairly
standard configurations. For the NOPR,
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DOE assumed that the installation costs
vary from one equipment class to
another, but not by efficiency level
within an equipment class. For the
NOPR, DOE tentatively concluded that
the engineering design options did not
impact the installation cost within an
equipment class. DOE therefore
assumed that the installation cost for
automatic commercial ice makers did
not vary among efficiency levels within
an equipment class. Costs that do not
vary with efficiency levels do not
impact the LCC, PBP, or NIA results.
During the public meeting
manufacturers commented that not all
customers can accommodate increased
unit sizes, and that DOE must consider
additional costs incurred from
modifying facilities to accommodate ice
makers with potential changes
including plumbing and/or electrical
work, relocating existing equipment,
and/or building renovations. (Scotsman,
Public Meeting Transcript, No. 70 at p.
126–127; Manitowoc, Public Meeting
Transcript, No. 70 at p. 133 and p. 209;
Ice-O-Matic, Public Meeting Transcript,
No. 70 at p. 208 and p. 210)
In written comments, AHRI stated it
was incorrect to assume installation cost
would not increase with the efficiency
improvement. (AHRI, No. 93 at p. 4)
AHRI and Follett stated that larger ice
makers will require installation space
modification and would result in higher
installation costs. (AHRI, No. 93 at p. 7–
8; Follett, No. 84 at p. 6) Hoshizaki
stated that the current installation cost
range considerations may be correct for
ice makers without size increases but
agreed with AHRI and Follett that the
installation cost would increase if the
cabinet size went up, and that drain
water heat exchangers would further
increase installation costs. (Hoshizaki,
No. 86 at p. 3–4) Manitowoc provided
written comments, adding that remote
condenser and remote condenser with
compressor units that have larger
condenser coils will require larger roof
curbs or stronger mounting, depending
on whether footprint or height is
affected. (Manitowoc, No. 92 at p. 3)
Scotsman stated in response to the
NOPR and to the NODA that customers
with space constraints could incur costs
including but not limited to building
renovation, water and wastewater
service relocation, and electric service
and countertop renovations. (Scotsman,
No. 85 at p. 5b–6b; No. 125 at p. 2)
Scotsman also stated that any efficiency
improvement greater than 5 percent
would cause cabinet size increases.
(Scotsman, No. 125 at p. 2) Policy
Analyst stated that DOE should assess
whether commercial ice maker
installation costs are affected by its
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proposed standards. (Policy Analyst,
No. 75, p. 10)
Joint Commenters commented that
DOE appropriately considered design
options that increased package sizes,
noting the options consumers have for
purchases and noting the opportunity
consumers might have to select smaller
units given the low utilization factors
used in the analysis. (Joint Commenters,
No. 87, p. 3) NEEA similarly stated that
DOE appropriately considered all the
factors related to chassis size increase
(NEEA, No. 91, pp. 1–2) PG&E and
SDG&E, and CA IOU noted that it is
unclear that insufficient space exists to
increase chassis sizes in all situations.
(PG&E and SDG&E, No. 89, p. 3, and CA
IOU, No. 129, p. 4)
As suggested by Policy Analyst and
manufacturers, DOE investigated further
the question of installation costs varying
by efficiency levels. In particular, DOE
investigated the issue around increased
cabinet sizes for ice makers and
modified the installation cost
calculation methodology to reflect
increased installation costs for
equipment classes that are size
constrained. In response to stakeholder
comments and data supplied by
stakeholders, DOE revised the analysis
for three equipment classes with
significant shipment volumes of 22inch-wide units and where height
increases in the cabinets were
considered in DOE’s engineering
analysis. In the engineering analysis for
the final rule, DOE examined design
options and efficiency level
improvements for 22-inch units for
three equipment classes under a
scenario where no increase in
equipment size was considered,
resulting in two separate cost-efficiency
curves (space constrained and nonspace constrained) for each of these
three classes (IMH–A–Small–B, IMH–
A–Large–B, and IMH–W–Small–B).
Each of these equipment classes is
designed for mounting on bins, ice
dispensers, or fountain dispensers, and
in the case of dispensers, generally the
combination is mounted on a counter or
table. For the LCC/PBP analysis and the
NIA, DOE integrated the two curves for
these equipment classes. To do so, at the
efficiency level where the 22-inch
engineering cost curves end, DOE
researched the additional installation
costs customers would incur in order to
raise ceilings or move walls to make it
possible for the customers to install the
larger, non-22-inch units. As PG&E,
SDG&E and CA IOU stated, not all
installations lack sufficient space to
accommodate increased chassis sizes.
Based on the research performed for the
final rule, DOE identified percentages of
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customers of the non-space constrained
equipment who also face size
constraints, and estimated additional
installation costs imposed by the need
to raise ceilings or address other height
constraints to facilitate cabinet size
increases. Chapter 8 of the final rule
TSD describes the process for including
building renovation costs in the ACIM
installation costs, and the inputs used in
the analysis.
In response to Hoshizaki and
Manitowoc comments, DOE researched
DWHX installation costs, and the cost to
install larger remote condensers. In both
cases, DOE identified incremental
installation costs for these design
options and added such to the
installation costs at the efficiency levels
that include these options.
In response to Scotsman and Ice-OMatic comments that the design options
might cause customers to need to
increase the size of electrical or water
services, the specific technologies
underlying the design options studied
by DOE would not require increased
electrical or water services. In
performing the engineering analyses,
DOE analyzed design options for each
equipment class at the same voltage
levels as existing typical units. As such,
there is no reason to believe that
meeting the energy conservation
standard for any specific equipment
class would require an increased
electrical service. Similarly, there is
reason to believe meeting the energy
conservation standard would require
greater water service, because no design
options were analyzed which would
increase water usage. Water or
wastewater services relocations or
countertop renovations would be
required if customers move ice makers,
but DOE’s belief is that moving ice
makers would not be a requirement
imposed by the small cabinet size
increases envisioned in this rulemaking.
Additional information regarding the
estimation of installation costs is
presented in TSD chapter 8.
b. Repair and Maintenance Costs
The repair cost is the average annual
cost to the customer for replacing or
repairing components in the automatic
commercial ice maker that have failed.
For the NOPR, DOE approximated
repair costs based on an assessment of
the components likely to fail within the
lifetime of an automatic commercial ice
maker in combination with the
estimated cost of these components
developed in the engineering analysis.
Under this methodology, repair and
replacement costs are based on the
original equipment costs, so the more
expensive the components are, the
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greater the expected repair or
replacement cost. For design options
modeled in the engineering analysis,
DOE estimated repair costs, and if they
were different than the baseline cost, the
repair costs were either increased or
decreased accordingly.
Maintenance costs are associated with
maintaining the proper operation of the
equipment. The maintenance cost does
not include the costs associated with the
replacement or repair of components
that have failed, which are included as
repair costs. In the NOPR analyses, DOE
estimated material and labor costs for
preventative maintenance based on RS
Means cost estimation data and on
telephone conservations with
contractors. DOE assumed maintenance
cost would remain constant for all
efficiency levels within an equipment
class.
AHRI commented that it is incorrect
to assume that changes in maintenance
and repair will be negligible for more
efficient equipment, and that DOE
should contact parts distributors to find
the price difference between permanent
split-capacitor (PSC) and ECM motors
and between 2-stage and 1-stage
compressors. AHRI noted that dealers
usually double their costs when
invoicing equipment owners. (AHRI,
No. 93 at p. 4) Similarly, Scotsman
commented that the supply-chain cost
impact of the standards would be nearly
equal in percentage to the manufactured
product cost increase. (Scotsman, No. 85
at p. 5b)
Scotsman commented that the
expedited product development
timeline would affect manufacturers by
impeding the traditional product
development process, resulting in a
higher product failure rate, additional
training burden, and increased repair
costs and that this cost should be
included in the analysis (Scotsman,
Public Meeting Transcript, No. 70 at p.
212, p. 218, p. 219–220).
In the final rule analysis released for
the NODA, DOE added a ‘‘repair labor
cost’’ to the original repair cost,
reflective of the cost of replacing
individual components. DOE’s research
did not identify studies or data
indicating that the failure rates, and in
turn maintenance and repair costs, of
energy-efficient equipment is
significantly higher than traditional
equipment. In response to AHRI’s
comments about contacting distributors
about motors and compressors, DOE did
collect labor information directly from
service companies upon which to base
the estimated labor hours. In response to
AHRI’s note about the doubling of costs,
the total repair chain markup
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underlying DOE’s estimated repair costs
is 250 percent of direct equipment costs.
In response to AHRI’s comment about
compressors, DOE did not include 2stage compressors in the engineering
analysis, and so the comment does not
apply.
In response to the Scotsman comment
about warranty costs, DOE has no
information indicating whether or how
much failure rates will change as a
result of standards implementation. To
the extent that training and warranty
costs are born by manufacturers and
identified in the data collection efforts,
such costs are included in the
manufacturer impact analysis.
3. Annual Energy and Water
Consumption
Chapter 7 of the final rule TSD details
DOE’s analysis of annual energy and
water usage at various efficiency levels
of automatic commercial ice makers.
Annual energy and water consumption
inputs by automatic commercial ice
maker equipment class are based on the
engineering analysis estimates of
kilowatt-hours of electricity per 100 lb
ice and gallons of water per 100 lb ice,
translated to annual kilowatt-hours and
gallons in the energy and water use
analysis (chapter 7 of the final rule
TSD). The development of energy and
water usage inputs is discussed in
section IV.F along with public input and
DOE’s response to the public input.
4. Energy Prices
DOE calculated average commercial
electricity prices using the EIA Form
EIA–826 data obtained online from the
‘‘Database: Sales (consumption),
revenue, prices & customers’’ Web
page.34 The EIA data are the average
commercial sector retail prices
calculated as total revenues from
commercial sales divided by total
commercial energy sales in kilowatthours, by state and for the nation. DOE
received no recommendations or
suggestions regarding this set of
assumptions at the April 2014 NOPR
public meeting or in written comments.
5. Energy Price Projections
To estimate energy prices in future
years for the NOPR and for the final
rule, DOE multiplied the average statelevel energy prices described in the
previous paragraph by the forecast of
annual average commercial energy price
indices developed in the Reference Case
34 U.S. Energy Information Administration. Sales
and revenue data by state, monthly back to 1990
(Form EIA–826). (Last accessed May 19, 2014).
www.eia.gov/electricity/data.cfm#sales.
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4699
from AEO2014.35 AEO2014 forecasted
prices through 2040. To estimate the
price trends after 2040, DOE assumed
the same average annual rate of change
in prices as exhibited by the forecast
over the 2031 to 2040 period. DOE
received no recommendations or
suggestions regarding this set of
assumptions at the April 2014 public
meeting or in written comments.
6. Water Prices
To estimate water prices in future
years for the NOPR, DOE used price
data from the 2008,36 2010,37 and 2012
American Water Works Association
(AWWA) Water and Wastewater
Surveys.38 The AWWA 2012 survey was
the primary data set. No data exists to
disaggregate water prices for individual
business types, so DOE varied prices by
state only and not by business type
within a state. For each state, DOE
combined all individual utility
observations within the state to develop
one value for each state for water and
wastewater service. Since water and
wastewater billings are frequently tied
to the same metered commodity values,
DOE combined the prices for water and
wastewater into one total dollars per
1,000 gallons figure. DOE used the
Consumer Price Index (CPI) data for
water-related consumption (1973–
2012) 39 in developing a real growth rate
for water and wastewater price
forecasts.
In written comments, the Alliance
stated that DOE looked only at energy
savings for air-cooled and water-cooled
ACIM equipment, and that DOE should
include water and wastewater cost in
the LCC analysis. The Alliance notes
that when such costs are included, aircooled equipment is more cost-effective
than water-cooled equipment. (Alliance,
No. 73 at p. 3) The Alliance further
recommended that DOE should reflect
the rising costs water and wastewater
cost in its life cycle analysis. (Alliance,
No. 73 at p. 3) The Alliance also
35 The spreadsheet tool that DOE used to conduct
the LCC and PBP analyses allows users 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.
36 American Water Works Association. 2008
Water and Wastewater Rate Survey. 2009. Denver,
CO. Report No. 54004.
37 American Water Works Association. 2010
Water and Wastewater Rate Survey. 2011. Denver,
CO. Report No. 54006.
38 American Water Works Association. 2012
Water and Wastewater Rate Survey. 2013. Denver,
CO. Report No. 54008.
39 The Bureau of Labor Statistics defines CPI as
a measure of the average change over time in the
prices paid by urban consumers for a market basket
of consumer goods and services. For more
information see www.bls.gov/cpi/home.htm.
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commented that DOE did not take into
account the embedded energy needed to
pump, tread and distribute water and to
collect and treat wastewater, noting that
the end user does not pay this cost and
that it is paid by the water and
wastewater user. (Alliance, No. 73 at p.
3, 18–19)
DOE includes water and wastewater
cost in the LCC analysis and notes that
real electric prices (2013$) escalate at
roughly 0.4 percent between 2013 and
2047, while real water and wastewater
prices escalate at roughly 2.0 percent
over the same time period. DOE
disagrees with the Alliance’s comment
that the end user of ice does not pay for
the cost of energy embedded in the
water used to make ice. This statement
implies that the hotels, restaurants and
other entities that use automatic
commercial ice makers and pay the
water and wastewater bills charge prices
that do not fully recover all of their
costs of doing business. DOE would
agree that the end user of ice does not
perceive the cost of the ice or any of the
factors of production that went into the
provision of the ice or the beverage
served with the ice. However, DOE
included water and wastewater costs in
the LCC analyses, thereby capturing the
cost of embedded energy in the analysis.
In response to the Alliance’s
comparison of equipment types, DOE’s
final rule and final rule TSD present
LCC results for all equipment classes.
As discussed in section II.A of this
preamble, DOE’s rulemaking authority
required DOE to promulgate standards
that do not eliminate features or reduce
customer utility. Because the existing
standards established by Congress made
water-cooled equipment separate
equipment classes differentiated by the
use of water in the condenser, DOE
considers the use of water in the
condenser to be a feature. For these
reasons, DOE has no reason to make
determinations that one equipment type
is more cost-effective than another type.
For the final rule, DOE updated the
calculation of State-level water prices
with the inclusion of 2013 consumer
price index values.
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7. Discount Rates
The discount rate is the rate at which
future expenditures are discounted to
establish their present value. DOE
determined the discount rate by
estimating the cost of capital for
purchasers of automatic commercial ice
makers. Most purchasers use both debt
and equity capital to fund investments.
Therefore, for most purchasers, the
discount rate is the weighted average
cost of debt and equity financing, or the
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weighted average cost of capital
(WACC), less the expected inflation.
DOE received no comments at the
April 2014 public meeting or in written
form related to discount rates.
To estimate the WACC of automatic
commercial ice maker purchasers for the
final rule, DOE used a sample of over
1,400 companies grouped to be
representative of operators of each of the
commercial business types (health care,
lodging, foodservice, retail, education,
food sales, and offices) drawn from a
database of 7,765 U.S. companies
presented on the Damodaran Online
Web site.40 This database includes most
of the publicly traded companies in the
United States. The WACC approach for
determining discount rates accounts for
the current tax status of individual firms
on an overall corporate basis. DOE did
not evaluate the marginal effects of
increased costs and the increased
depreciation due to more expensive
equipment, on the overall tax status.
DOE used the final sample of
companies to represent purchasers of
automatic commercial ice makers. DOE
combined company-specific information
from the Damodaran Online Web site,
long-term returns on the Standard &
Poor’s 500 stock market index from the
Damodaran Online Web site, nominal
long-term Federal government bond
rates, and long-term inflation to estimate
a WACC for each firm in the sample.
For most educational buildings and a
portion of the office buildings and
cafeterias occupied and/or operated by
public schools, universities, and state
and local government agencies, DOE
estimated the cost of capital based on a
40-year geometric mean of an index of
long-term (>20 years) tax-exempt
municipal bonds.41 42 Federal office
space was assumed to use the Federal
bond rate, derived as the 40-year
geometric average of long-term (>10
years) U.S. government securities.43
DOE recognizes that within the
business types purchasing automatic
commercial ice makers there will be
small businesses with limited access to
capital markets. Such businesses tend to
40 Damodaran financial data is available at https://
pages.stern.nyu.edu/∼adamodar/ (Last accessed
June 6, 2014).
41 Federal Reserve Bank of St. Louis, State and
Local Bonds—Bond Buyer Go 20-Bond Municipal
Bond Index. (Last accessed April 6, 2012). Annual
1974–2011 data were available at https://research.
stlouisfed.org/fred2/series/MSLB20/downloaddata
?cid=32995.
42 Rates for 2012 and 2013 calculated from
monthly data. Data source: U.S. Federal Reserve
(Last accessed July 10, 2014.) Available at https://
www.federalreserve.gov/releases/h15/data.htm.
43 Rate calculated with 1974–2013 data. Data
source: U.S. Federal Reserve (Last accessed July 10,
2014.) Available at https://www.federalreserve.gov/
releases/h15/data.htm.
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be viewed as higher risk by lenders and
face higher capital costs as a result. To
account for this, DOE included an
additional risk premium for small
businesses. The premium, 1.9 percent,
was developed from information found
on the Small Business Administration
Web site.44
Chapter 8 of the final rule TSD
provides more information on the
derivation of discount rates. The average
discount rate by business type is shown
on Table IV.27.
TABLE IV.27—AVERAGE DISCOUNT
RATE BY BUSINESS TYPE
Business type
Health Care ..........................
Lodging .................................
Foodservice ..........................
Retail .....................................
Education ..............................
Food Sales ...........................
Office ....................................
Average
discount
rate
(real)
(%)
3.4
7.9
7.1
5.8
4.0
6.9
6.2
8. Lifetime
DOE defines lifetime as the age at
which typical automatic commercial ice
maker equipment is retired from service.
DOE estimated equipment lifetime
based on its discussion with industry
experts and concluded a typical lifetime
of 8.5 years. For the NOPR analyses,
DOE elected to use an 8.5-year average
life for all equipment classes.
DOE received written comments on
the typical lifetime. Scotsman stated
continuous units might have a shorter
typical lifetime than batch type units
but did not provide estimates of the
difference. (Scotsman, No. 85 at p. 5b)
Hoshizaki commented that 8.5 years is
a good average lifetime assumption.
(Hoshizaki, No. 86 at p. 3) AHRI
commented that the average lifespan of
continuous type ice makers is 7 years
based on warranty data. (AHRI, No. 93
at p. 7) NAFEM commented that DOE
did not use adequate data to justify its
assumed lifetime of 8.5 years and that
DOE should study the difference in
lifetimes between batch type and
continuous type ice makers. (NAFEM,
No. 82 at p. 4)
AHRI and NAFEM both commented
that the proposed rule will increase the
size and the cost of automatic
commercial ice makers, and both
pointed to the example of air
44 Small Business Administration data on loans
between $10,000 and $99,000 compared to AAA
Corporate Rates. (Last accessed on June 10, 2013.)
Available at https://www.sba.gov/advocacy/7540/
6282.
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conditioners, where efficiency standards
led to larger and more expensive units.
The two stakeholders went on to state
that annual air conditioner industry
sales dropped about 18% while repair
parts sales sharply increased. (NAFEM,
No. 82 at p. 6 and p. 10; AHRI, No. 93
at p. 8) Follett commented that the
proposed rule is so stringent that it
would create significant hardship for
manufacturers and could require
compromises to reliability and
serviceability, adding that the rule could
incent end-users to repair rather than
replace their machines. (Follett, No. 84,
at p. 1)
With respect to NAFEM’s comment
about the adequacy of data, in the
framework and preliminary analysis
phases of this rulemaking, DOE
surveyed the available literature and
found a range of estimates of 7 to 10
years, with 8.5 being the average.
Literature cited on Table IV.28
suggested lifetimes of up to 20 years or
more for automatic commercial ice
makers, and this range was supported
by discussion with experts.
TABLE IV.28—ESTIMATES FOR AUTOMATIC COMMERCIAL ICE MAKER
LIFETIMES
Life
Reference
7 to 10 years .....
8.5 years ............
Arthur D. Little, 1996.45
California Energy Commission, 2004.46
Fernstrom, G., 2004.47
Koeller J., and H. Hoffman, 2008.48
Navigant Consulting, Inc.
2009.49
8.5 years ............
8.5 years ............
7 to 10 years .....
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With regard to the Scotsman’s
suggestion that continuous type ice
makers might have shorter life spans,
DOE found the comment lacking
sufficient specific information to act on
the comment. With respect to the AHRI
45 Arthur D. Little, Inc. Energy Savings for
Commercial Refrigeration. Final Report. June, 1996.
Submitted to the U.S. Department of Energy’s
Energy Efficiency and Renewable Energy Building
Technologies Program. Washington, DC.
46 California Energy Commission. Update of
Appliance Efficiency Regulations. 2004.
Sacramento, CA.
47 Fernstrom, G. B. Analysis of Standards Options
For Commercial Packaged Refrigerators, Freezers,
Refrigerator-Freezers and Ice Makers: Codes and
Standards Enhancement Initiative For PY2004: Title
20 Standards Development. 2004. Prepared by the
American Council for an Energy-Efficient Economy
for Pacific Gas & Electric Company, San Francisco,
CA.
48 Koeller J., and H. Hoffman. A report on
Potential Best Management Practices. 2008.
Prepared by Koeller and Company for the California
Urban Water Conservation Council, Sacramento,
CA.
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comment that continuous equipment
has a 7-year life, DOE notes that the
phrase ‘‘based on warranty data’’
provided no information that DOE could
analyze to determine whether to revise
the assumed equipment lifetime. In
addition, warranty claims do not
necessarily correlate with product
lifetime. For this reason, DOE decided
based on the previous, generally high
level of agreement with the 8.5-year
lifetime to retain that lifetime as the
basic assumption, and to use the 7-year
continuous product life for sensitivity
analyses.
With respect to the AHRI, NAFEM,
and Follett comments about
refurbishment, DOE acknowledges that
the increased size and prices of
automatic commercial ice makers
arising from new and amended
standards could lead to equipment
refurbishing or the purchase of used
equipment. DOE lacks sufficient
information to explicitly model the
extent of such refurbishment but
believes that it would not be significant
enough to change the rankings of TSLs.
When DOE performed additional and
recent research on repair costs before
issuance of the NODA, contractors
provided estimates of the hours to
replace failed components such as
compressors, but some also stated that
they recommended replacing the ice
maker instead of repairing it. In some
cases the contractor recommendations
were based on relative repair or
replacement costs and warranties while
in other cases they were based on the
time it would take to get the required,
specific ice maker components. DOE
also notes that, given the engineering
cost curves prepared for the final rule,
when the baseline efficiency
distribution of current shipments is
taken into account, the average total cost
increase faced by customers at TSL 3 is
less than 3 percent. For these reasons,
DOE believes that the degree of
refurbishing would not be significant
enough to change the rankings of the
TSLs considered in this rule.
9. Compliance Date of Standards
EPCA prescribes that DOE must
review and determine whether to amend
performance-based standards for cube
type automatic commercial ice makers
by January 1, 2015. (42 U.S.C.
6313(d)(3)(A)) In addition, EPCA
requires that the amended standards
established in this rulemaking must
49 Navigant Consulting, Inc. Energy Savings
Potential and R&D Opportunities for Commercial
Refrigeration. Final Report. 2009. Submitted to the
U.S. Department of Energy’s Energy Efficiency and
Renewable Energy Building Technologies Program,
Washington, DC.
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4701
apply to equipment that is
manufactured on or after 3 years after
the final rule is published in the Federal
Register 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.
6313(d)(3)(C)) For the NOPR analyses,
based on the January 1, 2015 statutory
deadline and giving manufacturers 3
years to meet the new and amended
standards, DOE assumed that the most
likely compliance date for the standards
set by this rulemaking would be January
1, 2018. As discussed in section IV.A.2,
DOE received comments about the
compliance date, including requests to
provide manufacturers 5 years to meet
the new and amended standards. As
stated in section IV.A.2, DOE believes
that the modifications it made in the
final rule analysis, relative to the NOPR,
will reduce the burden on
manufacturers to meet requirements
established by this rule. Therefore, DOE
has determined that the 3-year period is
adequate and is not extending the
compliance date for ACIMs. For the
final rule, a compliance date of January
1, 2018 was used for the LCC and PBP
analysis.
10. Base-Case and Standards-Case
Efficiency Distributions
To estimate the share of affected
customers who would likely be
impacted by a standard at a particular
efficiency level, DOE’s LCC analysis
considers the projected distribution of
efficiencies of equipment that customers
purchase under the base case (that is,
the case without new energy efficiency
standards). DOE refers to this
distribution of equipment efficiencies as
a base-case efficiency distribution.
For the NOPR, DOE estimated market
shares of each efficiency level within
each equipment class based on an
analysis of the automatic commercial
ice makers available for purchase by
customers. DOE analyzed all models
available as of November 2012,
calculated the percentage difference
between the baseline energy usage
embodied in the ice maker rulemaking
analyses, and organized the available
units by the efficiency levels. DOE then
calculated the percentage of available
models falling within each efficiency
level bin. This efficiency distribution
was used in the LCC and other
downstream analyses as the baseline
efficiency distribution.
At the NOPR public meeting ASAP
noted that the efficiency distribution
used by DOE showed manufacturers can
manufacture machines meeting the
efficiency levels proposed in the NOPR.
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(ASAP, Public Meeting Transcript, No.
70 at p. 256–257) Ice-O-Matic and
Manitowoc stated that the distribution
showed available equipment, but the
equipment at the higher efficiencies
might have small shipments relative to
other efficiency levels. (Ice-O-Matic,
Public Meeting Transcript, No. 70 at p.
260; Manitowoc, Public Meeting
Transcript, No. 70 at p. 261–263)
Hoshizaki commented that DOE’s
shipments analysis would be more
accurate if DOE requested actual
shipment data under NDA from
manufacturers each year. (Hoshizaki,
No. 86 at p. 4) At the public meeting,
manufacturers and AHRI agreed to
compile shipments information by
efficiency level.
In written comments, AHRI supplied
such information for batch type
equipment. AHRI also stated that DOE
should not use available models in the
AHRI database to estimate shipmentweighted market shares by efficiency
levels for batch type units, because by
doing so, DOE overestimates potential
energy savings by 11.3% or more.
(AHRI, No. 93 at p. 8–9)
For the final rule, DOE used the
efficiency distribution for batch type
equipment provided by AHRI. While
DOE did not analyze AHRI’s statement
of the overestimate of savings, DOE does
consider the shipment-based
distribution superior to the availableunit-based distribution. Lacking a
similar shipment-based distribution for
continuous equipment classes, DOE
used an available-unit-based
distribution for continuous equipment
classes for the final rule.
11. Inputs to Payback Period Analysis
Payback period is the amount of time
it takes the customer to recover the
higher purchase cost of more energyefficient equipment as a result of lower
operating costs. Numerically, the PBP is
the ratio of the increase in purchase cost
to the decrease in annual operating
expenditures. This type of calculation is
known as a ‘‘simple’’ PBP because it
does not take into account changes in
operating cost over time (i.e., as a result
of changing cost of electricity) or the
time value of money; that is, the
calculation is done at an effective
discount rate of zero percent. PBPs are
expressed in years. PBPs greater than
the life of the equipment mean that the
increased total installed cost of the
more-efficient equipment is not
recovered in reduced operating costs
over the life of the equipment, given the
conditions specified within the analysis,
such as electricity prices.
The inputs to the PBP calculation are
the total installed cost to the customer
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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.
In written comments, Earthjustice
stated that DOE inappropriately used a
3-year payback period as an upper limit
for an acceptable customer impact
without providing a justification for
such, and that DOE should revise its
approach for using payback period.
(Earthjustice, No. 81, pp. 1–2) DOE
acknowledges the comment and notes
that, for the NOPR, DOE intended the
use of the payback period as an
illustration of the relatively significant
differences between the impacts of
TSLs.
12. Rebuttable Presumption Payback
Period
EPCA (42 U.S.C. 6295(o)(2)(B)(iii) and
6313(d)(4)) established a rebuttable
presumption that new or amended
standards are 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 that the consumer will receive
during the first year as a result of the
standard, as calculated under the
applicable test procedure.
While DOE examined the rebuttable
presumption criterion, it considered
whether the standard levels considered
are economically justified through a
more detailed analysis of the economic
impacts of these levels pursuant to 42
U.S.C. 6295(o)(2)(B)(iii) and 6313(d)(4).
The results of this analysis served as the
basis for DOE to evaluate the economic
justification for a potential standard
level definitively (thereby supporting or
rebutting the results of any preliminary
determination of economic
justification).
H. National Impact Analysis—National
Energy Savings and Net Present Value
The NIA assesses the NES and the
NPV of total customer costs and savings
that would be expected as a result of the
amended energy conservation
standards. The NES and NPV are
analyzed at specific efficiency levels
(i.e., TSL) for each equipment class of
automatic commercial ice makers. 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 LCC analysis. For the
NOPR analysis, DOE forecasted the
energy savings, operating cost savings,
equipment costs, and NPV of customer
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Sfmt 4700
benefits for equipment sold from 2018
through 2047—the year in which the
last standards-compliant equipment is
shipped during the 30-year analysis.
DOE evaluates the impacts of the new
and amended standards by comparing
base-case projections with standardscase projections. The base-case
projections characterize energy use and
customer costs for each equipment class
in the absence of any new or amended
energy conservation standards. DOE
compares these base-case projections
with projections characterizing the
market for each equipment class if DOE
adopted the amended standards at each
TSL. For the standards cases, DOE
assumed a ‘‘roll-up’’ scenario in which
equipment at efficiency levels that do
not meet the standard level under
consideration would ‘‘roll up’’ to the
efficiency level that just meets the
proposed standard level, and equipment
already being purchased at efficiency
levels at or above the proposed standard
level would remain unaffected.
DOE uses a Microsoft Excel
spreadsheet model to calculate the
energy savings and the national
customer costs and savings from each
TSL. Final rule TSD chapter 10 and
appendix 10A explain the models and
how to use them, and interested parties
can review DOE’s analyses by
interacting with these spreadsheets. The
models and documentation are available
at: https://www1.eere.energy.gov/
buildings/appliance_standards/
rulemaking.aspx/ruleid/29.
The NIA spreadsheet model uses
average values as inputs (rather than
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
AEO2014 Reference Case. In addition,
DOE analyzed scenarios that used
inputs from the AEO2014 Low
Economic Growth and High Economic
Growth Cases. These cases have lower
and higher energy price trends,
respectively, compared to the Reference
Case. NIA results based on these cases
are presented in chapter 10 of the final
rule TSD.
A detailed description of the
procedure to calculate NES and NPV
and inputs for this analysis are provided
in chapter 10 of the final rule TSD.
1. Shipments
Comments related to the shipment
analysis received at the April 2014
public meeting were all questions for
clarification. The following description
of the shipments projection presents the
shipments analysis for the final rule.
The process described in this section
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was documented and released for
comments in the NODA.
DOE obtained data from AHRI,
ENERGY STAR, and U.S. Census
Bureau’s Current Industrial Reports
(CIR) to estimate historical shipments
for automatic commercial ice makers.
AHRI provided DOE with automatic
commercial ice maker shipment data for
2010 describing the distribution of
shipments by equipment class and by
harvest capacity. AHRI data provided to
DOE also included an 11-year history of
total shipments from 2000 to 2010. DOE
also collected total automatic
commercial ice maker shipment data for
the period of 1973 to 2009 from the CIR.
Additionally, DOE collected 2008–2012
data on ACIM shipments under the
ENERGY STAR program. The ENERGY
STAR data consisted of numbers of
units meeting ENERGY STAR efficiency
levels and the percent of the total
market represented, from which the
total market could be estimated.
ENERGY STAR shipments only
pertained to air-cooled batch
equipment.
In the preliminary analysis phase,
DOE relied extensively on the CIR
shipments data for the shipments
projection. Subsequent to receiving
comments on the preliminary analysis
shipments, DOE relied more heavily on
AHRI data for the NOPR and for the
final rule shipments projections. After
the NOPR analyses were completed,
analysis of ENERGY STAR data led DOE
to conclude that the AHRI data
understates shipments by approximately
9 percent and that the difference was
likely due to a greater number of
manufacturers represented in the
ENERGY STAR results. However, the
AHRI data gives significantly greater
detail than the ENERGY STAR data.
Therefore, the final rule and the NOPR
methodologies are identical except for
an upward adjustment of the historical
AHRI data by 9 percent to correct for the
presumed under-reporting of non-AHRImembers.
To determine the percentage of
shipments going to replace existing
stock and the percentage represented by
new installations, DOE used the CIR
data to create a series of estimates of
total existing stock by aggregating
historical shipments across 8.5-year
historical periods. DOE used the CIR
data to estimate a time series of
shipments and total stock for 1994 to
2006—at the time of the analysis, the
last year of data available without
significant gaps in the data due to
disclosure limitations. For each year,
using shipments, stock, and the 8.5-year
life of the equipment, DOE estimated
that, on average, 14 percent of
shipments were for new installations
and the remainder for replacement of
existing stock.
DOE then used the historical AHRI
shipments to create a 2010 stock
estimate. The 2010 stock and 2010
shipments from AHRI, disaggregated
between new installations and
shipments for existing stock
replacement, were combined with
projections of new construction activity
from AEO2014 to generate a forecast of
shipments for new installations. Stock
and shipments were first disaggregated
to individual business types based on
data developed for DOE on commercial
ice maker stocks.50 The business types
and share of stock represented by each
type are shown in Table IV.29. Using a
4703
Weibull distribution assuming that
equipment has an average life of 8.5
years and lasts from 5 to 11 years, DOE
developed a 30-year series of
replacement ice maker shipments using
the AHRI historical series. Using the
estimated 2010 shipments to new
installations, and year-to-year changes
in new commercial sector floor space
additions from AEO2014, DOE
estimated future shipments for new
installations. (For the NOPR, DOE used
AEO2013 projections of floor space
additions.) The AEO2014 floor space
additions by building type are shown in
Table IV.30. The combination of the
replacement and new installation
shipments yields total shipments. The
final step was to distribute total sales to
equipment classes by multiplying the
total shipments by percentage shares by
class. Table IV.31 shows the percentages
represented by all equipment classes,
both the primary classes modeled
explicitly in all NOPR analyses as well
as the secondary classes.
TABLE IV.29—BUSINESS TYPES
INCLUDED IN SHIPMENTS ANALYSIS
Building type
as percent of
stock
(%)
Building type
Health Care ..........................
Lodging .................................
Foodservice ..........................
Retail .....................................
Education ..............................
Food Sales ...........................
Office ....................................
9
33
22
8
7
16
4
Total ...............................
100
TABLE IV.30—AEO2014 FORECAST OF NEW BUILDING SQUARE FOOTAGE
New construction
million ft2
Year
Health Care
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2013 .............................
2018 .............................
2020 .............................
2025 .............................
2030 .............................
2035 .............................
2040 .............................
Annual Growth Factor,
2031–2040 ................
Lodging
19:19 Jan 27, 2015
Retail
Education
Food sales
Office
66
67
65
63
71
72
76
147
164
176
181
150
207
188
31
51
47
48
55
57
56
279
428
404
444
515
527
565
247
209
197
169
190
228
252
21
36
33
34
39
40
40
174
411
451
392
276
415
403
2.4%
2.5%
2.4%
2.5%
1.7%
2.3%
2.1%
50 Navigant Consulting, Inc. Energy Savings
Potential and R&D Opportunities for Commercial
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Refrigeration. Final Report, submitted to the U.S.
Department of Energy. September 23, 2009. p. 41.
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TABLE IV.31—PERCENT OF SHIPPED
UNITS OF AUTOMATIC COMMERCIAL
ICE MAKERS
Equipment class
TABLE IV.31—PERCENT OF SHIPPED presented in section IV.G.10, and a
UNITS OF AUTOMATIC COMMERCIAL detailed description can be found in
chapter 10 of the final rule TSD. To
ICE MAKERS—Continued
Percentage of
shipments
(%)
IMH–W–Small–B ..................
IMH–W–Med–B ....................
IMH–W–Large–B ..................
IMH–A–Small–B ...................
IMH–A–Large–B ...................
RCU–Small–B .......................
RCU–RC/NC–Large–B .........
SCU–W–Small–B .................
SCU–W–Large–B .................
SCU–A–Small–B ..................
SCU–A–Large–B ..................
IMH–W–Small–C ..................
IMH–W–Large–C ..................
IMH–A–Small–C ...................
IMH–A–Large–C ...................
RCU–Small–C ......................
4.54
2.90
0.48
27.08
16.14
5.43
6.08
0.68
0.22
13.85
6.56
0.68
0.17
3.53
1.07
0.83
Percentage of
shipments
(%)
Equipment class
RCU–Large–C ......................
SCU–W–Small–C .................
SCU–W–Large–C .................
SCU–A–Small–C ..................
SCU–A–Large–C ..................
0.87
0.15
0.00
8.75
0.00
Total ...............................
100.00
Source: AHRI, 2010 Shipments data submitted to DOE as part of this rulemaking.
2. Forecasted Efficiency in the Base Case
and Standards Cases
estimate efficiency trends in the
standards cases, DOE uses a ‘‘roll-up’’
scenario in its standards rulemakings.
Under the ‘‘roll-up’’ scenario, DOE
assumes that equipment efficiencies in
the base case that do not meet the
standard level under consideration
would ‘‘roll up’’ to the efficiency level
that just meets the proposed standard
level, and equipment already being
purchased at efficiencies at or above the
standard level under consideration
would be unaffected. Table IV.32 shows
the shipment-weighted market shares by
efficiency level in the base-case
scenario.
The method for estimating the market
share distribution of efficiency levels is
TABLE IV.32—SHIPMENT-WEIGHTED MARKET SHARES BY EFFICIENCY LEVEL, BASE CASE
Market share by efficiency level
Percent
Equipment class
Level 1
IMH–W–Small–B ..........................
IMH–W–Med–B ............................
IMH–W–Large–B
IMH–W–Large–B–1 ..............
IMH–W–Large–B–2 ..............
IMH–A–Small–B ...........................
IMH–A–Large–B
IMH–A–Large–B–1 ...............
IMH–A–Large–B–2 ...............
RCU–Large–B
RCU–Large–B–1 ...................
RCU–Large–B–2 ...................
SCU–W–Large–B .........................
SCU–A–Small–B ..........................
SCU–A–Large–B ..........................
IMH–A–Small–C ...........................
IMH–A–Large–C ..........................
RCU–Small–C ..............................
SCU–A–Small–C ..........................
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Level 3A
Level 4
Level 4A
Level 5
Level 6
Level 7
15.6
20.0
44.8
15.3
................
................
2.5
8.9
0.0
................
0.0
................
................
................
................
................
87.2
87.2
23.7
12.8
12.8
29.5
................
................
46.8
................
................
0.0
................
................
0.0
................
................
................
................
................
0.0
................
................
0.0
................
................
................
34.1
16.8
27.8
22.5
35.1
60.8
0.3
................
2.7
................
................
................
................
................
................
................
................
................
43.9
43.9
71.6
51.8
62.6
30.6
43.5
27.8
44.1
36.4
36.4
0.6
15.3
14.8
11.1
21.7
27.8
8.8
18.8
18.8
0.0
12.9
21.5
19.4
17.4
33.3
14.7
................
................
................
................
................
................
................
................
................
1.0
1.0
22.5
8.0
0.0
5.6
8.7
5.6
17.6
................
................
................
................
................
................
................
................
................
................
................
5.4
12.0
1.1
19.4
8.7
0.0
14.7
................
................
0.0
0.0
0.0
13.9
................
5.6
0.0
................
................
................
0.0
................
................
................
................
................
For each year in the forecast period,
DOE calculates the NES for each TSL by
multiplying the stock of equipment
affected by the energy conservation
standards by the estimated per-unit
annual energy savings. DOE typically
considers the impact of a rebound effect,
introduced in the energy use analysis, in
its calculation of NES 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. When a
rebound effect occurs, it is generally
because the users of the equipment
perceive it as less costly to use the
equipment and elect to use it more
19:19 Jan 27, 2015
Level 3
37.1
55.8
3. National Energy Savings
VerDate Sep<11>2014
Level 2
intensively. In the case of automatic
commercial ice makers, users of the
equipment include restaurant wait staff,
hotel guests, cafeteria patrons, or
hospital staff using ice in the treatment
of patients. Users of automatic
commercial ice makers tend to have
little or no perception of or personal
stake in the cost of the ice and rather are
using the ice to serve a specific need.
Given this, DOE believes there is very
little or no potential for a rebound
effect. For the NIA, DOE used a rebound
factor of 1, or no effect, for automatic
commercial ice makers.
At the NOPR phase, the only
comment regarding rebound effect was
from the Policy Analyst. Policy Analyst
stated that DOE should evaluate
whether there was a rebound effect
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caused by the previous standard. (Policy
Analyst, No. 75 at p. 10) As stated
above, DOE believes that the users of
ACIM equipment would not perceive
the price effects, so DOE believes
rebound effect should not be present for
this equipment and does not believe
further analysis is necessary.
Inputs to the calculation of NES are
annual unit energy consumption,
shipments, equipment stock, and a siteto-source conversion factor.
The annual unit energy consumption
is the site energy consumed by an
automatic commercial ice maker unit in
a given year. Using the efficiency of
units at each efficiency level and the
baseline efficiency distribution, DOE
determined annual forecasted shipmentweighted average equipment efficiencies
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that, in turn, enabled determination of
shipment-weighted annual energy
consumption values.
The automatic commercial ice makers
stock in a given year is the total number
of automatic commercial ice makers
shipped from earlier years (up to 12
years earlier) that remain in use in that
year. The NES spreadsheet model keeps
track of the total units shipped each
year. For purposes of the NES and NPV
analyses in the NOPR analysis, DOE
assumed that, based on an 8.5-year
average equipment lifetimes,
approximately 12 percent of the existing
automatic commercial ice makers are
retired and replaced in each year. DOE
assumes that, for units shipped in 2047,
any units still remaining at the end of
2055 will be replaced.
DOE uses a multiplicative factor
called ‘‘site-to-source conversion factor’’
to convert site energy consumption (at
the commercial building) into primary
or source energy consumption (the
energy input at the energy generation
station required to convert and deliver
the energy required at the site of
consumption). These site-to-source
conversion factors account for the
energy used at power plants to generate
electricity and for the 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 amended
energy conservation standards.
For this final rule, DOE used
conversion factors based on the U.S.
energy sector modeling using the
National Energy Modeling System
(NEMS) Building Technologies (NEMS–
BT) version that corresponds to
AEO2014 and which provides national
energy forecasts through 2040. Within
the results of NEMS–BT model runs
performed by DOE, a site-to-source ratio
for commercial refrigeration was
developed. The site-to-source ratio was
held constant beyond 2040 through the
end of the analysis period (30 years plus
the life of equipment).
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
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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) 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.51
The approach used for this final rule,
and the FFC multipliers that were
applied are described in appendix 10D
of the final rule TSD. NES results are
presented in both primary and in terms
of FFC savings. The savings by TSL are
summarized in terms of FFC savings in
section I.C.
4. Net Present Value of Customer
Benefit
The inputs for determining the NPV
of the total costs and benefits
experienced by customers of the
automatic commercial ice makers are (1)
total annual installed cost; (2) total
annual savings in operating costs; and
(3) a discount factor. DOE calculated net
national customer savings for each year
as the difference in installation and
operating costs between the base-case
scenario and standards-case scenarios.
DOE calculated operating cost savings
over the life of each piece of equipment
shipped in the forecast period.
DOE multiplied monetary values in
future years by the discount factor to
determine the present value of costs and
savings. DOE estimated national
impacts with both a 3-percent and a 7percent real discount rate as the average
real rate of return on private investment
in the U.S. economy. These discount
rates are used in accordance with the
Office of Management and Budget
(OMB) guidance to Federal agencies on
the development of regulatory analysis
(OMB Circular A–4, September 17,
2003), and section E, ‘‘Identifying and
Measuring Benefits and Costs,’’ therein.
DOE defined the present year as 2013
for the NOPR analysis. The 7-percent
real value is an estimate of the average
before-tax rate of return to private
capital in the U.S. economy. DOE used
the 3-percent rate to capture the
potential effects of the new and
amended standards on private
consumption. This rate represents the
51 Docket ID: EERE–2010–BT–NOA–0028,
comment by Kirk Lundblade.
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‘‘societal rate of time preference,’’ which
is the rate at which society discounts
future consumption flows to their
present.
DOE received one comment from IceO-Matic stating that the 7-percent
discount rate was too high when the
current prime rate is 3.25 percent and
the current Treasury bill rate is 3.67
percent. (Ice-O-Matic, No. 120, p. 1; IceO-Matic, No. 121, p. 1) Ice-O-Matic also
indicated that the use of 7-percent
discount rate inflated the rate of return
experienced by customers. (Ice-O-Matic,
No. 120, p. 1)
As Ice-O-Matic noted, the discount
rate is high relative to current interest
rates. However, DOE suspects that the
comments misinterpreted the use of the
discount rate. In this case, the discount
rate is used to express a given number
of future dollars as an equivalent
number of dollars today, whereas the
comments seemed to assume the
discount rate was used as an interest
rate to express a given number of dollars
today as a future value equivalent. Since
the 7-percent discount rate that DOE
used in the NIA is used in accordance
with OMB guidelines, DOE will
continue using it in the NIA.
As discussed in section IV.G.1, DOE
included a projection of price trends in
the preliminary analysis NIA. For the
NOPR, DOE reviewed and updated the
analysis with the result that the
projected reference case downward
trend in prices is quite modest. For the
NOPR, DOE also developed high and
low case price trend projections, as
discussed in final rule TSD appendix
10B.
I. Customer Subgroup Analysis
In analyzing the potential impact of
new or amended standards on
commercial customers, DOE evaluates
the impact on identifiable groups (i.e.,
subgroups) of customers, such as
different types of businesses that may be
disproportionately affected. Small
businesses typically face a higher cost of
capital. In general, the lower the cost of
electricity and higher the cost of capital,
the more likely it is that an entity would
be disadvantaged by the requirement to
purchase higher efficiency equipment.
Based on the data available to DOE,
automatic commercial ice maker
ownership in three building types
represent over 70 percent of the market:
Food sales, foodservice, and hotels.
Based on data from the 2007 U.S.
Economic Census and size standards set
by the U.S. Small Business
Administration (SBA), DOE determined
that a majority of food sales, foodservice
and lodging firms fall under the
definition of small businesses. Chapter
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8 of the TSD presents the electricity
price by business type and discount
rates by building types, respectively,
while chapter 11 discusses these topics
as they specifically relate to small
businesses.
Comparing the foodservice, food
sales, and lodging categories,
foodservice faces the highest energy
price, with food sales and lodging facing
lower and nearly the same energy
prices. Lodging faces the highest cost of
capital. Foodservice faces a higher cost
of capital than food sales. Given the cost
of capital disparity, lodging was
selected for LCC subgroup analysis.
With foodservice facing a higher cost of
capital, it was selected for LCC
subgroup analysis because the higher
cost of capital should lead foodservice
customers to value first cost more and
future electricity savings less than
would be the case for food sales
customers.
Three written comments specifically
focused on the customer subgroups, all
three specifically focusing on the food
service industry. U.S. Senator Toomey
commented that the proposed rule will
negatively impact employment in the
food services industry, which is
dominated by small businesses, and that
restaurant owners would already
purchase efficient products if they were
going to be able to recoup the higher
prices through savings. (U.S. Senator
Toomey, No. 79 at p. 1) NRA
commented that the cost of new
standards could be greater for small
businesses, due to increased capital,
maintenance, repair, and installation
costs, thus affecting their payback
period. (NRA, No. 69 at p. 2–3) NAFEM
commented that the proposed rule will
affect the food service industry, which
is also dominated by small businesses,
because they will not be able to afford
equipment upgrades and will choose to
extend the life of used equipment.
(NAFEM, No. 82 at p. 5)
With respect to the issue of negative
employment impacts, if the standard
has a positive LCC benefit to the food
service customer, such an impact
should not reduce employment. DOE
notes that the LCC analysis looks strictly
at the net economic impact of a
hypothetical purchase of equipment and
does not look specifically at
employment. However, if the analysis
shows a net LCC benefit, the food
service customer should be better off
and presumably such result should not
negatively impact employment. DOE
agrees with the NRA comment that the
cost of new standards could be greater
for small businesses and notes the
analysis of the impacts is precisely the
point of the customer subgroup analysis.
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With respect to NAFEM’s comment
regarding small business’s inability to
afford the equipment upgrades, if the
results indicate positive LCC benefits
the presumption is that the customer’s
financial situation is improved with the
more efficient equipment when
compared to less efficient equipment.
DOE lacks information with which to
estimate the extent to which customers
might choose to extend the life of
equipment, but believes that given the
relatively modest average price increase
of the proposed standard
(approximately 3 percent) in
combination with the customer energy
savings, the proportion of customers
who would choose life extension is
small.
DOE estimated the impact on the
identified customer subgroups using the
LCC spreadsheet model. The standard
LCC and PBP analyses (described in
section IV.F) include various types of
businesses that use automatic
commercial ice makers. For the LCC
subgroup analysis, it was assumed that
the subgroups analyzed do not have
access to national purchasing accounts
or to major capital markets thereby
making the discount rates higher for
these subgroups. Details of the data used
for LCC subgroup analysis and results
are presented in chapter 11 of the TSD.
J. Manufacturer Impact Analysis
1. Overview
DOE performed an MIA to estimate
the impacts of new and amended energy
conservation standards on
manufacturers of automatic commercial
ice makers. The MIA has both
quantitative and qualitative aspects and
includes analyses of forecasted industry
cash flows, the INPV, investments in
research and development (R&D) and
manufacturing capital, and domestic
manufacturing employment.
Additionally, the MIA seeks to
determine how amended energy
conservation standards might affect
manufacturing employment, capacity,
and competition, as well as how
standards contribute to overall
regulatory burden. Finally, the MIA
serves to identify any disproportionate
impacts on manufacturer subgroups, in
particular, small businesses.
The quantitative part of the MIA
primarily relies on the Government
Regulatory Impact Model (GRIM), an
industry cash flow model with inputs
specific to this rulemaking. The key
GRIM inputs include data on the
industry cost structure, unit production
costs, product shipments, manufacturer
markups, and investments in R&D and
manufacturing capital required to
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produce compliant products. A key
GRIM output is the INPV, which is the
sum of industry annual cash flows over
the analysis period, discounted using
the industry weighted average cost of
capital. Another key output is the
impact to domestic manufacturing
employment. The model estimates the
impacts of more-stringent energy
conservation standards on a given
industry by comparing changes in INPV
and domestic manufacturing
employment between a base case and
the various TSLs in the standards case.
To capture the uncertainty relating to
manufacturer pricing strategy following
amended standards, the GRIM estimates
a range of possible impacts under
different markup scenarios.
The qualitative part of the MIA
addresses manufacturer characteristics
and market trends. Specifically, the MIA
considers such factors as manufacturing
capacity, competition within the
industry, the cumulative impact of other
DOE and non-DOE regulations, and
impacts on small business
manufacturers. The complete MIA is
outlined in chapter 12 of the final rule
TSD.
DOE conducted the MIA for this
rulemaking in three phases. In Phase 1
of the MIA, DOE prepared a profile of
the automatic commercial ice maker
industry. This included a top-down cost
analysis of automatic commercial ice
maker manufacturers that DOE used to
derive preliminary financial inputs for
the GRIM (e.g., revenues; materials,
labor, overhead, and depreciation
expenses; selling, general, and
administrative expenses (SG&A); and
R&D expenses). DOE also used public
sources of information to further
calibrate its initial characterization of
the automatic commercial ice maker
industry, including company Securities
and Exchange Commission (SEC) 10–K
filings,52 corporate annual reports, the
U.S. Census Bureau’s Economic
Census,53 and Hoover’s reports.54
In Phase 2 of the MIA, DOE prepared
a framework industry cash flow analysis
to quantify the impacts of new and
amended energy conservation
standards. The GRIM uses several
factors to determine a series of annual
cash flows starting with the
announcement of the standard and
extending over a 30-year period
52 U.S. Securities and Exchange Commission.
Annual 10–K Reports. Various Years. https://sec.gov.
53 U.S.Census Bureau, Annual Survey of
Manufacturers: General Statistics: Statistics for
Industry Groups and Industries. https://factfinder2.
census.gov/faces/nav/jsf/pages/
searchresults.xhtml?refresh=t.
54 Hoovers Inc. Company Profiles. Various
Companies. https://www.hoovers.com.
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following the effective date of the
standard. These factors include annual
expected revenues, costs of sales, SG&A
and R&D expenses, taxes, and capital
expenditures. In general, 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 changes in
sales volumes.
In addition, during Phase 2, DOE
developed interview guides to distribute
to manufacturers of automatic
commercial ice makers in order to
develop other key GRIM inputs,
including product and capital
conversion costs, and to gather
additional information on the
anticipated effects of energy
conservation standards on revenues,
direct employment, capital assets,
industry competitiveness, and subgroup
impacts.
In Phase 3 of the MIA, DOE
conducted structured, detailed
interviews with a representative crosssection 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. As part of Phase 3,
DOE also evaluated subgroups of
manufacturers that may be
disproportionately impacted by
amended standards or that may not be
accurately represented by the average
cost assumptions used to develop the
industry cash flow analysis. Such
manufacturer subgroups may include
small manufacturers, low volume
manufacturers, niche players, and/or
manufacturers exhibiting a cost
structure that largely differs from the
industry average.
DOE identified one subgroup, small
manufacturers, for which average cost
assumptions may not hold. DOE applied
the small business size standards
published by the SBA to determine
whether a company is considered a
small business. 65 FR 30836 (May 15,
2000), as amended by 65 FR 53533
(Sept. 5, 2000) and 67 FR 52597 (Aug.
13, 2002), as codified at 13 CFR part
121. 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,’’ which includes
commercial ice maker manufacturing, as
having 750 or fewer employees. The
750-employee threshold includes all
employees in a business’s parent
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company and any other subsidiaries.
Based on this classification, DOE
identified seven manufacturers of
automatic commercial ice makers that
qualify as small businesses. The
automatic commercial ice maker small
manufacturer subgroup is discussed in
chapter 12 of the final rule TSD and in
section VI.B.1 of this rulemaking.
2. Government Regulatory Impact Model
DOE uses the GRIM to quantify the
changes in industry cash flows resulting
from new or amended energy
conservation standards. The GRIM uses
manufacturer costs, markups,
shipments, and industry financial
information to arrive at a series of basecase annual cash flows absent new or
amended standards, beginning in 2015
and continuing through 2047. The GRIM
then models changes in costs,
investments, shipments, and
manufacturer margins that may result
from new or amended energy
conservation standards and compares
these results against those in the basecase forecast of annual cash flows. The
primary quantitative output of the GRIM
is the INPV, which DOE calculates by
summing the stream of annual
discounted cash flows over the full
analysis period. For manufacturers of
automatic commercial ice makers, DOE
used a real discount rate of 9.2 percent,
based on the weighted average cost of
capital as derived from industry
financials and feedback received during
confidential interviews with
manufacturers.
The GRIM calculates cash flows using
standard accounting principles and
compares changes in INPV between the
base case and each TSL. The difference
in INPV between the base case and a
standards case represents the financial
impact of the amended standard on
manufacturers at that particular TSL. As
discussed previously, DOE collected the
necessary information to develop key
GRIM inputs from a number of sources,
including publicly available data and
interviews with manufacturers
(described in the next section). The
GRIM results are shown in section
V.B.2.a. Additional details about the
GRIM can be found in chapter 12 of the
final rule TSD.
a. Government Regulatory Impact Model
Key Inputs
Manufacturer Production Costs
Manufacturing higher efficiency
equipment is typically more expensive
than manufacturing baseline equipment
due to the use of more complex, and
typically more costly, components. The
changes in the MPCs of the analyzed
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equipment can affect the revenues, gross
margins, and cash flow of the industry,
making production cost data key GRIM
inputs for DOE’s analysis.
For each efficiency level of each
equipment class that was directly
analyzed, DOE used the MPCs
developed in the engineering analysis,
as described in section IV.B and further
detailed in chapter 5 of the final rule
TSD. For equipment classes that were
indirectly analyzed, DOE used a
composite of MPCs from similar
equipment classes, substitute
component costs, and design options to
develop an MPC for each efficiency
level. For equipment classes that had
multiple units analyzed, DOE used a
weighted average MPC based on the
relative shipments of products at each
efficiency level as the input for the
GRIM. Additionally, DOE used
information from its reverse engineering
analysis, described in section IV.D.4, to
disaggregate the MPCs into material and
labor costs. These cost breakdowns and
equipment markups were validated with
manufacturers during manufacturer
interviews.
Base-Case Shipments Forecast
The GRIM estimates manufacturer
revenues based on total unit shipment
forecasts and the distribution of
shipments by efficiency level. Changes
in sales volumes and efficiency mix
over time can significantly affect
manufacturer finances. For the base-case
analysis, the GRIM uses the NIA’s
annual shipment forecasts from 2015,
the base year, to 2047, the end of the
analysis period. See chapter 9 of the
final rule TSD for additional details.
Product Conversion Costs, Capital
Conversion Costs, and Stranded Assets
New and amended energy
conservation standards will cause
manufacturers to incur conversion costs
to bring their production facilities and
product designs into compliance. For
the MIA, DOE classified these
conversion costs into two major groups:
(1) Product conversion costs and (2)
capital conversion costs. Product
conversion costs include investments in
research, development, testing,
marketing, and other non-capitalized
costs necessary to make product designs
comply with new or amended energy
conservation standards. Capital
conversion costs include investments in
property, plant, and equipment
necessary to adapt or change existing
production facilities such that new
product designs can be fabricated and
assembled.
If new or amended energy
conservation standards require
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investment in new manufacturing
capital, there also exists the possibility
that they will render existing
manufacturing capital obsolete. In the
case that this obsolete manufacturing
capital is not fully depreciated at the
time new or amended standards go into
effect, this would result in the stranding
of these assets, and would necessitate
the write-down of their residual undepreciated value.
DOE used multiple sources of data to
evaluate the level of product and capital
conversion costs and stranded assets
manufacturers would likely face to
comply with new or amended energy
conservation standards. DOE used
manufacturer interviews to gather data
on the level of investment anticipated at
each proposed efficiency level and
validated these assumptions using
estimates of capital requirements
derived from the product teardown
analysis and engineering model
described in section IV.D.4. These
estimates were then aggregated and
scaled using information gained from
industry product databases to derive
total industry estimates of product and
capital conversion costs and to protect
confidential information.
In general, DOE assumes that all
conversion-related investments occur
between the year the final rule is
published and the year by which
manufacturers must comply with the
new or amended standards. The
investment figures used in the GRIM
can be found in section V.B.2.a of this
preamble. For additional information on
the estimated product conversion and
capital conversion costs, see chapter 12
of the final rule TSD.
b. Government Regulatory Impact Model
Scenarios
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Markup Scenarios
As discussed in section IV.J.2.b MSPs
include direct manufacturing
production costs (i.e., labor, material,
overhead, and depreciation estimated in
DOE’s MPCs) and all non-production
costs (i.e., SG&A, R&D, and interest),
along with profit. To calculate the MSPs
in the GRIM, DOE applied manufacturer
markups to the MPCs estimated in the
engineering analysis. 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 amended energy
conservation standards: (1) A
preservation of gross margin percentage
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markup scenario; and (2) a preservation
of earnings before interest and taxes
(EBIT) markup scenario. These
scenarios lead to different markups
values that, when applied to the 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
with efficiency, this scenario implies
that the absolute dollar markup will
increase as well. Based on publicly
available financial information for
manufacturers of automatic commercial
ice makers and comments from
manufacturer interviews, DOE assumed
the industry average markup on
production costs to be 1.25. Because this
markup scenario assumes that
manufacturers would be able to
maintain their gross margin percentage
as production costs increase in response
to new and amended energy
conservation standards, it represents a
lower bound of industry impacts (higher
industry profitability) under new and
amended energy conservation
standards.
In the preservation of EBIT markup
scenario, manufacturer markups are
calibrated so that EBIT in the year after
the compliance date of the amended
energy conservation standard is the
same as in the base case. Under this
scenario, as the cost of production goes
up, manufacturers are generally
required to reduce the markups on their
minimally compliant products to
maintain a cost-competitive offering.
The implicit assumption behind this
scenario is that the industry can only
maintain EBIT in absolute dollars after
compliance with the amended standard
is required. Therefore, operating margin
(as a percentage) shrinks in the
standards cases. This markup scenario
represents an upper bound of industry
impacts (lower profitability) under an
amended energy conservation standard.
3. Discussion of Comments
During the NOPR public meeting,
interested parties commented on the
assumptions and results of the analyses
in the NOPR TSD. In addition,
interested parties submitted written
comments on the assumptions and
results of the NOPR TSD and NODA.
DOE summarizes the MIA related
comments below:
a. Conversion Costs
At the NOPR Stage, several
stakeholders pointed out high capital
costs and intense redesign efforts would
be required by the proposed standards.
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Hoshizaki commented that many of the
design options suggested in this
rulemaking would require
manufacturers to modify or buy new
tooling and grow packaging, pallets, and
conveyor belts to accommodate larger
machines. Hoshizaki noted that these
costs would compound to over $20
million in the first year. (Hoshizaki, No.
86 at p. 7–8) Ice-O-Matic commented
that DOE should directly consider the
capital expenditures associated with
tooling changes as it is a discrete
expense that is not planned from year to
year. (Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 88)
As suggested by Ice-O-Matic, DOE
does consider conversion expenses to be
one-time expenditures that are not
planned from year-to-year. DOE models
conversion investments, including
capital expenditures, as occurring
between the announcement year and
standards year. These investments result
in decreases in operating profit, free
cash flow, and INPV. DOE’s conversion
cost estimates account for all production
line modifications associated with the
design options considered in the
engineering analysis including changes
in conveyor, equipment, and tooling.
For the final rule, DOE made changes to
the considered design options based on
feedback from the industry. DOE
believes the changes in design options
will reduce the capital requirements on
industry.
Several manufacturers noted that a
significant portion of their product lines
would require redesign in order to meet
the standard levels proposed in the
NOPR. Specifically, Manitowoc
commented that 90% of its models
would require a major redesign to meet
the proposed standards. (Manitowoc,
No. 92 at p. 2–3) Similarly, Hoshizaki
commented that about 80% of their
continuous type units would not be able
to meet the proposed standards.
(Hoshizaki, Public Meeting Transcript,
No. 70 at p. 74) Hoshizaki noted in a
written comment that over 75% of units
on the market will be unable to meet the
proposed standard. (Hoshizaki, No. 86
at p. 1) Scotsman commented that 97%
of their product line would need to be
replaced in order to achieve the
proposed efficiency levels. (Scotsman,
No. 85 at p. 2b) Emerson estimated 70%
of the batch ice machines would need
some amount of redesign in order to
meet the proposed minimum efficiency
levels at the NOPR stage. (Emerson, No.
122 at p. 1) AHRI commented that 99%
of the existing batch type market would
be eliminated if the proposed TSL 3
became effective and that the impact of
NOPR TSL 3 would lead to industry
consolidation, loss of jobs, and loss of
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international sales. (AHRI, No. 93 at p.
10–12) NAFEM noted general concerns
about product obsolescence at the NOPR
levels. (NAFEM, No. 82 at p. 2)
Between the NOPR and the Final
Rule, DOE revised and updated its
analysis based on stakeholders
comments received at the NOPR public
meeting, in additional manufacturer
interviews, and in written responses to
the NOPR and NODA. These updates
included changes in its approach to
calculating the energy use associated
with groups of design options, changes
in inputs for calculations of energy use
and equipment manufacturing cost, and
consideration of space-constrained
applications. In response to the NOPR
and NODA comments, DOE adjusted the
design options it considered to reduce
impacts on the industry. A discussion of
these changes can be found in section
IV.D.3. After applying the change to the
analyses, the efficiency levels that DOE
determined to be cost-effective changed
considerably. These revised TSLs are
presented in section V.A.
When compared to the NOPR levels,
DOE believes the revised levels
proposed in section V.A will reduce the
burdens on industry. Table IV.33 below
presents the portion of model that DOE
estimates would require redesign at the
various final rule TSLs.
TABLE IV.33—PORTION OF INDUSTRY MODELS REQUIRING REDESIGN AT FINAL RULE TSLS
Percent of models failing at each TSL
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
Batch ................................................................................................................................
Continuous .......................................................................................................................
27%
29
39%
41
51%
55
66%
55
84%
78
100%
100
Total ..........................................................................................................................
28
40
52
63
82
100
b. Cumulative Regulatory Burden
NRA and NAFEM both commented
that DOE should consider the impacts of
the cumulative regulatory burden of
rulemakings, including energy
conservation standards for CRE and
walk-in units as well as EPA
rulemakings on refrigerants, and
standards imposed nearly
simultaneously on equipment
manufacturers. (NRA, No. 69 at pp. 3–
4) (NAFEM, No. 82 at pp. 6–7)
DOE is instructed to consider all
Federal, product-specific burdens that
go into effect within 3 years of the
compliance date of this final rule. The
list of other standards considered in the
cumulative regulatory burden analysis
can be found in section V.B.2.g. DOE
has included the energy conservation
standard final rules for walk-in coolers
and freezers final rule and the
commercial refrigeration equipment
final rule. DOE has not included the
EPA SNAP rulemaking in this analysis.
Because that rulemaking is in the NOPR
stage and is not finalized at this time,
any estimation of the impact or effective
dates would be speculative.
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c. SNAP and Compliance Date
Considerations
AHRI stated that the burden imposed
by a potential changes in refrigerants is
significant and will require major
redesign just to maintain current
efficiency levels. (AHRI, No. 168 at p. 5)
AHRI urged DOE to extend the
compliance period to five years or put
a hold on the ACIM standards
rulemaking until the SNAP refrigerants
are finalized in order to avoid another
redesign during the compliance period
of the amended ACIM energy
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conservation standard. (AHRI, No. 70 at
p. 16) Emerson also supported the idea
of DOE starting the three-year
compliance period after EPA finalizes a
decision on refrigerants, allowing
manufactures of components and
equipment to re-design for both energy
efficiency and low-GWP refrigerants in
one design cycle. (Emerson, No. 122 at
p.1) Ice-O-Matic proposed either a five
year compliance period for the NODA
TSL 3 or that DOE chose a lower
standard level. (Ice-O-Matic, No. 121 at
p. 2) Manitowoc stated that commercial
ice makers are not within the current
scope of the SNAP NOPR, however it
believes that ice makers could be
affected by a subsequent rulemaking.
Furthermore, Manitowoc noted that
even if there is no action on ice makers,
the component suppliers to the ice
maker industry (including suppliers of
compressors, expansion valves, and heat
exchangers) will be focusing their efforts
on supporting the transition to SNAP
refrigerants. Consequently, the
commercial ice maker industry will be
affected even if it is not directly covered
by EPA rules. Manitowoc also
supported a course of action to reduce
the risk of multiple redesigns due to the
refrigerant changes and an amended
energy conservation standard.
(Manitowoc, No. 126 at p. 3) NEEA
expressed their support for DOE’s
current refrigerant-neutral position.
(NEEA, No. 91 at p. 2)
Since the SNAP rulemaking is in the
NOPR stage and not finalized at this
time, any estimation of the impact or
effectives dates would be speculative,
however in its August 6, 2014 proposal,
EPA did not list ACIM as a product that
would be impacted by forthcoming
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Total
regulations (82 FR 46126). DOE cannot
speculate on the outcome of a
rulemaking in progress and can only
consider in its rulemakings regulations
that are currently in effect. Therefore,
DOE has not included possible
outcomes of a potential EPA SNAP
rulemaking.
In response to the request that DOE
extend the compliance date period for
automatic commercial ice makers
beyond the 3 years specified by the
NOPR, as stated in section IV.A.2, DOE
has determined that the 3 year
compliance period is adequate and is
not extending the compliance date for
ACIMs. In response to AHRI’s comment
that DOE should put a hold on the
ACIM standards rulemaking until the
SNAP refrigerants are finalized, EPCA
prescribes that DOE must issue a final
rule establishing energy conservation
standards for automatic commercial ice
makers not later than January 1, 2015
and DOE does not have the authority to
alter this statutory mandate. (42 U.S.C.
6313(d)(3))
d. ENERGY STAR
Manitowoc and Hoshizaki noted that
the proposed standard bypasses the
ENERGY STAR level (Manitowoc,
Public Meeting Transcript, No. 70 at p.
74; Hoshizaki, No. 86 at p. 1)
Manitowoc expressed concern that, if
efficiency standards were raised to the
level proposed in the NOPR, there
would be no more room for an ENERGY
STAR category, which would be
disruptive to the industry. (Manitowoc,
Public Meeting Transcript, No. 70 at p.
74)
DOE acknowledges the importance of
the ENERGY STAR program and of
understanding its interaction with
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energy efficiency standards. However,
EPCA requires DOE to establish energy
conservation standards at the maximum
level that is technologically feasible and
economically justified. The standard
level considered in this final rule is
estimated to reduce cumulative source
energy usage by 8% percent over the
baseline, for products purchased in
2018–2047. Comparatively, the maxtech level is estimated to reduce
cumulative source energy usage by 14%
percent over the baseline for the same
time period (refer to section V.B.3 for a
complete discussion of energy savings).
As such, the standard level continues to
leave room for ENERGY STAR rebate
programs, and therefore new ENERGY
STAR levels could be reestablished once
compliance with these standards is
required.
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e. Request for DOE and EPA
Collaboration
Hoshizaki commented that during a
previous round of refrigerant
changeovers, it took over five years to
make the appropriate changes to their
product line and that it would take even
longer this time due to the highly
flammable refrigerant alternatives under
consideration that would require
additional redesign work. Hoshizaki
requested that DOE and EPA work
together to ensure that manufacturers
are not unduly burdened with standards
from both agencies. (Hoshizaki, No. 86
at p. 6–7)
DOE recognizes that the combined
effects of recent or impending
regulations may have serious
consequences for some manufacturers,
groups of manufacturers, or an entire
industry. As such, DOE conducts an
analysis of the cumulative regulatory
burden as part of its rulemakings
pertaining to equipment efficiency. As
stated previously, however, DOE cannot
speculate on the outcome of a
rulemaking in progress and can only
consider in its rulemakings regulations
that are currently in effect. If a
manufacturer believes that its design is
subjected to undue hardship by
regulations, the manufacturer may
petition DOE’s Office of Hearing and
Appeals (OHA) for exception relief or
exemption from the standard pursuant
to OHA’s authority under section 504 of
the DOE Organization Act (42 U.S.C.
7194), as implemented at subpart B of
10 CFR part 1003. OHA has the
authority to grant such relief on a caseby-case basis if it determines that a
manufacturer has demonstrated that
meeting the standard would cause
hardship, inequity, or unfair
distribution of burdens.
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f. Compliance With Refrigerant Changes
Could Be Difficult
NAFEM commented that municipal
and state regulations and codes may
make it difficult to comply with
proposed EPA refrigerant regulations in
some localities and could create
hardship for manufacturers. (NAFEM,
No. 82 at p. 7)
This comment relates to proposed
EPA refrigerant regulations, and is
beyond the scope of this rulemaking.
DOE has forwarded the comment to
EPA’s Stratospheric Protection Division.
g. Small Manufacturers
NAFEM notes that the proposed rule
has a disparate impact on small
businesses because commercial ice
makers are largely manufactured by
small businesses. (NAFEM, No. 82 at p.
5) AHRI agreed that this rulemaking has
impacts on small businesses and
requested DOE account for all small
ACIM manufacturers. (AHRI, No. 93 at
p. 12)
DOE recognizes the potential for this
rule to affect small businesses. As a
result, DOE presented a small business
manufacturer sub-group analysis in the
NOPR stage and in this final rule notice.
DOE used industry trade association
membership directories, public product
databases, individual company Web
sites, and other market research tools to
establish a draft list of covered small
manufacturers. DOE presented its draft
list of covered small manufacturers to
stakeholders and industry
representatives and asked if they were
aware of any other small manufacturers
that should be added to the list during
manufacturer interviews and at DOE
public meetings. DOE identified seven
small manufacturers at the NOPR stage.
Stakeholders did not provide any
information in interviews or comments
that identified additional small
manufacturers of automatic commercial
ice makers. As discussed in section
VI.B, DOE applied the small business
size standards published by the SBA to
determine whether a company is
considered a small manufacturer. The
SBA defines a small business for NAICS
333415 ‘‘Air-Conditioning and Warm
Air Heating Equipment and Commercial
and Industrial Refrigeration Equipment
Manufacturing’’ as having 750 or fewer
employees. The 750-employee threshold
includes all employees in a business’s
parent company and any other
subsidiaries. Given the lack of
additional new information, DOE
maintains that there are seven small
business manufacturers of the covered
product in the Final Regulatory
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Fmt 4701
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Flexibility Analysis, found in section
VI.B.
NAFEM did not provide any data
supporting the suggestion that the
majority of domestic ice maker sales are
from small manufacturers. Based on a
2008 study by Koeller & Company,55
DOE understands that the ACIM market
is dominated by four manufacturers
who produce approximately 90 percent
of the automatic commercial ice makers
for sale in the United States. The four
major manufacturers with the largest
market share are Manitowoc, Scotsman,
Hoshizaki, and Ice-O-Matic; none of
which are consider small business
manufacturers. The remaining 12 large
and small manufacturers account for ten
percent of domestic sales. Thus, DOE
disagrees with NAFEM’s statement that
a majority of sales are from small
manufacturers.
h. Large Manufacturers
Scotsman commented that DOE’s
INPV analysis ignores manufacturers’
current financial stability and noted that
the impacts on large manufacturers
could be significantly more severe than
the average. (Scotsman, No. 85 at p.6b)
The MIA does not forecast the
financial stability of individual
manufacturers. The MIA is an industrylevel analysis. Inherent to this analysis
is that fact that not all industry
participants will perform equally.
i. Negative Impact on Market Growth
Follett and Hoshizaki commented that
more stringent standards have an
adverse impact on innovation and
development of new products. Follett
commented that DOE’s analysis must
account for the lost opportunity to
initiate growth projects that would
expand the market. (Follett, No. 84 at
p.10) (Hoshizaki, No.86 at p.4) NRA
commented that the cost of R&D would
be passed on to end-users, causing them
to delay purchasing new equipment and
thus negatively affecting the ice
machine industry. (NRA, No. 69 at p. 4)
The MIA uses the annual shipments
forecast from the Shipment’s Analysis
as an input in the GRIM. The Shipments
Analysis provides the base case
shipments as well as standards case
shipments. The analysis uses data from
AHRI, ENERGY STAR, and U.S. Census
Bureau’s Current Industrial Reports
(CIR) to estimate historical shipments
for automatic commercial ice makers.
Future shipments are broken down into
replacement units based on a stock
accounting model; new sales based on
55 Koeller, John, P.E., and Herman Hoffman, P.E.
A Report on Potential Best Management Practices.
Rep. The California Urban Water Conservation
Council, n.d. Web. 19 May 2014.
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projections of new construction activity
from AEO2014. More detail on this
methodology can be found in section
IV.H.1. DOE’s analysis does not
speculate on additional shipments that
are the result of ‘‘growth projects.’’
Manufacturers did not provide
estimations of these growth levels or
justification for such growth levels.
Thus, DOE was not able to include such
growth factors in its models.
mstockstill on DSK4VPTVN1PROD with RULES2
j. Negative Impact on Non-U.S. Sales
Follett added that the additional cost
of efficient components would impact
non-U.S. sales. (Follett, No. 84 at p.7)
Ice-O-Matic commented that they can’t
afford designs that can only be sold in
North America and that they will lose
global busines. (Ice-O-Matic, No. 70 at
p.308) Scotsman stated it will be a
challenge to meet DOE efficiency
thresholds, the EPA SNAP regulations
and EU regulations with common
equipment platforms. Scotsman
continued that the regulations will make
it difficult for domestic manufacturers
to compete in the global market, where
the customers’ primary decision
criterion is sales price. (Scotsman,
No.125 at p. 2–3) Scotsman requested
DOE’s analysis account for the impact
that regulations will have on
manufacturers’ ability to compete in a
global market against cheaper products
not governed by DOE standards.
(Scotsman, No.70 at p.43–44)
The standards in this final rule only
cover equipment placed into commerce
in the domestic market, and as such, do
not restrict manufacturers from selling
products below the new and amended
standards in foreign markets. DOE notes
that manufacturers make products today
that meet the standard set by the 2005
energy conservation standard for
automatic commercial ice makers and
are able to compete against
manufacturers with production lines in
lower cost countries. In their comments,
manufacturers did not provide any
information as to which product models
or which efficiencies are sold into
international markets. If the models sold
internationally have efficiencies that
exceed the amended standard, then
manufacturers will likely see a
production cost decrease as sales roll-up
to the new standard and production
volumes increase. It is also possible that
manufacturer production costs could
increase marginally due to small
production runs. However, stakeholders
did not provide enough information for
DOE to model the price-sensitivity of
the foreign market.
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k. Employment
Ice-O-Matic commented that, if the
market loses net present value,
companies are not going to accept less
profit, and so there’s no way they can
employ the same number of people
unless they reduce their pay. (Ice-OMatic, No. 70 at p.313) In the NOPR
public meeting, AHRI, Scotsman, and
Ice-o-matic noted concerns about DOE
direct employment estimates being too
low. (No. 70 at p.320–330)
DOE analyzes the potential impacts of
the energy conservation standard on
direct production labor in section
V.B.2.d. This analysis estimates the
production head count, including
production workers up to the linesupervisor level who are directly
involved in fabricating and assembling
a product within an original equipment
manufacturer (OEM) facility. It does not
account for sales, engineering,
management, and all other workers who
are not directly producing and
assembling product. DOE presents an
upper and lower bound for direct
employment. DOE does not assert that
employment will remain steady
throughout the analysis period.
In the NOPR, DOE clearly stated the
assumptions that contributed to its
estimate of direct production
employment. These assumptions
included: Unit sales, labor content per
unit sold, average hourly wages for
production workers, and annual hours
worked by production workers. The
calculation of production employment
is discussed in detail in chapter 12 of
the TSD, section 12.7. In the NOPR and
NODA comments, DOE did not receive
any comments on these key production
employment assumptions. However,
DOE updated its final rule analysis
based on a revised engineering analysis,
shipments analysis, and trial standard
levels.
l. Compliance With 12866 and 13563
NAFEM commented that DOE is in
violation of Executive Orders 12866 and
13563. (NAFEM, No. 82 at p.8) DOE has
fulfilled the obligations required by
Executive Orders 12866 and 13563.
Additional information can be found in
section VI of this preamble.
m. Warranty Claims
Scotsman noted concern that the MIA
results had not ‘‘accurately accounted
for warranty increases’’. (Scotsman,
No.125 at p.3) Specifically, it noted that
an ECM condenser fan motor would cost
significantly more than its current
component.
DOE did not explicitly factor in
changes in warranty set-asides or
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Fmt 4701
Sfmt 4700
4711
payments. In interviews, DOE requested
manufacturers highlight key concerns
related to the rulemaking. Warranty
concerns were not cited as a key issue.
In order for DOE to account for changes
in warranty costs, manufacturers would
need to provide data on current product
failure rates, causes of failure and
related repair costs, expected future
warranty rates, and changes in expected
repair costs. Insufficient information
was provided to model a change in
warranty reserve and warranty pay out.
Aside from the Scotsman data point on
the cost of ECM fan motors, no other
manufacturer supplied hard data related
to warranty expenses. As a result, DOE
did not incorporate a change in
warranty rate in its analysis.
n. Impact to Suppliers, Distributors,
Dealers, and Contractors
AHRI commented that DOE must
perform analyses to assess the impacts
of the final rule on component
suppliers, distributors, dealers, and
contractors. Policy Analyst also
suggested that DOE assess whether
suppliers are affected by the proposed
standard. (Policy Analyst, No. 75 at p.
10) The MIA assesses the impact of
amended energy conservation standards
on manufacturers of automatic
commercial ice makers. Analysis of the
impacts on distributors, dealers, and
contractors as a result of energy
conservation standards on
manufacturers of automatic commercial
ice makers falls outside the scope of this
analysis.
Impacts on component suppliers
might arise if manufacturers switched to
more-efficient components, or if there
was a substantial reduction in sales
orders following new or amended
standards. In public comments and in
confidential interviews, manufacturers
expressed that given their low
production volumes, the automatic
commercial ice maker manufacturing
industry has little influence over
component suppliers relative to other
commercial refrigeration equipment
industries. (Manitowoc, Preliminary
Analysis Public Meeting Transcript, No.
42 at pp. 14–15). It follows that energy
conservation standards for automatic
commercial ice makers would have little
impact on component suppliers given
their marginal contribution to overall
commercial refrigeration component
demand.
K. Emissions Analysis
In the emissions analysis, DOE
estimated the reduction in power sector
emissions of CO2, NOX, SO2, and Hg
from potential energy conservation
standards for automatic commercial ice
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mstockstill on DSK4VPTVN1PROD with RULES2
makers. 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), 77 FR 49701
(Aug. 17, 2012)) the FFC analysis
includes impacts on emissions of CH4
and N2O, both of which are recognized
as greenhouse gases (GHGs).
DOE primarily conducted the
emissions analysis using emissions
factors for CO2 and most of the other
gases derived from data in the
AEO2014. Combustion emissions of CH4
and N2O were estimated using
emissions intensity factors published by
the Environmental Protection Agency
(EPA), GHG Emissions Factors Hub.56
DOE developed separate emissions
factors for power sector emissions and
upstream emissions. The method that
DOE used to derive emissions factors is
described in chapter 13 of the final rule
TSD.
For CH4 and N2O, DOE calculated
emissions reduction in tons and also in
terms of units of carbon dioxide
equivalent (CO2eq). Gases are converted
to CO2eq by multiplying the physical
units by the gases’ global warming
potential (GWP) over a 100-year time
horizon. Based on the Fourth
Assessment Report of the
Intergovernmental Panel on Climate
Change,57 DOE used GWP values of 28
for CH4 and 265 for N2O.
EIA prepares the AEO using NEMS.
Each annual version of NEMS
incorporates the projected impacts of
existing air quality regulations on
emissions. AEO2014 generally
represents current legislation and
environmental regulations, including
recent government actions, for which
implementing regulations were
available as of October 31, 2013.
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
56 https://www.epa.gov/climateleadership/
inventory/ghg-emissions.html.
57 Intergovernmental Panel on Climate Change.
Climate Change 2013: The Physical Science Basis.
Contribution of Working Group I to the Fifth
Assessment Report of the Intergovernmental Panel
on Climate Change. 2013. Stocker, T.F., D. Qin, G.K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A.
Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.).
Cambridge University Press, Cambridge, United
Kingdom and New York, NY, USA. Chapter 8.
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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 U.S. Environmental
Protection Agency (EPA) by the U.S.
Court of Appeals for the District of
Columbia Circuit but it remained in
effect.58 In 2011 EPA issued a
replacement for CAIR, the Cross-State
Air Pollution Rule (CSAPR). 76 FR
48208 (August 8, 2011). On August 21,
2012, the D.C. Circuit issued a decision
to vacate CSAPR.59 The court ordered
EPA to continue administering CAIR.
The emissions factors used for this final
rule, which are based on AEO2014,
assume that CAIR remains a binding
regulation through 2040.60
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 2016, however, SO2
emissions will fall as a result of the
Mercury and Air Toxics Standards
(MATS) for power plants. 77 FR 9304
(Feb. 16, 2012). 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 non58 See North Carolina v. EPA, 550 F.3d 1176 (D.C.
Cir. 2008); North Carolina v. EPA, 531 F.3d 896
(D.C. Cir. 2008).
59 See EME Homer City Generation, LP v. EPA,
696 F.3d 7, 38 (D.C. Cir. 2012).
60 On April 29, 2014, the U.S. Supreme Court
reversed the judgment of the D.C. Circuit and
remanded the case for further proceedings
consistent with the Supreme Court’s opinion. The
Supreme Court held in part that EPA’s methodology
for quantifying emissions that must be eliminated
in certain states due to their impacts in other
downwind states was based on a permissible,
workable, and equitable interpretation of the Clean
Air Act provision that provides statutory authority
for CSAPR. See EPA v. EME Homer City Generation,
No 12–1182, slip op. at 32 (U.S. April 29, 2014).
Because DOE is using emissions factors based on
AEO2014 for today’s final rule, the analysis
assumes that CAIR, not CSAPR, is the regulation in
force. The difference between CAIR and CSAPR is
not relevant for the purpose of DOE’s analysis of
SO2 emissions.
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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. AEO2014 assumes that, in
order to continue operating, coal plants
must have either flue gas
desulfurization or dry sorbent injection
systems installed by 2016. Both
technologies are used to reduce acid gas
emissions, and also reduce SO2
emissions. Under the MATS, emissions
will be far below the cap established by
CAIR, 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 2016 and beyond.
CAIR established a cap on NOX
emissions in 28 eastern States and the
District of Columbia.61 Energy
conservation standards are expected to
have little effect on NOX emissions in
those States covered by CAIR 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 this
final rule 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
AEO2014, which incorporates the
MATS.
In response to the NOPR, DOE
received one comment specifically
about measuring environmental
benefits. Policy Analyst stated that DOE
should commit to measuring
environmental benefits and reductions
in energy usage as a result of these
standards. (Policy Analyst, No. 75 at p.
10) DOE has invested a great deal of
time and effort in quantifying the energy
reductions and environmental benefits
of this rule, as described in this section
and as described in the discussion of the
61 CSAPR also applies to NO and it would
X
supersede the regulation of NOX under CAIR. As
stated previously, the current analysis assumes that
CAIR, not CSAPR, is the regulation in force. The
difference between CAIR and CSAPR with regard to
DOE’s analysis of NOX emissions is slight.
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NIA (IV.H). Given the dispersed nature
of automatic commercial ice makers on
customer premises across the country,
actual physical measurement of the
energy savings and environmental
benefits would be a large and costly
undertaking which would likely not
yield useful results. However, DOE is
committed to working with other
governmental agencies to continue
developing tools for quantifying the
environmental benefits of proceedings
such as this ACIM rulemaking. The
discussion that follows of the
development of the social cost of carbon
(SCC) is the prime example of these
efforts.
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L. Monetizing Carbon Dioxide and Other
Emissions Impacts
As part of the development of the
standards in this final rule, DOE
considered the estimated monetary
benefits 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 equipment 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 this final rule, DOE is relying on
a set of values for the social cost of
carbon (SCC) that was developed by an
interagency process. The basis for these
values is summarized below, and a more
detailed description of the
methodologies used is provided as an
appendix to chapter 14 of the final rule
TSD.
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 CO2. A domestic SCC value is
meant to reflect the value of damages in
the United States resulting from a unit
change in CO2 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
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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. 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.
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 CO2
emissions, the analyst faces a number of
serious challenges. A report from the
National Research Council 62 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 limits of both
quantification and monetization, SCC
estimates can be useful in estimating the
social benefits of reducing CO2
emissions. 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
62 National Research Council. Hidden Costs of
Energy: Unpriced Consequences of Energy
Production and Use. National Academies Press:
Washington, DC (2009).
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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.
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. Development of Social Cost of Carbon
Values
In 2009, an interagency process was
initiated to offer a preliminary
assessment of how best to quantify the
benefits from reducing CO2 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
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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 higher-
than-expected impacts from temperature
change further out in the tails of the
SCC distribution. The values grow in
real terms over time. 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,
although preference is given to
consideration of the global benefits of
reducing CO2 emissions. Table IV.34
presents the values in the 2010
interagency group report,63 which is
reproduced in appendix 14A of the
TSD.
TABLE IV.34—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050
[2007 dollars per metric ton CO2]
Discount rate
(%)
Year
3
2.5
3
Average
2010
2015
2020
2025
2030
2035
2040
2045
2050
5
Average
Average
95th percentile
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
The SCC values used for this
rulemaking were generated using the
most recent versions of the three
integrated assessment models that have
been published in the peer-reviewed
literature.64 (See appendix 14–B of the
final rule TSD for further information.)
4.7
5.7
6.8
8.2
9.7
11.2
12.7
14.2
15.7
Table IV.35 shows the updated sets of
SCC estimates in 5-year increments from
2010 to 2050. The full set of annual SCC
estimates between 2010 and 2050 is
reported in appendix 14–B of the final
rule TSD. The central value that
emerges is the average SCC across
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
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.
TABLE IV.35—ANNUAL SCC VALUES FROM 2013 INTERAGENCY UPDATE, 2010–2050
[2007 dollars per metric ton CO2]
Discount rate
(%)
Year
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3
2.5
3
Average
2010
2015
2020
2025
2030
2035
2040
2045
2050
5
Average
Average
95th Percentile
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
63 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. www.
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11
12
14
16
19
21
24
26
whitehouse.gov/sites/default/files/omb/inforeg/foragencies/Social-Cost-of-Carbon-for-RIA.pdf.
64 Technical Update of the Social Cost of Carbon
for Regulatory Impact Analysis Under Executive
Order 12866. Interagency Working Group on Social
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37
43
47
52
56
61
66
71
51
57
64
69
75
80
86
92
97
89
109
128
143
159
175
191
206
220
Cost of Carbon, United States Government. May
2013; revised November 2013.
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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 in section
IV.L.1.a 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 analytic challenges that are
being 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 2013$ using the Gross
Domestic Product price deflator. For
each of the four cases of SCC values, the
values for emissions in 2015 were $12.0,
$40.5, $62.4, and $119 per metric ton of
CO2 avoided. 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.
In responding to the NOPR, many
commenters questioned why DOE
quantified the emissions. Commenters
also questioned the scientific and
economic basis of the SCC values.
Scotsman stated they did not
understand the logic of predicting
emissions reductions associated with a
product with such a limited population
relative to national average energy
consumption. (Scotsman, No. 95 at page
7) As stated earlier in the SCC
discussion, DOE quantifies emissions
reductions as one of the societal impacts
of all standards in accordance with
section 1(b) of Executive Order 12866.
A number of stakeholders stated that
DOE should not use SCC values to
establish monetary figures for emissions
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reductions until the SCC undergoes a
more rigorous notice, review, and
comment process. (AHRI, No. 93 at pp.
13–14; The Associations, No. 77 at p. 4)
The Cato Institute commented that SCC
should be barred from use until its
deficiencies are rectified. (Cato Institute,
No. 74 at p. 1) Similarly, IER stated that
SCC should no longer be used in
Federal regulatory analysis and
rulemakings. (IER, No. 83 at p. 2) In
contrast, IPI et al. affirmed that current
SCC values are sufficiently robust and
accurate for continued use in regulatory
analyses. (IPI, No. 78 at p. 1)
In conducting the interagency process
that developed the SCC values,
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. Key uncertainties and
model differences transparently and
consistently inform the range of SCC
estimates. These uncertainties and
model differences are discussed in the
interagency working group’s reports,
which are reproduced in appendix 14A
and 14B of the TSD, as are the major
assumptions. The 2010 SCC values have
been used in a number of Federal
rulemakings upon which the public had
opportunity to comment. In November
2013, the OMB announced a new
opportunity for public comment on the
TSD underlying the revised SCC
estimates. See 78 FR 70586 (Nov. 26,
2013). OMB is currently reviewing
comments and considering whether
further revisions to the 2013 SCC
estimates are warranted. DOE stands
ready to work with OMB and the other
members of the interagency working
group on further review and revision of
the SCC estimates as appropriate.
IER commented that the SCC is
inappropriate for use in federal
rulemakings because it is based on
subjective modeling decisions rather
than objective observations and because
it violates OMB guidelines for accuracy,
reliability, and freedom from bias. (IER,
No. 83 at p. 2) The General Accounting
Office (GAO) was asked to review the
Interagency Working Group’s (IWG)
development of SCC estimates,65 and
noted that OMB and EPA participants
reported that the IWG documented all
major issues consistent with Federal
standards for internal control. The GAO
also found, according to its document
review and interviews, that the IWG’s
development process followed three
principles: (1) It used consensus-based
decision making; (2) it relied on existing
65 www.directives.doe.gov/directives-documents/
400-series/0411.2-APolicy.
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academic literature and models; and (3)
it took steps to disclose limitations and
incorporate new information. Further,
DOE has sought to ensure that the data
and research used to support its policy
decisions—including the SCC values—
are of high scientific and technical
quality and objectivity, as called for by
the Secretarial Policy Statement on
Scientific Integrity.66 See section VI.L
for DOE’s evaluation of this final rule
and supporting analyses under the DOE
and OMB information quality
guidelines.
The Cato Institute stated that the
determination of the SCC is discordant
with the best scientific literature on the
equilibrium climate sensitivity and the
fertilization effect of CO2—two critically
important parameters for establishing
the net externality of CO2 emissions.
(Cato Institute, No. 74 at pp. 1, 12–15)
The revised estimates that were issued
in November 2013 are based on the best
available scientific information on the
impacts of climate change. The issue of
equilibrium climate sensitivity is
addressed in section 14A.4 of appendix
14A in the TSD. The EPA, in
collaboration with other Federal
agencies, continues to investigate
potential improvements to the way in
which economic damages associated
with changes in CO2 emissions are
quantified.
AHRI commented that the GHG
emissions reductions benefits may be
overestimated because the DOE’s
analysis does not take into
consideration EPA’s planned regulation
of GHG emissions from power plants,
which would affect the estimated
carbon emissions. AHRI suggested DOE
conduct additional research on the
impact of EPA’s regulations on SCC
values. (AHRI, No. 93 at p. 14) As noted
in section IV.L.1, DOE participates in
the IWG process. DOE believes that if
necessary and appropriate the IWG will
perform research as suggested by AHRI,
but notes that results from any such
research will not be timely for inclusion
in this rulemaking. With respect to
AHRI’s comment about accounting for
EPA’s planned regulations, DOE cannot
account for regulations that are not
currently in effect because whether such
regulations will be adopted and their
final form are matters of speculation at
this time.
The Cato Institute commented that the
IWG appears to violate the directive in
OMB Circular A–4, which states, ‘‘Your
analysis should focus on benefits and
costs that accrue to citizens and
residents of the United States. Where
you choose to evaluate a regulation that
66 www.gao.gov/products/GAO-14-663.
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is likely to have effects beyond the
borders of the United States, these
effects should be reported separately.’’
The Cato Institute stated that instead of
focusing on domestic benefits and
separately reporting any international
effects, the IWG only reports the global
costs and makes no determination of the
domestic costs. (Cato Institute, No. 74 at
pp. 2–3) IER expressed similar concerns
about the IWG’s use of a global
perspective in reporting SCC estimates.
(IER, No. 83 at pp. 16–17) AHRI
commented that either domestic or
global costs and benefits should be
considered, but not both. (AHRI, No. 93
at p. 14)
Although the relevant analyses
address both domestic and global
impacts, the interagency group has
determined that it is appropriate to
focus on a global measure of SCC
because of the distinctive nature of the
climate change problem, which is
highly unusual in at least two respects.
First, it involves a global externality:
Emissions of most greenhouse gases
contribute to damages around the world
when they are emitted in the United
States. Second, climate change presents
a problem that the United States alone
cannot solve. The issue of global versus
domestic measures of the SCC is further
discussed in appendix 14A of the TSD.
AHRI stated that the costs of the
proposed rule are calculated over the
course of a 30-year period, while
avoided SCC benefit is calculated over
a 300-year period. AHRI further
commented that longer-term (i.e., 30–
300 years) impacts of regulations on
businesses are unknown, and should be
studied. (AHRI, No. 93 at p. 14) For the
analysis of national impacts of
standards, DOE considers the lifetime
impacts of equipment shipped in a 30year period, with energy and cost
savings impacts aggregated until all of
the equipment shipped in the 30-year
period is retired. With respect to the
valuation of CO2 emissions reductions,
the SCC estimates developed by the
IWG are meant to represent the full
discounted value (using an appropriate
range of discount rates) of emissions
reductions occurring in a given year.
Thus, DOE multiplies the SCC values
for achieving the emissions reductions
in each year of the analysis by the
carbon reductions estimated for each of
those same years. Neither the costs nor
the benefits of emissions reductions
outside the analytic time frame are
included in the analysis.
2. Valuation of Other Emissions
Reductions
As noted in section IV.K, DOE has
taken into account how new or
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amended energy conservation standards
would reduce NOX emissions in those
22 States not affected by emissions caps.
DOE estimated the monetized value of
NOX emissions reductions resulting
from each of the TSLs considered for
this final rule based on estimates found
in the relevant scientific literature.
Estimates of monetary value for
reducing NOX from stationary sources
range from $476 to $4,893 per ton
(2013$).67 DOE calculated monetary
benefits using a medium value for NOX
emissions of $2,684 per short ton (in
2013$), and real discount rates of 3
percent and 7 percent.
DOE is evaluating appropriate
monetization of avoided SO2 and Hg
emissions in energy conservation
standards rulemakings. It has not
included such monetization in the
current analysis.
M. Utility Impact Analysis
The utility impact analysis estimates
several effects on the power generation
industry that would result from the
adoption of new or amended energy
conservation standards. In the utility
impact analysis, DOE analyzes the
changes in electric installed capacity
and generation that result for each TSL.
The utility impact analysis uses a
variant of NEMS,68 which is a public
domain, multi-sectored, partial
equilibrium model of the U.S. energy
sector. DOE uses a variant of this model,
referred to as NEMS–BT,69 to account
for selected utility impacts of new or
amended energy conservation
standards. DOE’s analysis consists of a
comparison between model results for
the most recent AEO Reference Case and
for cases in which energy use is
decremented to reflect the impact of
potential standards. The energy savings
inputs associated with each TSL come
from the NIA. Chapter 15 of the final
67 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.
Available at: www.whitehouse.gov/sites/default/
files/omb/assets/omb/inforeg/2006_cb/2006_cb_
final_report.pdf.
68 For more information on NEMS, refer to the
U.S. Department of Energy, Energy Information
Administration documentation. A useful summary
is National Energy Modeling System: An Overview
2003, DOE/EIA–0581(2003), March, 2003.
69 DOE/EIA approves use of the name ‘‘NEMS’’ to
describe only an official version of the model
without any modification to code or data. Because
this analysis entails some minor code modifications
and the model is run under various policy scenarios
that are variations on DOE/EIA assumptions, DOE
refers to it by the name ‘‘NEMS–BT’’ (‘‘BT’’ is DOE’s
Building Technologies Program, under whose aegis
this work has been performed).
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rule TSD describes the utility impact
analysis.
DOE received one comment about the
utility impact analysis. Policy Analyst
commented that DOE should commit to
measuring the effects of these energy
savings on the security, reliability, and
costs of maintaining the nation’s energy
system. (Policy Analyst, No. 75 at p. 10)
As discussed in Chapter 15 of the TSD,
DOE does quantify the effects of the
energy savings on the nation’s energy
system. Given the widely dispersed
nature of automatic commercial ice
makers on customer premises across the
country, physically measuring the
impacts would be time-consuming and
costly and would likely not result in
useful measurements of the effects. DOE
has over the course of many energy
conservation standards rulemakings
developed the tools and processes used
in this rulemaking to estimate the
impacts on the electric utility system,
and those impacts are discussed in
Chapter 15 of the TSD.
N. Employment Impact Analysis
Employment impacts from new or
amended energy conservation standards
include direct and indirect impacts.
Direct employment impacts, which are
addressed in the MIA, are any changes
in the number of employees of
manufacturers of the equipment subject
to standards. Indirect employment
impacts, which are assessed as part of
the employment impact analysis, are
changes in national employment that
occur due to the shift in expenditures
and capital investment caused by the
purchase and operation of moreefficient equipment. Indirect
employment impacts from standards
consist of the jobs created or eliminated
in the national economy due to (1)
reduced spending by end users on
energy; (2) reduced spending on new
energy supply by the utility industry; (3)
increased customer spending on the
purchase of new equipment; and (4) the
effects of those three factors throughout
the economy.
One method for assessing the possible
effects on the demand for labor of such
shifts in economic activity is to compare
sector employment statistics developed
by the Labor Department’s Bureau of
Labor Statistics (BLS). BLS regularly
publishes its estimates of the number of
jobs per million dollars of economic
activity in different sectors of the
economy, as well as the jobs created
elsewhere in the economy by this same
economic activity. Data from BLS
indicate that expenditures in the utility
sector generally create fewer jobs (both
directly and indirectly) than
expenditures in other sectors of the
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economy.70 There are many reasons for
these differences, including wage
differences and the fact that the utility
sector is more capital-intensive and less
labor-intensive than other sectors.
Energy conservation standards have the
effect of reducing customer utility bills.
Because reduced customer expenditures
for energy likely lead to increased
expenditures in other sectors of the
economy, the general effect of efficiency
standards is to shift economic activity
from a less labor-intensive sector (i.e.,
the utility sector) to more laborintensive sectors (e.g., the retail and
service sectors). Thus, based on the BLS
data alone, DOE believes net national
employment may increase because of
shifts in economic activity resulting
from amended energy conservation
standards for automatic commercial ice
makers.
For the standard levels considered in
this final rule, DOE estimated indirect
national employment impacts using an
input/output model of the U.S. economy
called Impact of Sector Energy
Technologies version 3.1.1 (ImSET).71
ImSET is a special-purpose version of
the ‘‘U.S. Benchmark National InputOutput’’ (I–O) model, which was
designed to estimate the national
employment and income effects of
energy-saving technologies. The ImSET
software includes a computer-based I–O
model having structural coefficients that
characterize economic flows among the
187 sectors. ImSET’s national economic
I–O structure is based on a 2002 U.S.
benchmark table, specially aggregated to
the 187 sectors most relevant to
industrial, commercial, and residential
building energy use. DOE notes that
ImSET is not a general equilibrium
forecasting model and understands the
uncertainties involved in projecting
employment impacts, especially
changes in the later years of the
analysis. Because ImSET does not
incorporate price changes, the
employment effects predicted by ImSET
may overestimate actual job impacts
over the long run. For the final rule,
DOE used ImSET only to estimate shortterm (through 2022) employment
impacts.
DOE received no comments
specifically on the indirect employment
impacts. Comments received were
70 See U.S. Department of Commerce—Bureau of
Economic Analysis. Regional Multipliers: A User
Handbook for the Regional Input-Output Modeling
System (RIMS II). 1992.
71 Scott, M.J., O.V. Livingston, P.J. Balducci, J.M.
Roop, and R.W. Schultz. ImSET 3.1: Impact of
Sector Energy Technologies. 2009. Pacific
Northwest National Laboratory, Richland, WA.
Report No. PNNL–18412. www.pnl.gov/main/
publications/external/technical_reports/PNNL18412.pdf.
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Jkt 235001
related to manufacturing employment
impacts, and DOE reiterates that the
indirect employment impacts estimated
with ImSET for the entire economy
differ from the direct employment
impacts in the ACIM manufacturing
sector estimated using the GRIM in the
MIA, as described at the beginning of
this section. The methodologies used
and the sectors analyzed in the ImSET
and GRIM models are different.
For more details on the employment
impact analysis and its results, see
chapter 16 of the TSD and section
V.B.3.d of this preamble.
O. Regulatory Impact Analysis
DOE prepared a regulatory impact
analysis (RIA) for this rulemaking,
which is described in chapter 17 of the
final rule 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 qualitative 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 amended
automatic commercial ice makers
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 identified the following major
policy alternatives for achieving
increased automatic commercial ice
makers efficiency:
• No new regulatory action
• Commercial customer tax credits
• Commercial customer 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. See chapter 17 of
the final rule TSD for further details.
In response to the NOPR, DOE
received comments from NAFEM stating
that NAFEM commented that DOE
failed to consider the positive role of
ENERGY STAR in the marketplace, that
the Federal Energy Management
Program (FEMP) already encourages
manufacturers to innovate and create
energy savings, the effects of local and
state initiatives, and the effects of
PO 00000
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4717
voluntary building standards that
require high efficiency products in the
marketplace. (NAFEM, No. 82 at pp. 8–
9)
In response to the NAFEM comment,
DOE notes first that FEMP and other
voluntary programs tend to use
ENERGY STAR as the efficiency target
levels for equipment classes covered by
ENERGY STAR. DOE recognizes that the
market has achieved a roughly 60percent success rate in reaching the
ENERGY STAR criteria for the time that
ENERGY STAR has covered automatic
commercial ice makers. The marketdriven accomplishments are reflected in
the distribution of shipments by
efficiency level for the base conditions,
and very much influence the results of
the analysis. The selected TSL 3 yields
a shipments-weighted average efficiency
improvement of approximately 8
percent. If all customers purchased
efficiency level 1 equipment (i.e.,
baseline equipment), the shipmentsweighted average efficiency
improvement would be over 18 percent.
The difference is attributable to the
combination of ENERGY STAR, FEMP,
utility incentive programs, incentive
programs operated by governmental
entities and others, and customer
economic decision making.
In deciding what efficiency targets to
model in the RIA, DOE noted that
modeling the new ENERGY STAR
criteria would show modest energy
savings and NPV results because, as
noted above, the baseline already
reflects the market-driven
accomplishments. Further, ENERGY
STAR changes their criteria
periodically. The first set of automatic
commercial ice maker criteria was in
effect for approximately 5 years, and the
second set became effective February 1,
2013. If the ENERGY STAR criteria are
updated again after a 5-year period, the
criteria will be revised by the
compliance date of this rule. Because
future ENERGY STAR criteria are
unknown, DOE performed the
regulatory impact analysis using TSL 3
efficiency levels matched with the 60percent ENERGY STAR success rate.
DOE believes that in performing the
analysis in this fashion, DOE was
acknowledging the ability of the
ENERGY STAR program to reach
customers and impact their decisionmaking.
V. Analytical Results
A. Trial Standard Levels
1. Trial Standard Level Formulation
Process and Criteria
DOE selected between two and seven
efficiency levels for all equipment
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
net benefits to the nation. The net
benefits to the nation also include
monetized values of emissions
reductions in addition to the customer
NPV. Where a sufficient number of
efficiency levels allow it, TSL 4 is set at
least one level below max-tech and one
level above the efficiency level with the
highest NPV. In one case, the TSL 4
efficiency level is the maximum NPV
level because the next higher level had
a negative NPV. In cases where the
maximum NPV efficiency level is the
penultimate efficiency level and the
max-tech level showed a positive NPV,
the TSL 4 efficiency level is also the
max-tech level.
classes for analysis. For all equipment
classes, the first efficiency level is the
baseline efficiency level. Based on the
results of the NIA and other analyses,
DOE selected five TSLs above the
baseline level for each equipment class
for the NOPR stage of this rulemaking.
Table V.1 shows the mapping between
TSLs and efficiency levels.
TSL 5 was selected as the max-tech
level for all equipment classes. At this
level, DOE’s analysis considered that
equipment would require use of design
options that generally are not used by
ice makers, but that are currently
commercially available; specifically
drain water heat exchangers for batch
ice makers and ECM motors for all ice
maker classes. The range of energy use
reduction at the max-tech level varies
widely with the equipment class, from
7% for IMH–W–Large–B to 33% for
SCU–A–Small–B.
TSL 4 was chosen as an intermediate
level between the max-tech level and
the maximum customer NPV level,
subject to the requirement that the TSL
4 NPV must be positive. ‘‘Customer
NPV’’ is the NPV of future savings
obtained from the NIA. It provides a
measure of the benefits only to the
customers of the automatic commercial
ice makers and does not account for the
TSL 3 was chosen to represent the
group of efficiency levels with the
highest customer NPV at a 7-percent
discount rate.
TSL 2 was selected to provide
intermediate efficiency levels between
the TSLs 1 and 3. Note that with the
number of efficiency levels available for
each equipment class, there is often
overlap between TSL levels. Thus, TSL
2 includes efficiency levels that overlap
with both TSLs 1 and 3. The intent of
TSL 2 is to provide an intermediate
level that examines in efficiency options
between TSLs 1 and 3.
TSL 1 was set equal to efficiency level
2. In the NOPR analysis, DOE set
efficiency level 2 to be equivalent to
ENERGY STAR in effect at the time DOE
started the analysis for products rated
by ENERGY STAR and to an equivalent
efficiency improvement for other
equipment classes. However, the
ENERGY STAR level for automatic
commercial ice makers has since been
revised.72 Therefore, in the NODA and
final rule analysis DOE has instead used
a more consistent 10-percent level for
efficiency level 2, representing energy
use 10 percent lower than the baseline
energy use. This level reflects but is not
fully consistent with the former
ENERGY STAR level for those classes
covered by ENERGY STAR. The new
ENERGY STAR level, defined for all aircooled equipment classes (i.s. IMH–A,
RCU, and SCU–A classes for both batch
and continuous ice makers) does not
consistently align with any of the TSLs
selected by DOE. For example, for IMH–
A batch classes, the current ENERGY
STAR level corresponds roughly to TSL
1 at 300 lb ice/24 hours, TSL 3 at 800
lb ice/24 hours, and is more stringent
than TSL 5 at 1,500 lb ice/24 hours.
Graphical comparison of the TSLs,
ENERGY STAR, and existing products is
providing in Chapter 3 of the TSL.
TABLE V.1—MAPPING BETWEEN TSLS AND EFFICIENCY LEVELS *
TSL 1
TSL 2
TSL 3
TSL 4
IMH–W–Small–B .................................
IMH–W–Med–B ...................................
IMH–W–Large–B †
IMH–W–Large–B–1 .....................
IMH–W–Large–B–2 .....................
IMH–A–Small–B ..................................
IMH–A–Large–B †
IMH–A–Large–B1 ........................
IMH–A–Large–B2 ........................
RCU–Large–B†
RCU–Large–B1 ............................
RCU–Large–B2 ............................
SCU–W–Large–B ................................
SCU–A–Small–B .................................
SCU–A–Large–B .................................
IMH–A–Small–C ..................................
IMH–A–Large–C .................................
RCU–Small–C .....................................
SCU–A–Small–C .................................
mstockstill on DSK4VPTVN1PROD with RULES2
Equipment class
Level 2 .................
Level 2 .................
Level 2 .................
Level 2 .................
Level 3 .................
Level 2 .................
Level 3 .................
Level 3 .................
Level 5.
Level 4.
Level 1 .................
Level 1 .................
Level 2 .................
Level 1 .................
Level 1 .................
Level 3 .................
Level 1 .................
Level 1 .................
Level 3A ...............
Level 1 .................
Level 1 .................
Level 3A ...............
Level 2.
Level 2.
Level 6.
Level 2 .................
Level 2 .................
Level 3 .................
Level 2 .................
Level 3A ...............
Level 3 .................
Level 4 .................
Level 3 .................
Level 5.
Level 3.
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
Level
2
2
2
2
2
2
2
2
2
.................
.................
.................
.................
.................
.................
.................
.................
.................
2
2
4
4
4
3
2
3
3
.................
.................
.................
.................
.................
.................
.................
.................
.................
2
2
5
5
5
4
3
4
4
.................
.................
.................
.................
.................
.................
.................
.................
.................
3
2
6
6
6
4
3
4
4
.................
.................
.................
.................
.................
.................
.................
.................
.................
TSL 5
4.
3.
6.
7.
6.
6.
5.
6.
6.
* For three large equipment classes—IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B—because the harvest capacity range is so wide,
DOE analyzed two typical models to model the low and the high portions of the applicable range with greater accuracy. The smaller of the two is
noted as B1 and the larger as B2.
† DOE analyzed impacts for the B1 and B2 typical units and aggregated impacts to the equipment class level.
72 ENERGY STAR Version 2.0 for Automatic
Commercial Ice Makers became effective on
February 1, 2013.
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4719
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Table V.2 illustrates the efficiency
improvements incorporated in all TSLs.
TABLE V.2—PERCENTAGE EFFICIENCY IMPROVEMENT FROM BASELINE BY TSL *
Equipment class
TSL 1
IMH–W–Small–B ..................................................................
IMH–W–Med–B ....................................................................
IMH–W–Large–B ..................................................................
IMH–W–Large–B1 ........................................................
IMH–W–Large–B2 ........................................................
IMH–A–Small–B ...................................................................
IMH–A–Large–B ...................................................................
IMH–A–Large–B1 .........................................................
IMH–A–Large–B2 .........................................................
RCU–Large–B ......................................................................
RCU–Large–B1 .............................................................
RCU–Large–B2 .............................................................
SCU–W–Large–B .................................................................
SCU–A–Small–B ..................................................................
SCU–A–Large–B ..................................................................
IMH–A–Small–C ...................................................................
IMH–A–Large–C ..................................................................
RCU–Small–C ......................................................................
SCU–A–Small–C ..................................................................
TSL 2
10.0%
10.0
0.0
0.0
0.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
TSL 3
10.0%
10.0
0.0
0.0
0.0
15.0
14.2
15.0
10.0
10.0
10.0
10.0
20.0
20.0
20.0
15.0
10.0
15.0
15.0
TSL 4
15.0%
10.0
0.0
0.0
0.0
18.1
15.2
15.8
11.8
10.0
10.0
10.0
25.0
25.0
25.0
20.0
15.0
20.0
20.0
TSL 5
15.0%
15.0
0.0
0.0
0.0
18.1
18.7
20.0
11.8
14.7
15.0
10.0
29.8
30.0
29.1
20.0
15.0
20.0
20.0
23.9%
18.1
8.1
8.3
7.4
25.5
21.6
23.4
11.8
17.1
17.3
13.9
29.8
32.7
29.1
25.7
23.3
26.6
26.6
* Percentage improvements for IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B are a weighted average of the B1 and B2 units, using
weights provided in TSD chapter 7.
Table V.3 illustrates the design
options associated with each TSL level,
for each analyzed product class. The
design options are discussed in section
IV.D.3 of this final rule and in chapter
5 of the TSD.
TABLE V.3—DESIGN OPTIONS FOR ANALYZED PRODUCTS CLASSES AT EACH TSL
Equipment class
Baseline
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
Design Options for Each TSL (options are cumulative—TSL 5 includes all preceding options)
IMH–W–Small–B .................
No BW Fill .........
SPM PM ............
+ Comp EER ....
+ Cond ..............
Same EL as
TSL 1.
+ Cond ..............
Same EL as
TSL 3.
IMH–W–Small–B (22 inch
wide).
IMH–W–Med–B ...................
No BW Fill .........
SPM PM ............
BW Fill ..............
SPM PM ............
BW Fill ..............
SPM PM ............
+ Comp EER ....
+ Cond ..............
+ Comp EER ....
ECM PM ...........
Same EL as
Baseline.
Same EL as
TSL 1.
Same EL as
TSL 1.
Same EL as
Baseline.
+ Cond ..............
BW Fill ..............
Same EL as
TSL 1.
Same EL as
Baseline.
Same EL as
TSL 3.
+ Cond ..............
IMH–W–Large–B2 ...............
BW Fill ..............
SPM PM ............
Same EL as
Baseline.
Same EL as
Baseline.
Same EL as
Baseline.
Same EL as
Baseline.
IMH–A–Small–B ..................
BW Fill ..............
SPM PM ............
SPM FM ............
+ Evap ..............
+ Evap ..............
Same EL as
TSL 3.
IMH–A–Small–B (22 inch
wide).
BW Fill ..............
SPM PM ............
SPM FM ............
+ Evap ..............
ECM PM ...........
DWHX ...............
Same EL as
TSL 3.
N/A for 22-inch.
IMH–A–Large–B1 ................
No BW Fill .........
SPM PM ............
SPM FM ............
No BW Fill .........
SPM PM ............
SPM FM ............
BW Fill ..............
SPM PM ............
SPM FM ............
+ Comp EER ....
+ Cond ..............
+ Evap ..............
ECM FM ............
+ Comp EER ....
+ Cond ..............
+ Evap ..............
ECM FM ............
+ Comp EER ....
PSC FM ............
ECM FM ............
BW Fill ..............
BW Fill ..............
DWHX.
+ Comp EER ....
ECM FM ............
BW Fill ..............
+ Comp EER ....
ECM FM ............
ECM PM ...........
+ Cond ..............
DWHX ...............
BW Fill ..............
ECM PM ...........
DWHX ...............
Same EL as
TSL 1.
DWHX ...............
BW Fill ..............
ECM PM ...........
+ Cond ..............
N/A for 22-inch ..
N/A for 22-inch.
Same EL as
TSL 3.
Same EL as
TSL 3.
mstockstill on DSK4VPTVN1PROD with RULES2
IMH–W–Large–B1 ...............
IMH–A–Large–B1 (22 inch
wide).
IMH–A–Large–B2 ................
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DWHX ...............
E:\FR\FM\28JAR2.SGM
Same EL as
Baseline.
28JAR2
BW Fill
+ Evap
ECM PM
DWHX.
N/A for 22-inch.
DWHX.
+ Comp EER
+ Cond
ECM PM
DWHX.
+ Comp EER
+ Cond
ECM PM
DWHX.
+ Evap
ECM PM
DWHX.
4720
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.3—DESIGN OPTIONS FOR ANALYZED PRODUCTS CLASSES AT EACH TSL—Continued
Equipment class
Baseline
TSL 1
RCU–Large–B1 ...................
BW Fill ..............
SPM PM ............
PSC FM ............
RCU–Large–B2 ...................
BW Fill ..............
SPM PM ............
PSC FM ............
SCU–W–Large–B ................
No BW Fill .........
SPM PM ............
No BW Fill .........
SPM PM ............
SPM FM ............
No BW Fill .........
SPM PM ............
SPM FM ............
PSC AM ............
SPM FM ............
PSC AM ............
SPM FM ............
PSC AM ............
SPM FM ............
SCU–A–Small–B .................
SCU–A–Large–B .................
RCU–Small–C .....................
IMH–A–Small–C ..................
IMH–A–Large–C ..................
SCU–A–Small–C .................
PSC AM ............
SPM FM ............
TSL 2
TSL 3
+ Cond ..............
+ Comp EER ....
Same EL as
TSL 1.
Same EL as
TSL 1.
+ Comp EER ....
ECM FM ............
+ Cond ..............
ECM PM ...........
BW Fill ..............
+ Evap ..............
+ Cond ..............
+ Comp .............
EER ...................
+Cond ...............
+ Comp EER ....
Same EL as
TSL 1.
+Evap ................
+ Cond ..............
+ Comp EER ....
+ Comp EER ....
BW Fill ..............
+ Comp EER ....
PSC FM ............
+ Comp EER ....
+ Cond ..............
+ Comp EER ....
ECM FM ............
+ Cond ..............
+ Comp EER ....
TSL 4
TSL 5
+ Cond ..............
ECM FM ............
Same EL as
TSL 1.
+ Comp EER ....
DWHX.
Same EL as
TSL 1.
ECM FM ............
ECM PM ...........
+ Cond ..............
DWHX ...............
Same EL as
TSL 1.
+ Cond ..............
+ Cond ..............
DWHX.
PSC FM ............
BW Fill ..............
ECM FM
DWHX.
BW Fill ..............
ECM FM ............
BW Fill ..............
ECM PM ...........
ECM FM ............
ECM PM ...........
DWHX ...............
ECM FM ............
+ Cond ..............
ECM FM ............
+ Cond ..............
+ Comp EER ....
+ Cond ..............
Same EL as
TSL3.
Same EL as
TSL 3.
Same EL as
TSL 3.
+ Cond
ECM AM.
ECM AM.
+ Comp EER ....
ECM FM ............
Same EL as
TSL 3.
DWHX.
Same EL as
TSL 4.
+ Cond
ECM FM
ECM AM.
ECM FM
ECM AM.
EL = Efficiency Level
SPM = Shaded Pole Motor
PSC = Permanent Split Capacitor Motor
ECM = Electronically Commutated Motor
FM = Fan Motor (Air-Cooled Units)
AM = Auger Motor (Continuous Units)
BW Fill = Batch Water Fill Option Included
+ Cond = Increase in Condenser Size
+ Evap = Increase in Evaporator Size
+ Comp EER = Increase in Compressor EER
DWHX = Addition of Drain Water Heat Exchanger
Chapter 5 of the TSD contains full
descriptions of the design options,
DOE’s analyses for the equipment size
increase associated with the design
options selected, and DOE’s analyses of
the efficiency gains for each design
option considered.
2. Trial Standard Level Equations
Table V.4 and Table V.5 translate the
TSLs into potential standards. In Table
V.4, the TSLs are translated into energy
consumption standards for the batch
classes, while Table V.5 provides the
potential energy consumption standards
for the continuous classes. Note that the
size nomenclature for the classes (Small,
Medium, Large, and Extended) in many
cases designate different capacity ranges
than the current class sizes. However,
the discussion throughout this preamble
is based primarily on the current class
capacity ranges—the alternative
designation is made in Table V.4 and
Table V.5 for future use when the new
energy conservation standards take
effect.
TABLE V.4—EQUATIONS REPRESENTING THE TSLS FOR BATCH EQUIPMENT CLASSES
[Maximum energy use in kWh/100 lb ice]
Capacity
range
lb ice/24 hours
Batch equipment class
IMH–W–Small–B ......................................
IMH–W–Med–B ........................................
mstockstill on DSK4VPTVN1PROD with RULES2
IMH–W–Large–B ......................................
IMH–W–Extended–B ................................
IMH–A–Small–B .......................................
IMH–A–Medium–B ...................................
IMH–A–Large–B .......................................
VerDate Sep<11>2014
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<300
≥300 and
<850
≥850 and
<1500
≥1,500 and
<2,600
≥2,600
<300
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
7.19–0.0055H
6.28–
0.00247H
4.42–
0.00028H
4.0
7.19–0.0055H
6.28–
0.00247H
4.42–
0.00028H
4.0
6.88–0.0055H
5.8–0.00191H
6.88–0.0055H
5.9–0.00224H
4.0
4.0
4.0
4.0
4.0
10.09–
0.0106H
7.81–0.003H
4.0
10.05–
0.01173H
7.38–
0.00284H
5.56–
0.00056H
4.0
10–0.01233H
4.0
10–0.01233H
7.05–0.0025H
7.19–
0.00298H
5.04–
0.00029H
6.32–0.0055H
5.17–
0.00165H
3.86–
0.00012H
3.62 +
0.00004H
3.72
9.38–
0.01233H
6.31–0.0021H
≥300 and
<800
≥800 and
<1,500
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0.00099H
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0.00063H
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0.00003H
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
4721
TABLE V.4—EQUATIONS REPRESENTING THE TSLS FOR BATCH EQUIPMENT CLASSES—Continued
[Maximum energy use in kWh/100 lb ice]
Capacity
range
lb ice/24 hours
Batch equipment class
IMH–A–Extended–B .................................
RCU–NRC–Small–B ................................
>1,500
<988 *
RCU–NRC–Large–B ................................
TSL 1
≥988 * and
<1,500
≥1,500 and
<2,400
≥2,400
<930 **
RCU–NRC–Extended–B ..........................
RCU–RC–Small–B ...................................
RCU–RC–Large–B ...................................
RCU–RC–Extended–B .............................
SCU–W–Small–B .....................................
SCU–W–Large–B .....................................
SCU–A–Small–B ......................................
≥930 ** and
<1,500
≥1,500 and <
2,400
≥2,400
<200
≥200
<110
≥110 and
<200
≥200
SCU–A–Large–B ......................................
SCU–A–Extended–B ................................
TSL 2
TSL 3
TSL 4
TSL 5
4.73
7.97–
0.00342H
4.59
4.72
7.97–
0.00342H
4.59
4.61
7.97–
0.00342H
4.59
4.61
7.52–
0.00323H
4.34
4.61
7.35–
0.00312H
4.23
4.59
4.59
4.59
4.59
7.97–
0.00342H
4.79
4.59
7.97–
0.00342H
4.79
4.59
7.97–
0.00342H
4.79
3.92 +
0.00028H
4.59
7.52–
0.00323H
4.54
3.96 +
0.00018H
4.39
7.35–
0.00312H
4.43
4.79
4.79
4.79
4.79
10.64–0.019H
6.84
16.72–
0.0469H
14.91–
0.03044H
8.82
4.79
9.88–0.019H
6.08
15.43–
0.0469H
13.24–0.027H
4.79
9.5–0.019H
5.7
14.79–
0.0469H
12.42–
0.02533H
7.35
4.12 +
0.00028H
4.79
9.14–0.019H
5.34
14.15–
0.0469H
11.47–
0.02256H
6.96
4.16 +
0.00018H
4.59
9.14–0.019H
5.34
13.76–
0.0469H
10.6–0.02
7.84
6.96
* 985 for TSL4, 1,000 for TSL5
** 923 for TSL4, 936 for TSL5
TABLE V.5—EQUATIONS REPRESENTING THE TSLS FOR CONTINUOUS EQUIPMENT CLASSES
[Maximum energy use in kWh/100 lb ice]
Continuous equipment class
Capacity
range
lb ice/24 hours
TSL 1
TSL 2
<801
7.29–0.003H
IMH–W–Large–C .....................................
IMH–A–Small–C .......................................
≥801
<310
IMH–A–Large–C ......................................
IMH–A–Extended–C ................................
RCU–NRC–Small–C ................................
≥310 and
<820
≥820
<800
RCU–NRC–Large–C ................................
RCU–RC–Small–C ...................................
≥800
<800
RCU–RC–Large–C ..................................
SCU–W–Small–C .....................................
≥800
<900
4.59
10.1–
0.00629H
9.49–
0.00433H
5.94
9.85–
0.00519H
5.7
10.05–
0.00519H
5.9
8.55–0.0034H
SCU–W–Large–C ....................................
SCU–A–Small–C ......................................
SCU–A–Large–C .....................................
≥900
<200
≥200 and 700
SCU–A–Extended–C ...............................
mstockstill on DSK4VPTVN1PROD with RULES2
IMH–W–Small–C ......................................
≥700
In developing TSLs, DOE analyzed
representative units for each equipment
class group, defined for the purposes of
this discussion by the ‘‘Type of Ice
Maker,’’ ‘‘Equipment Type,’’ and ‘‘Type
of Condenser Cooling’’ (see Table IV.2—
within each class group, further
segregation into equipment classes
involves only specification of harvest
capacity rate). DOE first established a
VerDate Sep<11>2014
19:19 Jan 27, 2015
Jkt 235001
5.49
15.26–0.03
10.66–
0.00702H
5.75
TSL 3
TSL 4
TSL 5
6.89–
0.00283H
4.59
9.64–
0.00629H
8.75–
0.00343H
5.94
9.78–0.0055H
6.48–
0.00267H
4.34
9.19–
0.00629H
8.23–0.0032H
6.48–
0.00267H
4.34
9.19–
0.00629H
8.23–0.0032H
5.61
9.7–0.0058H
5.61
9.7–0.0058H
5.75–
0.00237H
3.93
8.38–
0.00629H
7.25–
0.00265H
5.08
9.26–0.0058H
5.38
9.98–0.0055H
5.06
9.9–0.0058H
5.06
9.9–0.0058H
4.62
9.46–0.0058H
5.58
8.08 0.0032H
5.26
7.6–0.00302H
5.26
7.6–0.00302H
5.19
14.73–0.03H
10.06–
0.00663H
5.42
4.88
14.22–0.03H
9.47–
0.00624H
5.1
4.88
14.22–0.03H
9.47–
0.00624H
5.1
4.82
6.84–
0.00272H
4.39
13.4–0.03H
8.52–
0.00562H
4.59
percentage reduction in energy use
associated with each TSL for the
representative units. DOE calculated the
energy use (in kWh/100 lb ice)
associated with this reduction for the
harvest capacity rates associated with
the representative units (called
representative capacities). This
provided one or more points with which
to define a TSL curve for the entire
PO 00000
Frm 00077
Fmt 4701
Sfmt 4700
equipment class group as a function of
harvest capacity rate. DOE selected the
TSL curve to (a) pass through the points
defining energy use for the TSL at the
representative capacities; (b) be
continuous, with no gaps at the
representative capacities or at any other
capacities; and (c) be consistent with the
energy and capacity trends for
E:\FR\FM\28JAR2.SGM
28JAR2
4722
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
commercialized products of the
equipment class group.
For the IMH–A–B equipment classes,
DOE sought to set efficiency levels that
do not vary with harvest capacity for the
largest-capacity equipment, but doing so
would have violated EPCA’s antibacksliding provisions. As a result, the
efficiency levels for large-capacity
equipment for this class in the range up
to 2,500 lb ice/24 hours were set using
multiple segments. This is discussed in
section IV.D.2.c.
For the RCU–RC–Large–B, RCU–RC–
Small–C, and RCU–RC–Large–C
equipment classes, the efficiency levels
are 0.2 kWh/100 lb of ice higher than
those of the RCU–NRC–Large–B, RCU–
NRC–Small–C, and RCU–NRC–Large–C
equipment classes, respectively, as
discussed in section IV.D.2.a. The RCU–
RC–Small–B and RCU–NRC–Small–B
efficiency levels are equal, and the
harvest capacity break points for the
RCU–NRC classes have been set to avoid
gaps in allowable energy usage at the
breakpoints.
The TSL energy use levels calculated
for the representative capacities of the
directly-analyzed equipment classes are
presented Table V.6.
TABLE V.6—ENERGY CONSUMPTION BY TSL FOR THE REPRESENTATIVE AUTOMATIC COMMERCIAL ICE MAKER UNITS
Representative
harvest rate
lb ice/24 hours
Equipment class
IMH–W–Small–B ....................................................
IMH–W–Med–B ......................................................
IMH–W–Large–B–1 ................................................
IMH–W–Large–B–2 ................................................
IMH–A–Small–B .....................................................
IMH–A–Large–B–1 .................................................
IMH–A–Large–B–2 .................................................
RCU–NRC–Large–B–1 ..........................................
RCU–NRC–Large–B–2 ..........................................
SCU–W–Large–B ...................................................
SCU–A–Small–B ....................................................
SCU–A–Large–B ....................................................
IMH–A–Small–C .....................................................
IMH–A–Large–C ....................................................
RCU–Small–C ........................................................
SCU–A–Small–C ....................................................
B. Economic Justification and Energy
Savings
1. Economic Impacts on Commercial
Customers
mstockstill on DSK4VPTVN1PROD with RULES2
a. Life-Cycle Cost and Payback Period
Customers affected by new or
amended standards usually incur higher
purchase prices and lower operating
costs. DOE evaluates these impacts on
individual customers by calculating
changes in LCC and the PBP associated
with the TSLs. The results of the LCC
analysis for each TSL were obtained by
comparing the installed and operating
costs of the equipment in the base-case
scenario (scenario with no amended
energy conservation standards) against
the standards-case scenarios at each
TSL. The energy consumption values for
both the base-case and standards-case
scenarios were calculated based on the
DOE test procedure conditions specified
in the 2012 test procedure final rule,
which adopts an industry-accepted test
method. Using the approach described
in section IV.F, DOE calculated the LCC
savings and PBPs for the TSLs
considered in this final rule. The LCC
analysis is carried out in the form of
Monte Carlo simulations, and the results
of LCC analysis are distributed over a
range of values. DOE presents the mean
VerDate Sep<11>2014
19:19 Jan 27, 2015
Jkt 235001
300
850
1,500
2,600
300
800
1,500
1,500
2,400
300
110
200
310
820
800
220
Representative automatic commercial ice maker unit
kWh/100 lb
TSL 1
TSL 2
5.54
4.18
4.00
4.00
6.91
5.41
4.72
4.59
4.59
6.84
11.56
8.82
8.15
5.94
5.70
9.11
5.54
4.18
4.00
4.00
6.53
5.11
4.72
4.59
4.59
6.08
10.27
7.84
7.69
5.94
5.38
8.61
or median values, as appropriate,
calculated from the distributions of
results.
Table V.7 through Table V.25 show
the results of the LCC analysis for each
equipment class. Each table presents the
results of the LCC analysis, including
mean LCC, mean LCC savings, median
PBP, and distribution of customer
impacts in the form of percentages of
customers who experience net cost, no
impact, or net benefit.
Only five equipment classes have
positive LCC savings values at TSL 5,
while the remaining classes have
negative LCC savings. Negative average
LCC savings imply that, on average,
customers experience an increase in
LCC of the equipment as a consequence
of buying equipment associated with
that particular TSL. In four of the five
classes, the TSL 5 level is not negative,
but the LCC savings are less than onethird the TSL 3 savings. All of these
results indicate that the cost increments
associated with the max-tech design
option are high, and the increase in LCC
(and corresponding decrease in LCC
savings) indicates that the design
options embodied in TSL 5 result in
negative customer impacts. TSL 5 is
associated with the max-tech level for
all the equipment classes. Drain water
heat exchanger technology is the design
PO 00000
Frm 00078
Fmt 4701
Sfmt 4700
TSL 3
5.23
4.18
4.00
4.00
6.30
5.05
4.61
4.59
4.59
5.70
9.63
7.35
7.24
5.61
5.06
8.10
TSL 4
5.23
4.00
4.00
4.00
6.30
4.81
4.61
4.34
4.59
5.34
8.99
6.96
7.24
5.61
5.06
8.10
TSL 5
4.67
3.76
3.68
3.72
5.68
4.63
4.61
4.23
4.39
5.34
8.60
6.96
6.43
5.08
4.62
7.29
option associated with the max-tech
efficiency levels for batch equipment
classes. For continuous equipment
classes, the max-tech design options are
auger motors using permanent magnets.
The mean LCC savings associated
with TSL 4 are all positive values for all
equipment classes. The mean LCC
savings at all lower TSL levels are also
positive. The trend is generally an
increase in LCC savings for TSL 1
through 3, with LCC savings either
remaining constant or declining at TSL
4. In two cases, the highest LCC savings
are at TSL 2: IMH–A–Large–B1 and
SCU–W–Large–B. In one case, IMH–A–
Small–B, the highest LCC savings occur
at TSL1. Two of the three classes with
LCC savings maximums below TSL 3
have high one-time installation cost
adders for building renovations
expected to take place when existing
units are replaced, causing the TSL3
LCC savings to be depressed relative to
the lower levels. The drop-off in LCC
savings at TSL 4 is generally associated
with the relatively large cost for the
max-tech design options, the savings for
which frequently span the last two
efficiency levels.
As described in section IV.H.2, DOE
used a ‘‘roll-up’’ scenario in this
rulemaking. Under the roll-up scenario,
DOE assumes that the market shares of
E:\FR\FM\28JAR2.SGM
28JAR2
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
the efficiency levels (in the base case)
that do not meet the standard level
under consideration would be ‘‘rolled
up’’ into (meaning ‘‘added to’’) the
market share of the efficiency level at
the standard level under consideration,
and the market shares of efficiency
levels that are above the standard level
under consideration would remain
unaffected. Customers, in the base-case
scenario, who buy the equipment at or
above the TSL under consideration,
would be unaffected if the amended
standard were to be set at that TSL.
Customers, in the base-case scenario,
who buy equipment below the
considered TSL, would be affected if the
amended standard were to be set at that
TSL. Among these affected customers,
some may benefit from lower LCC of the
equipment and some may incur a net
cost due to higher LCC, depending on
the inputs to LCC analysis, such as
electricity prices, discount rates,
installation costs, and markups. DOE’s
results indicate that, with two
exceptions, nearly all customers either
benefit or are unaffected by setting
standards at TSLs 1, 2, or 3, with 0 to
2 percent of customers experiencing a
net cost in all but two classes. Some
customers purchasing IMH–A–Small–B
(21 percent) and IMH–A–Large–B2 (10
percent) equipment will experience net
costs at TSL3. In almost all cases, a
portion of the market would experience
net costs starting with TSL 4, although
in several equipment classes the
4723
percentage is below 10 percent. At TSL
5, only in IMH–A–Large–B2 (10 percent)
and SCU–W–Large–B (44 percent) do
less than 50 percent of customers show
a net cost, while in the other classes the
percentage of customers with a net cost
ranges as high as 96 percent.
The median PBP values for TSLs 1
through 3 are generally less than 3
years, except for IMH–A–Small–B
where the TSL 3 PBP is 4.7 years and
IMH–A–Large–B2 with a PBP of 6.9
years. The median PBP values for TSL
4 range from 0.7 years to 6.9 years.
PBP values for TSL 5 range from 4.9
years to nearly 12 years. In eight cases,
the the PBP exceeds the expected 8.5year equipment life.
TABLE V.7—SUMMARY LCC AND PBP RESULTS FOR IMH–W–SMALL–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
2,551
2,551
2,411
2,411
2,162
Discounted
operating
cost
Installed
cost
2,476
2,476
2,537
2,537
3,371
Life-cycle cost savings
LCC
9,533
9,533
9,381
9,381
9,200
Affected
customers’
average
savings
2013$
12,009
12,009
11,918
11,918
12,571
Payback
period,
median
years
% of customers that experience
Net
cost
%
175
175
214
214
(534)
No
impact
%
0
0
1
1
96
Net
benefit
%
63
63
47
47
0
37
37
52
52
4
2.5
2.5
2.7
2.7
13.4
TABLE V.8—SUMMARY LCC AND PBP RESULTS FOR IMH–W–MED–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
5,439
5,439
5,439
5,138
4,951
Discounted
operating
cost
Installed
cost
4,325
4,325
4,325
4,607
4,943
Life-cycle cost savings
LCC
21,470
21,470
21,470
21,251
21,115
Affected
customers’
average
savings
2013$
25,795
25,795
25,795
25,857
26,058
Payback
period,
median
years
% of customers that experience
Net
cost
%
308
308
308
165
(63)
No
impact
%
0
0
0
28
65
Net
benefit
%
44
44
44
24
9
56
56
56
47
26
2.1
2.1
2.1
5.0
7.6
TABLE V.9—SUMMARY LCC AND PBP RESULTS FOR IMH–W–LARGE–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
10,750
10,750
10,750
10,750
9,891
Discounted
operating
cost
Installed
cost
6,129
6,129
6,129
6,129
6,913
Life-cycle cost savings
LCC
42,992
42,992
42,992
42,992
42,381
Affected
customers’
average
savings
2013$
49,121
49,121
49,121
49,121
49,294
Payback
period,
median
years
% of customers that experience
Net
cost
%
0
0
0
0
(172)
No
impact
%
NA
NA
NA
NA
67
Net
benefit
%
NA
NA
NA
NA
13
NA
NA
NA
NA
20
NA
NA
NA
NA
10.6
mstockstill on DSK4VPTVN1PROD with RULES2
TABLE V.10—SUMMARY LCC AND PBP RESULTS FOR IMH–W–LARGE–B1 EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1 ............................
2 ............................
VerDate Sep<11>2014
9,166
9,166
19:19 Jan 27, 2015
Discounted
operating
cost
Installed
cost
5,004
5,004
Jkt 235001
PO 00000
37,051
37,051
Frm 00079
Life-cycle cost savings
LCC
Affected
customers’
average
savings
2013$
42,055
42,055
Fmt 4701
Net
cost
%
0
0
Sfmt 4700
Payback
period,
median
years
% of customers that experience
No
impact
%
NA
NA
E:\FR\FM\28JAR2.SGM
Net
benefit
%
NA
NA
28JAR2
NA
NA
NA
NA
4724
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.10—SUMMARY LCC AND PBP RESULTS FOR IMH–W–LARGE–B1 EQUIPMENT CLASS—Continued
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
3 ............................
4 ............................
5 ............................
9,166
9,166
8,405
Discounted
operating
cost
Installed
cost
5,004
5,004
5,747
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
37,051
37,051
36,509
42,055
42,055
42,256
Payback
period,
median
years
% of customers that experience
Net
cost
%
0
0
(200)
No
impact
%
NA
NA
70
Net
benefit
%
NA
NA
13
NA
NA
17
NA
NA
11.1
TABLE V.11—SUMMARY LCC AND PBP RESULTS FOR IMH–W–LARGE–B2 EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
15,868
15,868
15,868
15,868
14,693
Discounted
operating
cost
Installed
cost
9,763
9,763
9,763
9,763
10,681
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
62,182
62,182
62,182
62,182
61,346
71,945
71,945
71,945
71,945
72,027
Payback
period,
median
years
% of customers that experience
Net
cost
%
0
0
0
0
(80)
No
impact
%
NA
NA
NA
NA
59
Net
benefit
%
NA
NA
NA
NA
13
NA
NA
NA
NA
29
NA
NA
NA
NA
8.9
TABLE V.12—SUMMARY LCC AND PBP RESULTS FOR IMH–A–SMALL–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
3,184
3,009
2,901
2,901
2,640
Discounted
operating
cost
Installed
cost
2,539
2,655
2,695
2,695
3,331
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
8,420
8,293
8,214
8,214
8,048
10,959
10,948
10,909
10,909
11,379
Payback
period,
median
years
% of customers that experience
Net
cost
%
136
72
77
77
(393)
No
impact
%
1
21
21
21
95
Net
benefit
%
76
47
0
0
0
22
32
79
79
5
3.4
4.8
4.7
4.7
11.9
TABLE V.13—SUMMARY LCC AND PBP RESULTS FOR IMH–A–LARGE–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
..............................
..............................
..............................
..............................
..............................
Installed
cost
7,272
6,964
6,881
6,622
6,411
Discounted
operating
cost
4,337
4,418
4,435
4,711
5,068
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
14,598
14,230
14,170
13,988
13,834
18,935
18,648
18,605
18,699
18,902
Payback
period,
median
years
% of customers that experience
Net
cost
%
382
501
361
265
55
No
impact
%
1
1
2
31
53
Net
benefit
%
69
45
12
12
10
30
53
86
57
37
2.2
2.4
2.3
3.9
5.6
TABLE V.14—SUMMARY LCC AND PBP RESULTS FOR IMH–A–LARGE–B1 EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
mstockstill on DSK4VPTVN1PROD with RULES2
TSL
1
2
3
4
5
..............................
..............................
..............................
..............................
..............................
VerDate Sep<11>2014
Installed
cost
6,617
6,251
6,192
5,885
5,636
19:19 Jan 27, 2015
Discounted
operating
cost
4,172
4,269
4,275
4,602
5,025
Jkt 235001
PO 00000
13,943
13,506
13,464
13,247
13,066
Frm 00080
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
18,115
17,775
17,738
17,850
18,091
Fmt 4701
Sfmt 4700
439
580
407
294
45
Payback
period,
median
years
% of customers that experience
Net
cost
%
No
impact
%
0
0
0
35
61
E:\FR\FM\28JAR2.SGM
Net
benefit
%
66
38
3
3
0
28JAR2
34
62
97
63
39
1.2
1.5
1.5
3.4
5.4
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
4725
TABLE V.15—SUMMARY LCC AND PBP RESULTS FOR IMH–A–LARGE–B2 EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
..............................
..............................
..............................
..............................
..............................
Installed
cost
10,802
10,802
10,591
10,591
10,591
Discounted
operating
cost
5,222
5,222
5,298
5,298
5,298
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
18,129
18,129
17,975
17,975
17,975
23,350
23,350
23,273
23,273
23,273
Payback
period,
median
years
% of customers that experience
Net
cost
%
76
76
110
110
110
No
impact
%
9
9
10
10
10
Net
benefit
%
83
83
61
61
61
8
8
29
29
29
7.4
7.4
6.9
6.9
6.9
TABLE V.16—SUMMARY LCC AND PBP RESULTS FOR RCU–LARGE–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
..............................
..............................
..............................
..............................
..............................
Installed
cost
10,908
10,908
10,908
10,362
10,066
Discounted
operating
cost
6,423
6,423
6,423
6,813
7,207
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
14,588
14,588
14,588
14,213
14,000
21,012
21,012
21,012
21,026
21,206
Payback
period,
median
years
% of customers that experience
Net
cost
%
748
748
748
418
144
No
impact
%
0
0
0
23
55
Net
benefit
%
56
56
56
22
2
44
44
44
55
42
1.1
1.1
1.1
3.3
5.0
TABLE V.17—SUMMARY LCC AND PBP RESULTS FOR RCU–LARGE–B1 EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
..............................
..............................
..............................
..............................
..............................
Installed
cost
10,514
10,514
10,514
9,931
9,664
Discounted
operating
cost
6,220
6,220
6,220
6,635
6,985
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
14,190
14,190
14,190
13,790
13,595
20,410
20,410
20,410
20,425
20,580
Payback
period,
median
years
% of customers that experience
Net
cost
%
743
743
743
391
161
No
impact
%
0
0
0
25
55
Net
benefit
%
56
56
56
20
1
44
44
44
55
44
0.9
0.9
0.9
3.4
4.9
TABLE V.18—SUMMARY LCC AND PBP RESULTS FOR RCU–LARGE–B2 EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
16,807
16,807
16,807
16,807
16,077
Discounted
operating
cost
Installed
cost
9,465
9,465
9,465
9,465
10,516
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
20,540
20,540
20,540
20,540
20,046
30,005
30,005
30,005
30,005
30,562
Payback
period,
median
years
% of customers that experience
Net
cost
%
820
820
820
820
(109)
No
impact
%
1
1
1
1
57
Net
benefit
%
56
56
56
56
20
43
43
43
43
23
3.0
3.0
3.0
3.0
7.0
TABLE V.19—SUMMARY LCC AND PBP RESULTS FOR SCU–W–LARGE–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
mstockstill on DSK4VPTVN1PROD with RULES2
TSL
1
2
3
4
5
..............................
..............................
..............................
..............................
..............................
VerDate Sep<11>2014
Installed
cost
3,151
2,804
2,630
2,464
2,464
20:54 Jan 27, 2015
Discounted
operating
cost
3,540
3,620
3,664
4,114
4,114
Jkt 235001
PO 00000
10,617
10,364
10,238
10,117
10,117
Frm 00081
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
14,158
13,984
13,902
14,231
14,231
Fmt 4701
Sfmt 4700
444
613
550
192
192
Payback
period,
median
years
% of customers that experience
Net
cost
%
No
impact
%
0
0
0
44
44
E:\FR\FM\28JAR2.SGM
Net
benefit
%
28
28
5
0
0
28JAR2
72
72
94
56
56
1.1
1.6
1.8
5.1
5.1
4726
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.20—SUMMARY LCC AND PBP RESULTS FOR SCU–A–SMALL–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
1,962
1,747
1,639
1,532
1,473
Discounted
operating
cost
Installed
cost
2,799
2,845
2,918
3,000
3,416
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
7,193
7,051
6,843
6,778
6,737
9,992
9,896
9,761
9,778
10,153
Payback
period,
median
years
% of customers that experience
Net
cost
%
110
161
281
230
(145)
No
impact
%
0
1
1
16
77
Net
benefit
%
48
20
12
0
0
52
79
87
84
23
2.2
2.4
2.6
3.5
8.9
TABLE V.21—SUMMARY LCC AND PBP RESULTS FOR SCU–A–LARGE–B EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
..............................
..............................
..............................
..............................
..............................
Installed
cost
2,713
2,414
2,265
2,141
2,141
Discounted
operating
cost
3,275
3,345
3,402
3,854
3,854
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
10,070
9,685
9,590
9,500
9,500
13,344
13,030
12,992
13,355
13,355
Payback
period,
median
years
% of customers that experience
Net
cost
%
163
400
439
71
71
No
impact
%
0
0
0
54
54
Net
benefit
%
37
1
1
0
0
63
99
99
46
46
1.8
1.6
2.1
6.5
6.5
TABLE V.22—SUMMARY LCC AND PBP RESULTS FOR IMH–A–SMALL–C EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
3,872
3,658
3,445
3,445
3,201
Discounted
operating
cost
Installed
cost
6,674
6,709
6,745
6,745
7,264
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
8,869
8,723
8,572
8,572
8,552
15,543
15,432
15,317
15,317
15,816
Payback
period,
median
years
% of customers that experience
Net
cost
%
245
292
313
313
(165)
No
impact
%
0
0
0
0
68
Net
benefit
%
69
58
39
39
14
31
42
61
61
18
1.5
1.6
1.7
1.7
8.8
* Values in parentheses are negative values.
TABLE V.23—SUMMARY LCC AND PBP RESULTS FOR IMH–A–LARGE–C EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
..............................
..............................
..............................
..............................
..............................
Installed
cost
7,445
7,445
7,033
7,033
6,348
Discounted
operating
cost
5,538
5,538
5,568
5,568
6,310
Life-cycle cost savings
Affected
customers’
average
savings
2013$
LCC
14,275
14,275
13,979
13,979
13,705
19,813
19,813
19,547
19,547
20,015
Payback
period,
median
years
% of customers that experience
Net
cost
%
539
539
626
626
28
No
impact
%
0
0
0
0
54
Net
benefit
%
57
57
35
35
9
43
43
65
65
37
0.7
0.7
0.7
0.7
5.9
TABLE V.24—SUMMARY LCC AND PBP RESULTS FOR RCU–SMALL–C EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
mstockstill on DSK4VPTVN1PROD with RULES2
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
6,966
6,580
6,195
6,195
5,688
Discounted
operating
cost
Installed
cost
5,690
5,758
5,808
5,808
6,523
8,588
8,319
8,046
8,046
7,878
Life-cycle cost savings
LCC
Affected
customers’
average
savings
2013$
14,278
14,078
13,854
13,854
14,402
498
448
505
505
(73)
Net
cost
%
No
impact
%
0
0
0
0
64
20:54 Jan 27, 2015
Jkt 235001
PO 00000
Frm 00082
Fmt 4701
Sfmt 4700
E:\FR\FM\28JAR2.SGM
Net
benefit
%
72
44
11
11
6
* Values in parentheses are negative values.
VerDate Sep<11>2014
Payback
period,
median
years
% of customers that experience
28JAR2
28
55
89
89
31
0.7
1.2
1.2
1.2
5.8
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
4727
TABLE V.25—SUMMARY LCC AND PBP RESULTS FOR SCU–A–SMALL–C EQUIPMENT CLASS
Life-cycle cost, all customers
2013$
Energy
usage
kWh/yr
TSL
1
2
3
4
5
............................
............................
............................
............................
............................
3,077
2,907
2,738
2,738
2,515
Discounted
operating
cost
Installed
cost
3,622
3,646
3,685
3,685
4,224
8,175
8,059
7,948
7,948
7,950
Life-cycle cost savings
LCC
Affected
customers’
average
savings
2013$
11,797
11,705
11,633
11,633
12,174
Payback
period,
median
years
% of customers that experience
Net
cost
%
224
278
290
290
(268)
No
impact
%
0
0
1
1
86
Net
benefit
%
56
47
32
32
0
44
53
67
67
14
0.8
1.1
1.5
1.5
11.4
* Values in parentheses are negative values.
mstockstill on DSK4VPTVN1PROD with RULES2
b. Life-Cycle Cost Subgroup Analysis
As described in section IV.I, DOE
estimated the impact of amended energy
conservation standards for automatic
commercial ice makers, at each TSL, on
two customer subgroups—the
foodservice sector and the lodging
sector. For the automatic commercial ice
makers, DOE has not distinguished
between subsectors of the foodservice
industry. In other words, DOE has been
treating it as one sector as opposed to
modeling limited or full service
restaurants and other types of
foodservice firms separately.
Foodservice was chosen as one
representative subgroup because of the
large percentage of the industry
represented by family-owned or locally
owned restaurants. Likewise, lodging
was chosen due to the large percentage
of the industry represented by locally
owned or franchisee-owned hotels. DOE
carried out two LCC subgroup analyses,
one each for restaurants and lodging, by
using the LCC spreadsheet described in
chapter 8 of the final rule TSD, but with
certain modifications. This included
fixing the input for business type to the
identified subgroup, which ensured that
the discount rates and electricity price
rates associated with only that subgroup
were selected in the Monte Carlo
simulations (see chapter 8 of the TSD).
Another major change from the LCC
analysis was an added assumption that
the subgroups do not have access to
national capital markets, which results
in higher discount rates for the
subgroups. The higher discount rates
lead the subgroups to place a lower
value on future savings and a higher
value on the upfront equipment
purchase costs. The LCC subgroup
analysis is described in chapter 11 of
the TSD.
Table V.26 presents the comparison of
mean LCC savings for the small business
VerDate Sep<11>2014
20:54 Jan 27, 2015
Jkt 235001
subgroup in foodservice sector with the
national average values (LCC savings
results from chapter 8 of the TSD). For
TSLs 1–3, in most equipment classes,
the LCC savings for the small business
subgroup are only slightly different from
the average, with some slightly higher
and others slightly lower. Table V.27
presents the percentage change in LCC
savings compared to national average
values. DOE modeled all equipment
classes in this analysis, although DOE
believes it is likely that the very large
equipment classes are not commonly
used in foodservice establishments. For
TSLs 1–3, the differences range from ¥7
percent for IMH–A–Large–B2 at TSLs 1
and 2, to +3 percent for the same class
at TSL 3 and IMH–A–Small–B at TSL 2.
For most equipment classes in Table
V.27, the percentage change ranges from
a decrease in LCC savings of less than
2 percent to an increase of 2 percent. In
summary, the differences are minor at
TSLs 1–3.
Table V.28 presents the comparison of
median PBPs for the small business
subgroup in the foodservice sector with
national median values (median PBPs
from chapter 8 of the TSD). The PBP
values are the same as or shorter than
the small business subgroup in all cases.
This arises because the first-year
operating cost savings—which are used
for payback period—are higher, leading
to a shorter payback. However, given
their higher discount rates, these
customers value future savings less,
leading to lower LCC savings. First-year
savings are higher because the
foodservice electricity prices are higher
than the average of all classes.
Table V.29 presents the comparison of
mean LCC savings for the small business
subgroup in the lodging sector (hotels
and casinos) with the national average
values (LCC savings results from chapter
8 of the TSD). Table V.30 presents the
PO 00000
Frm 00083
Fmt 4701
Sfmt 4700
percentage difference between LCC
savings of the lodging sector customer
subgroup and national average values.
For lodging sector small business, LCC
savings are lower across the board. For
TSLs 1–3, the lodging subgroup LCC
savings range from 9 to 13 percent
lower. The reason for this is that the
energy price for lodging is slightly lower
than the average of all commercial
business types (97 percent of the
average). This, combined with a higher
discount rate, reduces the value of
future operating and maintenance
benefits as well as the present value of
the benefits, thus resulting in lower LCC
savings. For IMH–A–Small–B the
difference exceeds 20 percent, which is
likely due to the higher installation cost
for this class in combination with the
much higher than average discount rate.
The IMH–A–Large–B2 class is also
significantly lower, in percentage terms.
DOE notes that the difference is
relatively small in terms of dollars;
however, because the national average
savings are small, the difference is
significant in percentage terms. The
lodging subgroup savings for IMH–A–
Large–B2 are 88 percent lower than the
average at TSLs 1 and 2, and 37 percent
lower at TSL 3—the level recommended
for the standard.
Table V.31 presents the comparison of
median PBPs for the small business
subgroup in the lodging sector with
national median values (median PBPs
from chapter 8 of the TSD). The PBP
values are slightly longer or the same for
all equipment classes in the lodging
small business subgroup at all TSLs. As
noted above, the energy savings would
be lower than a national average. Thus,
the slightly lower median PBP appears
to be a result of a narrower electricity
saving results distribution that is close
to but below the national average.
E:\FR\FM\28JAR2.SGM
28JAR2
4728
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.26—COMPARISON OF MEAN LCC SAVINGS FOR THE FOODSERVICE SECTOR SMALL BUSINESS SUBGROUP WITH
THE NATIONAL AVERAGE VALUES
Equipment class
Mean LCC savings
2013$ *
Category
TSL 1
IMH–W–Small–B .....................................
IMH–W–Med–B .......................................
IMH–W–Large–B ....................................
IMH–W–Large–B1 ..................................
IMH–W–Large–B2 ..................................
IMH–A–Small–B ......................................
IMH–A–Large–B .....................................
IMH–A–Large–B1 ...................................
IMH–A–Large–B2 ...................................
RCU–Large–B .........................................
RCU–Large–B1 .......................................
RCU–Large–B2 .......................................
SCU–W–Large–B ...................................
SCU–A–Small–B .....................................
SCU–A–Large–B ....................................
IMH–A–Small–C .....................................
IMH–A–Large–C .....................................
RCU–Small–C .........................................
SCU–A–Small–C ....................................
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 .................................
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 .................................
TSL 2
174
175
312
308
NA
NA
NA
NA
NA
NA
139
136
387
382
444
439
81
76
754
748
749
743
832
820
431
444
112
110
164
163
248
245
544
539
503
498
225
224
TSL 3
174
175
312
308
NA
NA
NA
NA
NA
NA
75
72
498
501
575
580
81
76
754
748
749
743
832
820
601
613
162
161
392
400
296
292
544
539
453
448
281
278
TSL 4
212
214
312
308
NA
NA
NA
NA
NA
NA
78
77
359
361
404
407
114
110
754
748
749
743
832
820
541
550
276
281
432
439
317
313
630
626
509
505
293
290
TSL 5
212
214
168
165
NA
NA
NA
NA
NA
NA
78
77
264
265
292
294
114
110
424
418
397
391
832
820
184
192
226
230
65
71
317
313
630
626
509
505
293
290
(535)
(534)
(60)
(63)
(169)
(172)
(198)
(200)
(77)
(80)
(390)
(393)
54
55
43
45
114
110
150
144
166
161
(99)
(109)
184
192
(148)
(145)
65
71
(155)
(165)
44
28
(57)
(73)
(257)
(268)
* Values in parenthesis are negative numbers.
TABLE V.27—PERCENTAGE CHANGE IN MEAN LCC SAVINGS FOR THE FOODSERVICE SECTOR SMALL BUSINESS
SUBGROUP COMPARED TO NATIONAL AVERAGE VALUES *
TSL 1
(%)
mstockstill on DSK4VPTVN1PROD with RULES2
Equipment class
TSL 2
(%)
¥1
1
NA
NA
NA
2
1
1
7
1
1
1
¥3
1
1
1
1
1
1
IMH–W–Small–B ......................................................................................
IMH–W–Med–B ........................................................................................
IMH–W–Large–B ......................................................................................
IMH–W–Large–B1 ...................................................................................
IMH–W–Large–B2 ...................................................................................
IMH–A–Small–B .......................................................................................
IMH–A–Large–B ......................................................................................
IMH–A–Large–B1 ....................................................................................
IMH–A–Large–B2 ....................................................................................
RCU–Large–B ..........................................................................................
RCU–Large–B1 ........................................................................................
RCU–Large–B2 ........................................................................................
SCU–W–Large–B .....................................................................................
SCU–A–Small–B ......................................................................................
SCU–A–Large–B .....................................................................................
IMH–A–Small–C ......................................................................................
IMH–A–Large–C ......................................................................................
RCU–Small–C ..........................................................................................
SCU–A–Small–C ......................................................................................
TSL 3
(%)
¥1
1
NA
NA
NA
3
¥1
¥1
7
1
1
1
¥2
1
¥2
1
1
1
1
¥1
1
NA
NA
NA
2
¥1
¥1
3
1
1
1
¥2
¥2
¥2
1
1
1
1
TSL 4
(%)
¥1
2
NA
NA
NA
2
¥1
¥1
3
1
1
1
¥4
¥2
¥9
1
1
1
1
* Negative percentage values imply decrease in LCC savings, and positive percentage values imply increase in LCC savings.
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28JAR2
TSL 5
(%)
0
5
1
1
4
1
¥2
¥4
3
4
3
9
¥4
¥2
¥9
6
57
22
4
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
4729
TABLE V.28—COMPARISON OF MEDIAN PAYBACK PERIODS FOR THE FOODSERVICE SECTOR SMALL BUSINESS SUBGROUP
WITH NATIONAL MEDIAN VALUES
Equipment class
Median payback period
years
Category
TSL 1
IMH–W–Small–B .....................................
IMH–W–Med–B .......................................
IMH–W–Large–B ....................................
IMH–W–Large–B1 ..................................
IMH–W–Large–B2 ..................................
IMH–A–Small–B ......................................
IMH–A–Large–B .....................................
IMH–A–Large–B1 ...................................
IMH–A–Large–B2 ...................................
RCU–Large–B .........................................
RCU–Large–B1 .......................................
RCU–Large–B2 .......................................
SCU–W–Large–B ...................................
SCU–A–Small–B .....................................
SCU–A–Large–B ....................................
IMH–A–Small–C .....................................
IMH–A–Large–C .....................................
RCU–Small–C .........................................
SCU–A–Small–C ....................................
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 .................................
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 .................................
TSL 2
2.3
2.5
2.0
2.1
NA
NA
NA
NA
NA
NA
3.2
3.4
2.1
2.2
1.1
1.2
7.0
7.4
1.0
1.1
0.9
0.9
2.8
3.0
1.1
1.1
2.0
2.2
1.7
1.8
1.4
1.5
0.6
0.7
0.7
0.7
0.7
0.8
2.3
2.5
2.0
2.1
NA
NA
NA
NA
NA
NA
4.5
4.8
2.3
2.4
1.4
1.5
7.0
7.4
1.0
1.1
0.9
0.9
2.8
3.0
1.5
1.6
2.2
2.4
1.6
1.6
1.5
1.6
0.6
0.7
1.1
1.2
1.0
1.1
TSL 3
2.7
2.7
2.0
2.1
NA
NA
NA
NA
NA
NA
4.4
4.7
2.2
2.3
1.4
1.5
6.5
6.9
1.0
1.1
0.9
0.9
2.8
3.0
1.7
1.8
2.5
2.6
2.0
2.1
1.6
1.7
0.7
0.7
1.2
1.2
1.4
1.5
TSL 4
TSL 5
2.7
2.7
4.8
5.0
NA
NA
NA
NA
NA
NA
4.4
4.7
3.7
3.9
3.2
3.4
6.5
6.9
3.2
3.3
3.2
3.4
2.8
3.0
4.9
5.1
3.3
3.5
6.2
6.5
1.6
1.7
0.7
0.7
1.2
1.2
1.4
1.5
12.7
13.4
7.2
7.6
10.0
10.6
10.5
11.1
8.4
8.9
11.4
11.9
5.3
5.6
5.1
5.4
6.5
6.9
4.8
5.0
4.7
4.9
6.7
7.0
4.9
5.1
8.4
8.9
6.2
6.5
8.3
8.8
5.5
5.9
5.5
5.8
10.6
11.4
TABLE V.29—COMPARISON OF LCC SAVINGS FOR THE LODGING SECTOR SMALL BUSINESS SUBGROUP WITH THE
NATIONAL AVERAGE VALUES
Equipment class
Mean LCC savings
2013$ *
Category
TSL 1
IMH–W–Small–B .....................................
IMH–W–Med–B .......................................
IMH–W–Large–B ....................................
IMH–W–Large–B1 ..................................
IMH–W–Large–B2 ..................................
mstockstill on DSK4VPTVN1PROD with RULES2
IMH–A–Small–B ......................................
IMH–A–Large–B .....................................
IMH–A–Large–B1 ...................................
IMH–A–Large–B2 ...................................
RCU–Large–B .........................................
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Jkt 235001
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 .................................
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TSL 2
155
175
275
308
NA
NA
NA
NA
NA
NA
118
136
337
382
398
439
9
76
679
748
E:\FR\FM\28JAR2.SGM
155
175
275
308
NA
NA
NA
NA
NA
NA
54
72
443
501
523
580
9
76
679
748
28JAR2
TSL 3
189
214
275
308
NA
NA
NA
NA
NA
NA
61
77
321
361
368
407
70
110
679
748
TSL 4
189
214
123
165
NA
NA
NA
NA
NA
NA
61
77
211
265
237
294
70
110
347
418
TSL 5
(561)
(534)
(109)
(63)
(221)
(172)
(244)
(200)
(148)
(80)
(423)
(393)
(10)
55
(25)
45
70
110
71
144
4730
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.29—COMPARISON OF LCC SAVINGS FOR THE LODGING SECTOR SMALL BUSINESS SUBGROUP WITH THE
NATIONAL AVERAGE VALUES—Continued
Equipment class
Mean LCC savings
2013$ *
Category
TSL 1
RCU–Large–B1 .......................................
RCU–Large–B2 .......................................
SCU–W–Large–B ...................................
SCU–A–Small–B .....................................
SCU–A–Large–B ....................................
IMH–A–Small–C .....................................
IMH–A–Large–C .....................................
RCU–Small–C .........................................
SCU–A–Small–C ....................................
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 .................................
TSL 2
676
743
718
820
404
444
98
110
146
163
222
245
493
539
456
498
204
224
TSL 3
676
743
718
820
553
613
142
161
361
400
263
292
493
539
406
448
253
278
TSL 4
676
743
718
820
494
550
248
281
392
439
282
313
571
626
456
505
261
290
322
391
718
820
129
192
196
230
18
71
282
313
571
626
456
505
261
290
TSL 5
90
161
(205)
(109)
129
192
(182)
(145)
18
71
(189)
(165)
(33)
28
(133)
(73)
(288)
(268)
* Values in parentheses are negative numbers.
TABLE V.30—PERCENTAGE CHANGE IN MEAN LCC SAVINGS FOR THE LODGING SECTOR SMALL BUSINESS SUBGROUP
COMPARED TO NATIONAL AVERAGE VALUES *
TSL1
(%)
Equipment class
IMH–W–Small–B ......................................................................................
IMH–W–Med–B ........................................................................................
IMH–W–Large–B ......................................................................................
IMH–W–Large–B1 ...................................................................................
IMH–W–Large–B2 ...................................................................................
IMH–A–Small–B .......................................................................................
IMH–A–Large–B ......................................................................................
IMH–A–Large–B1 ....................................................................................
IMH–A–Large–B2 ....................................................................................
RCU–Large–B ..........................................................................................
RCU–Large–B1 ........................................................................................
RCU–Large–B2 ........................................................................................
SCU–W–Large–B .....................................................................................
SCU–A–Small–B ......................................................................................
SCU–A–Large–B .....................................................................................
IMH–A–Small–C ......................................................................................
IMH–A–Large–C ......................................................................................
RCU–Small–C ..........................................................................................
SCU–A–Small–C ......................................................................................
TSL2
(%)
–11
–11
NA
NA
NA
–13
–12
–9
–88
–9
–9
–12
–9
–11
–10
–9
–9
–8
–9
TSL3
(%)
–11
–11
NA
NA
NA
–25
–12
–10
–88
–9
–9
–12
–10
–11
–10
–10
–9
–9
–9
TSL4
(%)
–12
–11
NA
NA
NA
–21
–11
–10
–37
–9
–9
–12
–10
–12
–11
–10
–9
–10
–10
TSL5
(%)
–12
–26
NA
NA
NA
–21
–20
–19
–37
–17
–18
–12
–33
–15
–75
–10
–9
–10
–10
–5
–72
–29
–22
–84
–7
–118
–155
–37
–50
–44
–88
–33
–26
–75
–15
–215
–83
–7
* Negative percentage values imply decrease in LCC savings, and positive percentage values imply increase in LCC savings.
TABLE V.31—COMPARISON OF MEDIAN PAYBACK PERIODS FOR THE LODGING SECTOR SMALL BUSINESS SUBGROUP WITH
THE NATIONAL MEDIAN VALUES
Equipment class
Median payback period
years
Category
TSL 1
mstockstill on DSK4VPTVN1PROD with RULES2
IMH–W–Small–B .....................................
IMH–W–Med–B .......................................
IMH–W–Large–B ....................................
IMH–W–Large–B1 ..................................
IMH–W–Large–B2 ..................................
IMH–A–Small–B ......................................
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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 .......................................
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2.5
2.5
2.1
2.1
NA
NA
NA
NA
NA
NA
3.4
E:\FR\FM\28JAR2.SGM
2.5
2.5
2.1
2.1
NA
NA
NA
NA
NA
NA
4.8
28JAR2
TSL 3
2.8
2.7
2.1
2.1
NA
NA
NA
NA
NA
NA
4.7
TSL 4
2.8
2.7
5.1
5.0
NA
NA
NA
NA
NA
NA
4.7
TSL 5
13.5
13.4
7.7
7.6
10.7
10.6
11.2
11.1
9.0
8.9
12.3
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
4731
TABLE V.31—COMPARISON OF MEDIAN PAYBACK PERIODS FOR THE LODGING SECTOR SMALL BUSINESS SUBGROUP WITH
THE NATIONAL MEDIAN VALUES—Continued
Equipment class
Median payback period
years
Category
TSL 1
IMH–A–Large–B .....................................
IMH–A–Large–B1 ...................................
IMH–A–Large–B2 ...................................
RCU–Large–B .........................................
RCU–Large–B1 .......................................
RCU–Large–B2 .......................................
SCU–W–Large–B ...................................
SCU–A–Small–B .....................................
SCU–A–Large–B ....................................
IMH–A–Small–C .....................................
IMH–A–Large–C .....................................
RCU–Small–C .........................................
SCU–A–Small–C ....................................
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 .................................
Small Business .......................................
All Business Types .................................
Small Business .......................................
All Business Types .................................
Small Business .......................................
All Business Types .................................
Small Business .......................................
All Business Types .................................
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate
the impact of amended energy
conservation standards on
manufacturers of automatic commercial
ice makers. The following section
describes the expected impacts on
manufacturers at each TSL. Chapter 12
of the final rule TSD explains the
analysis in further detail.
mstockstill on DSK4VPTVN1PROD with RULES2
a. Industry Cash Flow Analysis Results
The following tables depict the
financial impacts of the new and
amended energy conservation standards
on manufacturers of automatic
commercial ice makers. The financial
impacts are represented by changes in
the industry net present value (INPV.) In
addition, the tables depict the
conversion costs that DOE estimates
manufacturers would incur for all
equipment classes at each TSL. The
impact of the energy efficiency
standards on industry cash flow were
analyzed under two markup scenarios
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3.4
2.2
2.2
1.2
1.2
7.5
7.4
1.1
1.1
0.9
0.9
3.0
3.0
1.1
1.1
2.2
2.2
1.8
1.8
1.5
1.5
0.7
0.7
0.7
0.7
0.8
0.8
that correspond to the range of
anticipated market responses to
amended energy conservation
standards.
The first markup scenario assessed
the lower bound of potential impacts
(higher profitability). DOE modeled a
preservation of gross margin percentage
markup scenario, in which a uniform
‘‘gross margin percentage’’ markup is
applied across all efficiency levels. In
this scenario, DOE assumed that a
manufacturer’s absolute dollar markup
would increase as production costs
increase in the amended energy
conservation standards case.
Manufacturers have indicated that it is
optimistic to assume that they would be
able to maintain the same gross margin
percentage markup as their production
costs increase in response to a new or
amended energy conservation standard,
particularly at higher TSLs.
The second markup scenario assessed
the upper bound of potential impacts
(lower profitability). DOE modeled the
preservation of the EBIT markup
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TSL 2
4.8
2.4
2.4
1.5
1.5
7.5
7.4
1.1
1.1
0.9
0.9
3.0
3.0
1.6
1.6
2.4
2.4
1.6
1.6
1.6
1.6
0.7
0.7
1.2
1.2
1.1
1.1
TSL 3
4.7
2.3
2.3
1.5
1.5
6.9
6.9
1.1
1.1
0.9
0.9
3.0
3.0
1.8
1.8
2.6
2.6
2.1
2.1
1.7
1.7
0.7
0.7
1.2
1.2
1.5
1.5
TSL 4
4.7
3.9
3.9
3.4
3.4
6.9
6.9
3.4
3.3
3.5
3.4
3.0
3.0
5.2
5.1
3.5
3.5
6.6
6.5
1.7
1.7
0.7
0.7
1.2
1.2
1.5
1.5
TSL 5
11.9
5.7
5.6
5.4
5.4
6.9
6.9
5.1
5.0
5.0
4.9
7.1
7.0
5.2
5.1
8.9
8.9
6.6
6.5
9.0
8.8
6.0
5.9
5.9
5.8
11.7
11.4
scenario, which assumes that
manufacturers would not be able to
preserve the same overall gross margin,
but instead would lower their markup
for marginally compliant products to
maintain a cost-competitive product
offering and keep the same overall level
of EBIT as in the base case. Table V.32
and Table V.33 show the range of
potential INPV impacts for
manufacturers of automatic commercial
ice makers. The first table reflects the
lower bound of impacts (higher
profitability), and the second represents
the upper bound of impacts (lower
profitability).
Each scenario 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 sum of discounted cash
flows through 2047, the difference in
INPV between the base case and each
standards case, and the total industry
conversion costs required for each
standards case.
E:\FR\FM\28JAR2.SGM
28JAR2
4732
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.32—MANUFACTURER IMPACT ANALYSIS FOR AUTOMATIC COMMERCIAL ICE MAKERS—PRESERVATION OF GROSS
MARGIN PERCENTAGE MARKUP SCENARIO *
Trial standard level
Units
Base case
1
INPV .............................................
Change in INPV ...........................
2
3
4
5
Product Conversion Costs ...........
Capital Conversion Costs ............
2013$ millions .............................
2013$ millions .............................
% .................................................
2013$ millions .............................
2013$ millions .............................
121.6
..................
..................
..................
..................
115.0
(6.6)
(5.4)
12.3
0.2
112.3
(9.3)
(7.7)
18.1
0.6
109.5
(12.1)
(10.0)
23.8
1.3
109.3
(12.3)
(10.1)
28.1
2.0
109.8
(11.8)
(9.7)
40.3
3.9
Total Conversion Costs ........
2013$ millions .............................
..................
12.6
18.7
25.1
30.0
44.1
* Values in parentheses are negative numbers.
TABLE V.33—MANUFACTURER IMPACT ANALYSIS FOR AUTOMATIC COMMERCIAL ICE MAKERS—PRESERVATION OF EBIT
MARKUP SCENARIO *
Trial standard level
Units
Base case
1
INPV .............................................
Change in INPV ...........................
2
3
4
5
Product Conversion Costs ...........
Capital Conversion Costs ............
2013$ millions .............................
2013$ millions .............................
% .................................................
2013$ millions .............................
2013$ millions .............................
121.6
..................
..................
..................
..................
114.1
(7.5)
(6.2)
12.3
0.2
110.4
(11.2)
(9.2)
18.1
0.6
106.5
(15.1)
(12.5)
23.8
1.3
103.0
(18.6)
(15.3)
28.1
2.0
91.6
(30.0)
(24.6)
40.3
3.9
Total Conversion Costs ........
2013$ millions .............................
..................
12.6
18.7
25.1
30.0
44.1
mstockstill on DSK4VPTVN1PROD with RULES2
* Values in parentheses are negative numbers.
Beyond impacts on INPV, DOE
includes a comparison of free cash flow
between the base case and the standards
case at each TSL in the year before
amended standards take effect to
provide perspective on the short-run
cash flow impacts in the discussion of
the following results.
At TSL 1, DOE estimates impacts on
INPV for manufacturers of automatic
commercial ice makers to range from
¥$7.5 million to ¥$6.6 million, or a
change in INPV of ¥6.2 percent to ¥5.4
percent. At this TSL, industry free cash
flow is estimated to decrease to $6.7
million, or a drop of 35.7 percent,
compared to the base-case value of
$10.4 million in the year before the
compliance date (2017).
DOE estimates that approximately 27
percent of all batch commercial ice
makers and 29 percent of all continuous
commercial ice makers on the market
will require redesign to meet standards
at TSL 1. At this TSL DOE expects
capital and product conversion costs of
$0.2 million and $12.3 million,
respectively. Combined, the total
conversion cost is $12.5 million.
At TSL 2, DOE estimates impacts on
INPV for manufacturers of automatic
commercial ice makers to range from
¥$11.2 million to ¥$9.3 million, or a
change in INPV of ¥9.2 percent to ¥7.7
percent. At this TSL, industry free cash
flow is estimated to decrease to $4.8
million, or a drop of 53.5 percent,
VerDate Sep<11>2014
20:54 Jan 27, 2015
Jkt 235001
compared to the base-case value of
$10.4 million in the year before the
compliance date (2017).
DOE estimates that approximately 39
percent of all batch commercial ice
makers and 41 percent of all continuous
commercial ice makers on the market
will require redesign to meet standards
at TSL 2. At this TSL, DOE expects
industry capital and product conversion
costs of $0.6 million and of $18.1
million, respectively. Combined, the
total conversion cost is $18.7 million, 48
percent higher than those incurred by
industry at TSL 1.
At TSL 3, DOE estimates impacts on
INPV for manufacturers of automatic
commercial ice makers to range from
¥$15.1 million to ¥$12.1 million, or a
change in INPV of ¥12.5 percent to
¥10.0 percent. At this TSL, industry
free cash flow is estimated to decrease
to $2.9 million, or a drop of 72.4
percent, compared to the base-case
value of $10.4 million in the year before
the compliance date (2017).
DOE estimates that approximately 51
percent of all batch commercial ice
makers and 55 percent of all continuous
commercial ice makers on the market
will require redesign to meet standards
at TSL 3. At this TSL, DOE expects
industry capital and product conversion
costs of $23.8 million and of $1.3
million, respectively. Combined, the
total conversion cost is $25.1 million, 34
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percent higher than those incurred by
industry at TSL 2.
At TSL 4, DOE estimates impacts on
INPV for manufacturers of automatic
commercial ice makers to range from
¥$18.6 million to ¥$12.3 million, or a
change in INPV of ¥15.3 percent to
¥10.1 percent. At this TSL, industry
free cash flow is estimated to decrease
to $0.9 million, or a drop of 91.1
percent, compared to the base-case
value of $10.4 million in the year before
the compliance date (2017).
DOE estimates that approximately 66
percent of all batch commercial ice
makers and 55 percent of all continuous
commercial ice makers on the market
will require redesign to meet standards
at TSL 4. Additionally, for four
equipment classes, there is only one
manufacturer with products that
currently meet the standard. At this
TSL, DOE expects industry capital and
product conversion costs of $2.0 million
and of $28.1 million, respectively.
Combined, the total conversion cost is
$30.0 million, 20 percent higher than
those incurred by industry at TSL 3.
At TSL 5, DOE estimates impacts on
INPV for manufacturers of automatic
commercial ice makers to range from
¥$30.0 million to ¥$11.8 million, or a
change in INPV of ¥24.6 percent to
¥9.7 percent. At this TSL, industry free
cash flow is estimated to decrease to
¥$5.3 million, or a drop of 151.1
percent, compared to the base-case
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value of $10.4 million in the year before
the compliance date (2017).
DOE estimates that approximately 84
percent of all batch commercial ice
makers and 78 percent of all continuous
commercial ice makers on the market
will require redesign to meet standards
at TSL 5. Additionally, for five
equipment classes, there is only one
manufacturer with products that
currently meet the standard. At this
TSL, DOE expects industry capital and
product conversion costs of $3.9 million
and of $40.3 million, respectively.
Combined, the total conversion cost is
$44.1 million, 47 percent higher than
those incurred by industry at TSL 4.
b. Impacts on Direct Employment
DOE used the GRIM to estimate the
domestic labor expenditures and
number of domestic production workers
in the base case and at each TSL from
2015 through 2047. DOE used statistical
data from the most recent U.S Census
Bureau’s 2011 Annual Survey of
Manufactures (ASM), the results of the
engineering analysis, and interviews
with manufacturers to determine the
inputs necessary to calculate industrywide labor expenditures and domestic
employment levels. Labor expenditures
related to the manufacture of a product
are a function of the labor intensity of
the product, the sales volume, and an
assumption that wages in real terms
remain constant.
4733
produce the same scope of covered
products in the U.S. The lower end of
employment results in Table V.34
represent the maximum decrease to the
total number of U.S. production workers
in the industry due to manufacturers
moving production outside of the U.S.
While the results present a range of
employment impacts following the
compliance date of the new and
amended energy conservation
standards, the following discussion also
includes a qualitative discussion of the
likelihood of negative employment
impacts at the various TSLs. Finally, the
employment impacts shown are
independent of the employment impacts
from the broader U.S. economy, which
are documented in chapter 13 of the
final rule TSD.
DOE estimates that in the absence of
amended energy conservation
standards, there would be 389 domestic
production workers involved in
manufacturing automatic commercial
ice makers in 2018. Using 2011 Census
Bureau data and interviews with
manufacturers, DOE estimates that
approximately 84 percent of automatic
commercial ice makers sold in the
United States are manufactured
domestically. Table V.34 shows the
range of the impacts of potential
amended energy conservation standards
on U.S. production workers in the
automatic commercial ice maker
industry.
In the GRIM, DOE used the labor
content of each product and the
manufacturing production costs from
the engineering analysis to estimate the
annual labor expenditures in the
automatic commercial ice maker
industry. 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 worker (production worker
hours multiplied by the labor rate found
in the U.S. Census Bureau’s ASM).
The estimates of production workers
in this section cover workers, including
line-supervisors, who are directly
involved in fabricating and assembling
automatic commercial ice makers
within an original equipment
manufacturer (OEM) facility. Workers
performing services that are closely
associated with production operations,
such as material handling with a
forklift, are also included as production
labor.
The employment impacts shown in
Table V.34 represent the potential
production employment changes that
could result following the compliance
date of new and amended energy
conservation standards. The upper end
of the employment results in Table V.34
estimates the maximum increase in the
number of production workers after
implementation of new or amended
energy conservation standards and it
assumes that manufacturers continue to
TABLE V.34—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC AUTOMATIC COMMERCIAL ICE MAKER
PRODUCTION WORKERS IN 2018
Base case
Total Number of Domestic Production Workers in 2018
(without changes in production locations) ....................
Potential Changes in Domestic Production Workers in
2018 * ............................................................................
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
389
391
402
414
418
444
....................
(389) to 2
(389) to 13
(389) to 25
(389) to 29
(389) to 55
mstockstill on DSK4VPTVN1PROD with RULES2
* DOE presents a range of potential employment impacts. Values in parentheses are negative numbers.
At all TSLs, most of the design
options analyzed by DOE do not greatly
alter the labor content of the final
product. For example, the use of higher
efficiency compressors or fan motors
involve one-time changes to the final
product but do not significantly change
the amount of production hours
required for the final assembly. One
manufacturer suggested that their
domestic production employment levels
would only change if market demand
contracted following higher overall
prices. However, more than one
manufacturer suggested that where they
already have overseas manufacturing
capabilities, they would consider
moving additional manufacturing to
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those facilities if they felt the need to
offset a significant rise in materials
costs. Provided the changes in materials
costs do not support the relocation of
manufacturing facilities, DOE would
expect only modest changes to domestic
manufacturing employment balancing
additional requirements for assembly
labor with the effects of price elasticity.
c. Impacts on Manufacturing Capacity
According to the majority of
automatic commercial ice maker
manufacturers interviewed, new or
amended energy conservation standards
that require modest changes to product
efficiency will not significantly affect
manufacturers’ production capacities.
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Any redesign of automatic commercial
ice makers would not change the
fundamental assembly of the
equipment, but manufacturers do
anticipate some potential for additional
lead time immediately following
standards associated with changes in
sourcing of higher efficiency
components, which may be supply
constrained.
One manufacturer cited the
possibility of a 3- to 6-month shutdown
in the event that amended standards
were set high enough to require
retooling of their entire product line.
Most of the design options that were
evaluated are already available on the
market as product options. Thus, DOE
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believes that, short of widespread
retooling, manufacturers will be able to
maintain manufacturing capacity levels
and continue to meet market demand
under amended energy conservation
standards.
d. Impacts on Subgroups of
Manufacturers
Small business, low-volume, niche
equipment manufacturers, and
manufacturers exhibiting a cost
structure substantially different from the
industry average could be affected
disproportionately. As discussed in
section IV.J, using average cost
assumptions to develop an industry
cash flow estimate is inadequate to
assess differential impacts among
manufacturer subgroups.
For automatic commercial ice makers,
DOE identified and evaluated the
impact of amended energy conservation
standards on one subgroup: small
manufacturers. The SBA defines a
‘‘small business’’ as having fewer than
750 employees for NAICS 333415, ‘‘Air-
Conditioning and Warm Air Heating
Equipment and Commercial and
Industrial Refrigeration Equipment
Manufacturing,’’ which includes icemaking machinery manufacturing. DOE
identified seven manufacturers in the
automatic commercial ice makers
industry that meet this definition.
For a discussion of the impacts on the
small manufacturer subgroup, see the
regulatory flexibility analysis in section
VI.B of this preamble and chapter 12 of
the final rule TSD.
e. Cumulative Regulatory Burden
While any one regulation may not
impose a significant burden on
manufacturers, the combined effects of
recent or 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. In addition to energy
conservation standards, other
regulations can significantly affect
manufacturers’ financial operations.
Multiple regulations affecting the same
manufacturer can strain profits and 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
equipment efficiency.
For the cumulative regulatory burden
analysis, DOE looks at other regulations
that could affect ACIM manufacturers
that will take effect approximately 3
years before or after the 2018
compliance date of amended energy
conservation standards for these
products. In written comments,
manufacturers cited Federal regulations
on equipment other than automatic
commercial ice makers that contribute
to their cumulative regulatory burden.
The compliance years and expected
industry conversion costs of relevant
amended energy conservation standards
are indicated in Table V.35.
TABLE V.35—COMPLIANCE DATES AND EXPECTED CONVERSION EXPENSES OF FEDERAL ENERGY CONSERVATION
STANDARDS AFFECTING AUTOMATIC COMMERCIAL ICE MAKER MANUFACTURERS
Federal energy conservation standards
Approximate
compliance date
Estimated total
industry
conversion
expense
Commercial refrigeration equipment, 79 FR 17725 (March 28, 2014) ...................................................
Walk-in Coolers and Freezers, 79 FR 32049 (June 3, 2014) .................................................................
Miscellaneous Refrigeration Equipment * ................................................................................................
2017
2017
TBD
$184.0M, (2012$)
$33.6.0M, (2012$)
TBD
* The final rule for this energy conservation standard has not been published. The compliance date and analysis of conversion costs have not
been finalized at this time.
DOE discusses these and other
requirements and includes the full
details of the cumulative regulatory
burden analysis in chapter 12 of the
final rule TSD.
3. National Impact Analysis
a. Amount and Significance of Energy
Savings
DOE estimated the NES by calculating
the difference in annual energy
consumption for the base-case scenario
and standards-case scenario at each TSL
for each equipment class and summing
up the annual energy savings for the
automatic commercial ice maker
equipment purchased during the 30year 2018 through 2047 analysis period.
Energy impacts include the 30-year
period, plus the life of equipment
purchased in the last year of the
analysis, or roughly 2018 through 2057.
The energy consumption calculated in
the NIA is full-fuel-cycle (FFC) energy,
which quantifies savings beginning at
the source of energy production. DOE
also reports primary or source energy
that takes into account losses in the
generation and transmission of
electricity. FFC and primary energy are
discussed in section IV.H.3.
Table V.36 presents the source NES
for all equipment classes at each TSL
and the sum total of NES for each TSL.
Table V.37 presents the energy
savings at each TSL for each equipment
class in the form of percentage of the
cumulative energy use of the equipment
stock in the base-case scenario.
TABLE V.36—CUMULATIVE NATIONAL ENERGY SAVINGS AT SOURCE FOR EQUIPMENT PURCHASED IN 2018–2047
[Quads]
Standard level * **
mstockstill on DSK4VPTVN1PROD with RULES2
Equipment class
TSL 1
IMH–W–Small–B ......................................................................................
IMH–W–Med–B ........................................................................................
IMH–W–Large–B † ...................................................................................
IMH–W–Large–B1 ...................................................................................
IMH–W–Large–B2 ...................................................................................
IMH–A–Small–B .......................................................................................
IMH–A–Large–B † ....................................................................................
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0.005
0.000
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0.000
0.000
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0.004
0.005
0.000
0.000
0.000
0.037
0.039
28JAR2
TSL 4
0.004
0.008
0.000
0.000
0.000
0.037
0.058
TSL 5
0.009
0.010
0.002
0.001
0.001
0.071
0.075
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TABLE V.36—CUMULATIVE NATIONAL ENERGY SAVINGS AT SOURCE FOR EQUIPMENT PURCHASED IN 2018–2047—
Continued
[Quads]
Standard level * **
Equipment class
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
IMH–A–Large–B1 ....................................................................................
IMH–A–Large–B2 ....................................................................................
RCU–Large–B † .......................................................................................
RCU–Large–B1 ........................................................................................
RCU–Large–B2 ........................................................................................
SCU–W–Large–B .....................................................................................
SCU–A–Small–B ......................................................................................
SCU–A–Large–B .....................................................................................
IMH–A–Small–C ......................................................................................
IMH–A–Large–C ......................................................................................
RCU–Small–C ..........................................................................................
SCU–A–Small–C ......................................................................................
0.016
0.002
0.015
0.014
0.001
0.000
0.007
0.006
0.002
0.002
0.001
0.006
0.031
0.002
0.015
0.014
0.001
0.001
0.018
0.014
0.004
0.002
0.002
0.010
0.035
0.003
0.015
0.014
0.001
0.001
0.024
0.019
0.006
0.003
0.003
0.015
0.055
0.003
0.029
0.027
0.001
0.001
0.032
0.023
0.006
0.003
0.003
0.015
0.071
0.003
0.037
0.035
0.002
0.001
0.036
0.023
0.009
0.006
0.005
0.023
Total ..................................................................................................
0.077
0.130
0.171
0.219
0.307
* A value equal to 0.000 means the NES rounds to less than 0.001 quads.
** Numbers may not add to totals, due to rounding.
† IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B results are the sum of the results for the two typical units denoted by B1 and B2.
TABLE V.37—CUMULATIVE SOURCE ENERGY SAVINGS BY TSL AS A PERCENTAGE OF CUMULATIVE BASELINE ENERGY
USAGE OF AUTOMATIC COMMERCIAL ICE MAKER EQUIPMENT PURCHASED IN 2018–2047
Base case
energy
usage
(quads)
Equipment class
TSL Savings as percent of baseline usage
TSL 1
(%)
TSL 2
(%)
TSL 3
(%)
TSL 4
(%)
TSL 5
(%)
IMH–W–Small–B ..............................................................
IMH–W–Med–B ................................................................
IMH–W–Large–B * ............................................................
IMH–W–Large–B1 ............................................................
IMH–W–Large–B2 ............................................................
IMH–A–Small–B ...............................................................
IMH–A–Large–B * .............................................................
IMH–A–Large–B1 .............................................................
IMH–A–Large–B2 .............................................................
RCU–Large–B * ................................................................
RCU–Large–B1 ................................................................
RCU–Large–B2 ................................................................
SCU–W–Large–B .............................................................
SCU–A–Small–B ..............................................................
SCU–A–Large–B ..............................................................
IMH–A–Small–C ...............................................................
IMH–A–Large–C ..............................................................
RCU–Small–C ..................................................................
SCU–A–Small–C ..............................................................
0.064
0.089
0.028
0.018
0.010
0.467
0.644
0.495
0.149
0.368
0.343
0.026
0.004
0.150
0.102
0.071
0.044
0.031
0.145
4
5
0
0
0
2
3
3
2
4
4
4
7
5
6
3
4
3
4
4
5
0
0
0
5
5
6
2
4
4
4
14
12
14
5
4
6
7
6
5
0
0
0
8
6
7
2
4
4
4
18
16
19
8
7
10
10
6
9
0
0
0
8
9
11
2
8
8
4
23
21
23
8
7
10
10
15
12
6
7
6
15
12
14
2
10
10
7
23
24
23
12
14
16
16
Total ..........................................................................
2.206
3
6
8
10
14
* IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B results are the sum of the results for the 2 typical units denoted by B1 and B2.
Table V.38 presents energy savings at
each TSL for each equipment class with
the FFC adjustment. The NES increases
from 0.081 quads at TSL 1 to 0.321
quads at TSL 5.
mstockstill on DSK4VPTVN1PROD with RULES2
TABLE V.38—CUMULATIVE NATIONAL ENERGY SAVINGS INCLUDING FULL-FUEL-CYCLE FOR EQUIPMENT PURCHASED IN
2018–2047
[Quads]
Standard level * **
Equipment class
TSL 1
IMH–W–Small–B ......................................................................................
IMH–W–Med–B ........................................................................................
IMH–W–Large–B † ...................................................................................
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0.000
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0.004
0.005
0.000
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0.004
0.008
0.000
TSL 5
0.010
0.011
0.002
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TABLE V.38—CUMULATIVE NATIONAL ENERGY SAVINGS INCLUDING FULL-FUEL-CYCLE FOR EQUIPMENT PURCHASED IN
2018–2047—Continued
[Quads]
Standard level * **
Equipment class
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
IMH–W–Large–B1 ...................................................................................
IMH–W–Large–B2 ...................................................................................
IMH–A–Small–B .......................................................................................
IMH–A–Large–B † ....................................................................................
IMH–A–Large–B1 ....................................................................................
IMH–A–Large–B2 ....................................................................................
RCU–Large–B † .......................................................................................
RCU–Large–B1 ........................................................................................
RCU–Large–B2 ........................................................................................
SCU–W–Large–B .....................................................................................
SCU–A–Small–B ......................................................................................
SCU–A–Large–B .....................................................................................
IMH–A–Small–C ......................................................................................
IMH–A–Large–C ......................................................................................
RCU–Small–C ..........................................................................................
SCU–A–Small–C ......................................................................................
0.000
0.000
0.011
0.020
0.017
0.003
0.016
0.015
0.001
0.000
0.008
0.006
0.002
0.002
0.001
0.007
0.000
0.000
0.024
0.035
0.033
0.003
0.016
0.015
0.001
0.001
0.019
0.015
0.004
0.002
0.002
0.011
0.000
0.000
0.039
0.040
0.037
0.004
0.016
0.015
0.001
0.001
0.026
0.020
0.006
0.003
0.003
0.016
0.000
0.000
0.039
0.061
0.057
0.004
0.030
0.029
0.001
0.001
0.033
0.024
0.006
0.003
0.003
0.016
0.001
0.001
0.075
0.078
0.075
0.004
0.038
0.037
0.002
0.001
0.037
0.024
0.009
0.007
0.005
0.024
Total ..................................................................................................
0.081
0.136
0.179
0.229
0.321
* A value equal to 0.000 means the NES rounds to less than 0.001 quads
** Numbers may not add to totals due to rounding.
† IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B results are the sum of the results for the 2 typical units denoted by B1 and B2.
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 9,
rather than 30, years of product
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.73 The review
timeframe established in EPCA
generally is not synchronized with the
product lifetime, product manufacturing
cycles or other factors specific to
automatic commercial ice makers. Thus,
this information is presented for
informational purposes only and is not
indicative of any change in DOE’s
analytical methodology. The NES
results based on a 9-year analysis period
are presented in Table V.39 . The
impacts are counted over the lifetime of
equipment purchased in 2018 through
2026.
TABLE V.39—NATIONAL FULL-FUEL-CYCLE ENERGY SAVINGS FOR 9-YEAR ANALYSIS PERIOD FOR EQUIPMENT
PURCHASED IN 2018–2026
[Quads]
Standard level * **
Equipment class
mstockstill on DSK4VPTVN1PROD with RULES2
TSL 1
IMH–W–Small–B ......................................................................................
IMH–W–Med–B ........................................................................................
IMH–W–Large–B † ...................................................................................
IMH–W–Large–B1 ...................................................................................
IMH–W–Large–B2 ...................................................................................
IMH–A–Small–B .......................................................................................
IMH–A–Large–B † ....................................................................................
IMH–A–Large–B1 ....................................................................................
IMH–A–Large–B2 ....................................................................................
RCU–Large–B † .......................................................................................
RCU–Large–B1 ........................................................................................
RCU–Large–B2 ........................................................................................
SCU–W–Large–B .....................................................................................
SCU–A–Small–B ......................................................................................
73 For automatic commercial ice makers, DOE is
required to review standards at least every five
years after the effective date of any amended
standards. (42 U.S.C. 6313(d)(3)(B)) If new
standards are promulgated, EPCA requires DOE to
provide manufacturers a minimum of 3 and a
maximum of 5 years to comply with the standards.
(42 U.S.C. 6313(d)(3)(C)) In addition, for certain
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0.001
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0.005
0.000
0.000
0.002
other types of commercial equipment that are not
specified in 42 U.S.C. 6311(1)(B)–(G), EPCA
requires DOE to review its standards at least once
every 6 years (42 U.S.C. 6295(m)(1) and 6316(a)),
and either a 3-year or a 5-year period after any new
standard is promulgated before compliance is
required. (42 U.S.C. 6295(m)(4) and 6316(a)) As a
result, DOE’s standards for automatic commercial
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0.001
0.001
0.000
0.000
0.000
0.007
0.011
0.010
0.001
0.005
0.005
0.000
0.000
0.006
0.001
0.001
0.000
0.000
0.000
0.012
0.012
0.011
0.001
0.005
0.005
0.000
0.000
0.008
TSL 4
0.001
0.002
0.000
0.000
0.000
0.012
0.018
0.017
0.001
0.009
0.009
0.000
0.000
0.010
TSL 5
0.003
0.003
0.001
0.000
0.000
0.022
0.023
0.022
0.001
0.012
0.011
0.001
0.000
0.011
ice makers can be expected to be in effect for 8 to
10 years between compliance dates, and its
standards governing certain other commercial
equipment, the period is 9 to 11 years. A 9-year
analysis was selected as representative of the time
between standard revisions.
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TABLE V.39—NATIONAL FULL-FUEL-CYCLE ENERGY SAVINGS FOR 9-YEAR ANALYSIS PERIOD FOR EQUIPMENT
PURCHASED IN 2018–2026—Continued
[Quads]
Standard level * **
Equipment class
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
SCU–A–Large–B .....................................................................................
IMH–A–Small–C ......................................................................................
IMH–A–Large–C ......................................................................................
RCU–Small–C ..........................................................................................
SCU–A–Small–C ......................................................................................
0.002
0.001
0.001
0.000
0.002
0.004
0.001
0.001
0.001
0.003
0.006
0.002
0.001
0.001
0.005
0.007
0.002
0.001
0.001
0.005
0.007
0.003
0.002
0.002
0.007
Total ..................................................................................................
0.024
0.041
0.054
0.069
0.097
* A value equal to 0.000 means the NES rounds to less than 0.001 quads.
** Numbers may not add to totals due to rounding.
† IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B results are the sum of the results for the 2 typical units denoted by B1 and B2.
b. Net Present Value of Customer Costs
and Benefits
DOE estimated the cumulative NPV to
the Nation of the total savings for the
customers that would result from
potential standards at each TSL. 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
opportunity cost of capital in the private
sector, because 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 amended
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 CPI), which has
averaged about 3 percent on a pre-tax
basis for the last 30 years.
Table V.40 and Table V.41 show the
customer NPV results for each of the
TSLs DOE considered for automatic
commercial ice makers at both 7-percent
and 3-percent discount rates,
respectively. In each case, the impacts
cover the expected lifetime of
equipment purchased from 2018
through 2047. Detailed NPV results are
presented in chapter 10 of the final rule
TSD.
The NPV results at a 7-percent
discount rate for TSL 5 were negative
for 9 classes, and also for one of the
typical size units of a large batch
equipment class for which the class
total was positive. In all cases the TSL
5 NPV was significantly lower than the
TSL 3 results. This is consistent with
the LCC analysis results for TSL 5,
which showed significant increase in
LCC and significantly higher PBPs that
were in some cases greater than the
average equipment lifetimes. Efficiency
levels for TSL 4 were chosen to
correspond to the highest efficiency
level with a positive NPV for all classes
at a 7-percent discount rate. Similarly,
the criteria for choice of efficiency
levels for TSL 3, TSL 2, and TSL 1 were
such that the NPV values for all the
equipment classes show positive values.
The criterion for TSL 3 was to select
efficiency levels with the highest NPV at
a 7-percent discount rate. Consequently,
the total NPV for automatic commercial
ice makers was highest for TSL 3, with
a value of $0.430 billion (2013$) at a 7percent discount rate. TSL 4 showed the
second highest total NPV, with a value
of $0.337 billion (2013$) at a 7-percent
discount rate. TSL 1, TSL 2 and TSL 5
have a total NPV lower than TSL 3 or
4.
TABLE V.40—NET PRESENT VALUE AT A 7-PERCENT DISCOUNT RATE FOR EQUIPMENT PURCHASED IN 2018–2047
[Billion 2013$]
Standard level *
Equipment class
mstockstill on DSK4VPTVN1PROD with RULES2
TSL 1
IMH–W–Small–B ................................................................................
IMH–W–Med–B ..................................................................................
IMH–W–Large–B ** ............................................................................
IMH–W–Large–B1 ..............................................................................
IMH–W–Large–B2 ..............................................................................
IMH–A–Small–B .................................................................................
IMH–A–Large–B ** .............................................................................
IMH–A–Large–B1 ...............................................................................
IMH–A–Large–B2 ...............................................................................
RCU–Large–B ** ................................................................................
RCU–Large–B1 ..................................................................................
RCU–Large–B2 ..................................................................................
SCU–W–Large–B ...............................................................................
SCU–A–Small–B ................................................................................
SCU–A–Large–B ................................................................................
IMH–A–Small–C .................................................................................
IMH–A–Large–C ................................................................................
RCU–Small–C ....................................................................................
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0.006
0.010
0.000
0.000
0.000
0.017
0.043
0.043
(0.000)
0.042
0.040
0.002
0.002
0.016
0.014
0.006
0.005
0.002
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TSL 2
0.006
0.010
0.000
0.000
0.000
0.017
0.109
0.109
(0.000)
0.042
0.040
0.002
0.002
0.037
0.059
0.009
0.005
0.004
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TSL 3
0.011
0.010
0.000
0.000
0.000
0.036
0.120
0.119
0.001
0.042
0.040
0.002
0.003
0.076
0.064
0.014
0.009
0.008
28JAR2
TSL 4
0.011
0.006
0.000
0.000
0.000
0.036
0.109
0.107
0.001
0.035
0.033
0.002
0.001
0.068
0.004
0.014
0.009
0.008
TSL 5
(0.049)
(0.008)
(0.002)
(0.002)
(0.000)
(0.238)
0.021
0.020
0.001
0.007
0.008
(0.001)
0.001
(0.060)
0.004
(0.014)
(0.001)
(0.003)
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.40—NET PRESENT VALUE AT A 7-PERCENT DISCOUNT RATE FOR EQUIPMENT PURCHASED IN 2018–2047—
Continued
[Billion 2013$]
Standard level *
Equipment class
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
SCU–A–Small–C ................................................................................
0.018
0.027
0.036
0.036
(0.062)
Total ............................................................................................
0.183
0.328
0.430
0.337
(0.406)
* A value equal to 0.000 means the NPV rounds to less than $0.001 (2013$). Values in parentheses are negative numbers.
** IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B results are the sum of the results for the 2 typical units denoted by B1 and B2.
TABLE V.41—NET PRESENT VALUE AT A 3-PERCENT DISCOUNT RATE FOR EQUIPMENT PURCHASED IN 2018–2047
[Billion 2013$]
Standard level *
Equipment class
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
IMH–W–Small–B ................................................................................
IMH–W–Med–B ..................................................................................
IMH–W–Large–B ** ............................................................................
IMH–W–Large–B1 ..............................................................................
IMH–W–Large–B2 ..............................................................................
IMH–A–Small–B .................................................................................
IMH–A–Large–B ** .............................................................................
IMH–A–Large–B1 ...............................................................................
IMH–A–Large–B2 ...............................................................................
RCU–Large–B ** ................................................................................
RCU–Large–B1 ..................................................................................
RCU–Large–B2 ..................................................................................
SCU–W–Large–B ...............................................................................
SCU–A–Small–B ................................................................................
SCU–A–Large–B ................................................................................
IMH–A–Small–C .................................................................................
IMH–A–Large–C ................................................................................
RCU–Small–C ....................................................................................
SCU–A–Small–C ................................................................................
0.014
0.022
0.000
0.000
0.000
0.039
0.091
0.090
0.001
0.088
0.084
0.004
0.003
0.035
0.030
0.012
0.011
0.005
0.038
0.014
0.022
0.000
0.000
0.000
0.046
0.234
0.233
0.001
0.088
0.084
0.004
0.005
0.079
0.127
0.019
0.011
0.009
0.057
0.025
0.022
0.000
0.000
0.000
0.092
0.259
0.254
0.005
0.088
0.084
0.004
0.005
0.169
0.138
0.030
0.019
0.017
0.076
0.025
0.016
0.000
0.000
0.000
0.092
0.271
0.266
0.005
0.084
0.080
0.004
0.002
0.159
0.031
0.030
0.019
0.017
0.076
(0.074)
(0.008)
(0.003)
(0.003)
(0.000)
(0.360)
0.122
0.117
0.005
0.039
0.039
(0.001)
0.002
(0.075)
0.031
(0.022)
0.001
(0.002)
(0.103)
Total ............................................................................................
0.389
0.712
0.942
0.822
(0.453)
* A value equal to 0.000 means the NPV rounds to less than $0.001 (2013$). Values in parentheses are negative numbers.
** IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B results are the sum of the results for the 2 typical units denoted by B1 and B2.
The NPV results based on the
aforementioned 9-year analysis period
are presented in Table V.42 and Table
V.43. The impacts are counted over the
lifetime of equipment purchased in
2018–2026. 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.42—NET PRESENT VALUE AT A 7-PERCENT DISCOUNT RATE FOR 9-YEAR ANALYSIS PERIOD FOR EQUIPMENT
PURCHASED IN 2018–2026
[Billion 2013$]
Standard level *
Equipment class
mstockstill on DSK4VPTVN1PROD with RULES2
TSL 1
IMH–W–Small–B ................................................................................
IMH–W–Med–B ..................................................................................
IMH–W–Large–B ................................................................................
IMH–W–Large–B–1 ............................................................................
IMH–W–Large–B–2 ............................................................................
IMH–A–Small–B .................................................................................
IMH–A–Large–B .................................................................................
IMH–A–Large–B–1 .............................................................................
IMH–A–Large–B–2 .............................................................................
RCU–Large–B ....................................................................................
RCU–Large–B–1 ................................................................................
RCU–Large–B–2 ................................................................................
SCU–W–Large–B ...............................................................................
SCU–A–Small–B ................................................................................
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0.003
0.005
0.000
0.000
0.000
0.009
0.021
0.021
(0.000)
0.021
0.020
0.001
0.001
0.008
Sfmt 4700
TSL 2
0.003
0.005
0.000
0.000
0.000
0.009
0.051
0.052
(0.000)
0.021
0.020
0.001
0.001
0.018
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TSL 3
0.005
0.005
0.000
0.000
0.000
0.018
0.057
0.057
0.001
0.021
0.020
0.001
0.001
0.036
28JAR2
TSL 4
0.005
0.003
0.000
0.000
0.000
0.018
0.036
0.036
0.001
0.018
0.017
0.001
0.000
0.032
TSL 5
(0.030)
(0.004)
(0.001)
(0.001)
(0.000)
(0.137)
(0.005)
(0.006)
0.001
0.004
0.005
(0.001)
0.000
(0.030)
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
4739
TABLE V.42—NET PRESENT VALUE AT A 7-PERCENT DISCOUNT RATE FOR 9-YEAR ANALYSIS PERIOD FOR EQUIPMENT
PURCHASED IN 2018–2026—Continued
[Billion 2013$]
Standard level *
Equipment class
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
SCU–A–Large–B ................................................................................
IMH–A–Small–C .................................................................................
IMH–A–Large–C ................................................................................
RCU–Small–C ....................................................................................
SCU–A–Small–C ................................................................................
0.007
0.003
0.003
0.001
0.009
0.028
0.004
0.003
0.002
0.013
0.030
0.007
0.005
0.004
0.018
0.001
0.007
0.005
0.004
0.018
0.001
(0.007)
(0.000)
(0.001)
(0.030)
Total ............................................................................................
0.090
0.158
0.207
0.147
(0.241)
* A value equal to 0.000 means the NPV rounds to less than $0.001 (2013$). Values in parentheses are negative numbers.
TABLE V.43—NET PRESENT VALUE AT A 3-PERCENT DISCOUNT RATE FOR 9-YEAR ANALYSIS PERIOD FOR EQUIPMENT
PURCHASED IN 2018–2026
[Billion 2013$]
Standard level *
Equipment class
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
IMH–W–Small–B ....................................................................................
IMH–W–Med–B ......................................................................................
IMH–W–Large–B ....................................................................................
IMH–W–Large–B–1 ................................................................................
IMH–W–Large–B–2 ................................................................................
IMH–A–Small–B .....................................................................................
IMH–A–Large–B .....................................................................................
IMH–A–Large–B–1 .................................................................................
IMH–A–Large–B–2 .................................................................................
RCU–Large–B ........................................................................................
RCU–Large–B–1 ....................................................................................
RCU–Large–B–2 ....................................................................................
SCU–W–Large–B ...................................................................................
SCU–A–Small–B ....................................................................................
SCU–A–Large–B ...................................................................................
IMH–A–Small–C .....................................................................................
IMH–A–Large–C ....................................................................................
RCU–Small–C ........................................................................................
SCU–A–Small–C ....................................................................................
0.005
0.008
0.000
0.000
0.000
0.014
0.033
0.033
0.001
0.032
0.030
0.002
0.001
0.013
0.011
0.004
0.004
0.002
0.014
0.005
0.008
0.000
0.000
0.000
0.017
0.081
0.081
0.001
0.032
0.030
0.002
0.002
0.029
0.043
0.007
0.004
0.003
0.021
0.009
0.008
0.000
0.000
0.000
0.035
0.090
0.089
0.002
0.032
0.030
0.002
0.002
0.057
0.047
0.011
0.007
0.006
0.028
0.009
0.006
0.000
0.000
0.000
0.035
0.067
0.065
0.002
0.031
0.030
0.002
0.001
0.054
0.010
0.011
0.007
0.006
0.028
(0.038)
(0.002)
(0.001)
(0.001)
(0.000)
(0.168)
0.016
0.014
0.002
0.015
0.016
(0.000)
0.001
(0.029)
0.010
(0.008)
0.001
(0.001)
(0.037)
Total ................................................................................................
0.142
0.253
0.332
0.264
(0.241)
* A value equal to 0.000 means the NPV rounds to less than $0.001 (2013$). Values in parentheses are negative numbers.
c. Water Savings
One energy-saving design option for
batch type ice makers had the additional
benefit of reducing potable water usage
for some types of batch type ice makers.
The water savings are identified on
Table V.44. DOE is not, as part of this
rulemaking, establishing a potable water
standard. The water savings identified
through the analyses are products of the
analysis of energy-saving design
options.
TABLE V.44—WATER SAVINGS
Water savings by standard level * **
million gallons
Equipment class
mstockstill on DSK4VPTVN1PROD with RULES2
TSL 1
IMH–W–Small–B ......................................................................................
IMH–W–Med–B ........................................................................................
IMH–W–Large–B ......................................................................................
IMH–W–Large–B1 ...................................................................................
IMH–W–Large–B2 ...................................................................................
IMH–A–Small–B .......................................................................................
IMH–A–Large–B ......................................................................................
IMH–A–Large–B1 ....................................................................................
IMH–A–Large–B2 ....................................................................................
RCU–Large–B ..........................................................................................
RCU–Large–B1 ........................................................................................
RCU–Large–B2 ........................................................................................
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761
0
0
0
0
0
0
0
0
0
0
0
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761
0
0
0
0
0
12,501
12,501
0
0
0
0
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TSL 3
1,733
0
0
0
0
0
12,501
12,501
0
0
0
0
28JAR2
TSL 4
1,733
0
0
0
0
0
11,733
11,733
0
0
0
0
TSL 5
1,733
0
0
0
0
–5,424
11,733
11,733
0
0
0
0
4740
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.44—WATER SAVINGS—Continued
Water savings by standard level * **
million gallons
Equipment class
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
SCU–W–Large–B .....................................................................................
SCU–A–Small–B ......................................................................................
SCU–A–Large–B .....................................................................................
IMH–A–Small–C ......................................................................................
IMH–A–Large–C ......................................................................................
RCU–Small–C ..........................................................................................
SCU–A–Small–C ......................................................................................
336
0
0
0
0
0
0
336
0
9,388
0
0
0
0
336
13,580
9,388
0
0
0
0
336
13,580
9,388
0
0
0
0
336
13,580
9,388
0
0
0
0
Total ..................................................................................................
1,097
22,987
37,539
36,771
31,347
mstockstill on DSK4VPTVN1PROD with RULES2
* A zero indicates no water usage reductions were identified.
** IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B results are the sum of the results for the 2 typical units denoted by B1 and B2.
d. Indirect Employment Impacts
In addition to the direct impacts on
manufacturing employment discussed
in section IV.N, DOE develops general
estimates of the indirect employment
impacts of the new and amended
standards on the economy. DOE expects
amended energy conservation standards
for automatic commercial ice makers to
reduce energy bills for commercial
customers and expects 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 automatic
commercial ice maker 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 new
and amended standards. These impacts
may affect a variety of businesses not
directly involved in the decision to
make, operate, or pay the utility bills for
automatic commercial ice makers. 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 BLS data (as
described in section IV.J of this
rulemaking; see chapter 16 of the final
rule TSD for more details).
Customers who purchase moreefficient equipment pay lower amounts
towards utility bills, which results in
job losses in the electric utilities sector.
In this input/output model, the dollars
saved on utility bills from more-efficient
automatic commercial ice makers are
spent in economic sectors that create
more jobs than are lost in electric and
water utilities sectors. Thus, the new
and amended energy conservation
standards for automatic commercial ice
makers are likely to slightly increase the
net demand for labor in the economy.
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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
includes the quality of jobs. As shown
in Table V.45, DOE estimates that net
indirect employment impacts from new
and amended automatic commercial ice
makers standard are small relative to the
national economy.
TABLE V.45—NET SHORT-TERM
CHANGE IN EMPLOYMENT
[Number of employees]
Trial standard
level
1
2
3
4
5
....................
....................
....................
....................
....................
2018
18 to 21 .......
31 to 38 .......
41 to 52 .......
41 to 63 .......
4 to 82 .........
2022
104
196
263
315
376
to
to
to
to
to
107.
204.
276.
340.
464.
4. Impact on Utility or Performance of
Equipment
In performing the engineering
analysis, DOE considers design options
that would not lessen the utility or
performance of the individual classes of
equipment. (42 U.S.C.
6295(o)(2)(B)(i)(IV) and 6313(d)(4)) As
presented in the screening analysis
(chapter 4 of the final rule TSD), DOE
eliminates from consideration any
design options that reduce the utility of
the equipment. For this rulemaking,
DOE did not consider TSLs for
automatic commercial ice makers that
reduce the utility or performance of the
equipment.
5. Impact of Any Lessening of
Competition
EPCA directs DOE to consider any
lessening of competition likely to result
from amended standards. It directs the
Attorney General of the United States
(Attorney General) to determine in
writing the impact, if any, of any
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lessening of competition likely to result
from a proposed standard. (42 U.S.C.
6295(o)(2)(B)(i)(V) and 6313(d)(4)) To
assist the Attorney General in making
such a determination, DOE provided the
DOJ with copies of this rule and the
TSD for review. During MIA interviews,
domestic manufacturers indicated that
foreign manufacturers have begun to
enter the automatic commercial ice
maker industry, but not in significant
numbers. Manufacturers also stated that
consolidation has occurred among
automatic commercial ice makers
manufacturers in recent years.
Interviewed manufacturers believe that
these trends may continue in this
market even in the absence of amended
standards.
More than one manufacturer
suggested that where they already have
overseas manufacturing capabilities,
they would consider moving additional
manufacturing to those facilities if they
felt the need to offset a significant rise
in materials costs. The Department
acknowledges that to be competitive in
the marketplace manufacturers must
constantly re-examine their supply
chains and manufacturing
infrastructure. DOE does not believe
however, that at the levels specified in
this final rule, amended standards
would result in domestic firms
relocating significant portions of their
domestic production capacity to other
countries. The majority of automatic
commercial ice makers are
manufactured in the U.S. and the
amended standards are at levels which
are already met by a large portion of the
product models being manufactured.
The amended standards can largely be
met using existing capital assets and
during interviews, manufacturers in
general indicated they would modify
their existing facilities to comply with
amended energy conservation
standards.
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
6. Need of the Nation To Conserve
Energy
An improvement in the energy
efficiency of the equipment subject to
this final rule is likely to improve the
security of the Nation’s energy system
by reducing overall demand for energy.
Reduced electricity demand resulting
from energy conservation may also
improve the reliability of the electricity
system. As a measure of this reduced
demand, chapter 15 in the final rule
TSD presents the estimated reduction in
national generating capacity for the
TSLs that DOE considered in this
rulemaking.
Energy savings from new and
amended standards for automatic
commercial ice makers could also
produce environmental benefits in the
form of reduced emissions of air
pollutants and GHGs associated with
electricity production. Table V.46
4741
provides DOE’s estimate of cumulative
CO2, NOX, Hg, N2O, CH4 and SO2
emissions reductions projected to result
from the TSLs considered in this rule.
The table includes both power sector
emissions and upstream emissions. The
upstream emissions were calculated
using the multipliers discussed in
section IV.K. DOE reports annual
emissions reductions for each TSL in
chapter 13 of the final rule TSD.
TABLE V.46—SUMMARY OF EMISSIONS REDUCTION ESTIMATED FOR AUTOMATIC COMMERCIAL ICE MAKERS TSLS
[Cumulative for equipment purchased in 2018–2047]
TSL
1
2
3
4
5
Power Sector and Site Emissions
CO2 (million metric tons) ..........................................................................
NOX (thousand tons) ...............................................................................
Hg (tons) ..................................................................................................
N2O (thousand tons) ................................................................................
CH4 (thousand tons) ................................................................................
SO2 (thousand tons) ................................................................................
4.68
3.71
0.01
0.06
0.44
4.13
7.87
6.23
0.02
0.11
0.73
6.95
10.38
8.22
0.03
0.14
0.97
9.17
13.25
10.50
0.04
0.18
1.24
11.70
18.62
14.75
0.05
0.25
1.74
16.45
0.42
6.03
0.00
0.00
35.15
0.08
0.56
7.96
0.00
0.00
46.40
0.10
0.72
10.17
0.00
0.01
59.23
0.13
1.00
14.29
0.00
0.01
83.24
0.18
8.29
12.26
0.02
0.11
35.89
7.02
10.94
16.19
0.03
0.14
47.37
9.27
13.97
20.67
0.04
0.18
60.47
11.83
19.63
29.04
0.05
0.26
84.97
16.62
Upstream Emissions
CO2 (million metric tons) ..........................................................................
NOX (thousand tons) ...............................................................................
Hg (tons) ..................................................................................................
N2O (thousand tons) ................................................................................
CH4 (thousand tons) ................................................................................
SO2 (thousand tons) ................................................................................
0.25
3.59
0.00
0.00
20.91
0.04
Total Emissions
CO2 (million metric tons) ..........................................................................
NOX (thousand tons) ...............................................................................
Hg (tons) ..................................................................................................
N2O (thousand tons) ................................................................................
CH4 (thousand tons) ................................................................................
SO2 (thousand tons) ................................................................................
mstockstill on DSK4VPTVN1PROD with RULES2
As part of the analysis for this final
rule, DOE estimated monetary benefits
likely to result from the reduced
emissions of CO2 and NOX that were
estimated for each of the TSLs
considered. As discussed in section
IV.L, 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 are based on the
average SCC from three integrated
VerDate Sep<11>2014
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Jkt 235001
4.93
7.30
0.01
0.06
21.35
4.18
assessment models, at discount rates of
2.5 percent, 3 percent, 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 four SCC values
for CO2 emissions reductions in 2015,
expressed in 2013$, are $12/ton, $40.5/
ton, $62.4/ton, and $119.0/ton. These
PO 00000
Frm 00097
Fmt 4701
Sfmt 4700
values for later years are higher due to
increasing emissions-related costs as the
magnitude of projected climate change
is expected to increase.
Table V.47 presents the global value
of CO2 emissions reductions at each
TSL. DOE calculated domestic values as
a range from 7 percent to 23 percent of
the global values, and these results are
presented in chapter 14 of the final rule
TSD.
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.47—GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION FOR POTENTIAL STANDARDS FOR AUTOMATIC
COMMERCIAL ICE MAKERS
SCC scenario *
TSL
5% Discount
rate, average
3% Discount
rate, average
2.5% Discount
rate, average
3% Discount
rate, 95th
percentile
million 2013$
Power Sector and Site Emissions
1
2
3
4
5
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
34.5
57.9
76.4
97.6
137.1
154.3
259.4
342.3
437.0
614.1
243.8
409.9
541.0
690.6
970.5
476.2
800.5
1,056.6
1,348.9
1,895.5
1.8
3.0
4.0
5.1
7.2
8.2
13.8
18.2
23.3
32.7
13.0
21.9
28.8
36.8
51.8
25.4
42.7
56.3
71.9
101.0
36.3
61.0
80.5
102.7
144.3
162.5
273.2
360.6
460.3
646.8
256.8
431.7
569.8
727.5
1,022.3
501.6
843.1
1,112.9
1,420.8
1,996.5
Upstream Emissions
1
2
3
4
5
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
Total Emissions
1
2
3
4
5
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
mstockstill on DSK4VPTVN1PROD with RULES2
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12, $40.5, $62.4, and $119.0 per metric ton (2013$).
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 rulemaking 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
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 final rule 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
emission reductions anticipated to
result from the new and amended
standards for the automatic commercial
ice makers. The dollar-per-ton values
that DOE used are discussed in section
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Jkt 235001
IV.L. Table V.48 presents the present
value of cumulative NOX emissions
reductions for each TSL calculated
using the average dollar-per-ton values
and 7-percent and 3-percent discount
rates.
TABLE V.48—PRESENT VALUE OF
NOX EMISSIONS REDUCTION FOR
POTENTIAL STANDARDS FOR AUTOMATIC COMMERCIAL ICE MAKERS—
Continued
TABLE V.48—PRESENT VALUE OF
NOX EMISSIONS REDUCTION FOR
POTENTIAL STANDARDS FOR AUTOMATIC COMMERCIAL ICE MAKERS
3%
Discount
rate
TSL
7%
Discount
rate
TSL
3%
Discount
rate
7%
Discount
rate
million 2013$
2
3
4
5
................................
................................
................................
................................
18.0
23.8
30.4
42.7
9.2
12.1
15.4
21.7
million 2013$
Power Sector and Site Emissions *
1
2
3
4
5
................................
................................
................................
................................
................................
5.6
9.4
12.4
15.8
22.2
2.9
4.9
6.5
8.2
11.6
Upstream Emissions
1
2
3
4
5
................................
................................
................................
................................
................................
5.2
8.7
11.4
14.6
20.5
2.5
4.3
5.6
7.2
10.1
Total Emissions
1 ................................
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10.7
Sfmt 4700
5.4
The NPV of the monetized benefits
associated with emission reductions can
be viewed as a complement to the NPV
of the customer savings calculated for
each TSL considered in this rulemaking.
Table V.49 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 3percent discount rate. The CO2 values
used in the table correspond to the four
scenarios for the valuation of CO2
emission reductions presented in
section IV.L.
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
TABLE V.49—AUTOMATIC COMMERCIAL ICE MAKERS TSLS: NET PRESENT VALUE OF CUSTOMER SAVINGS COMBINED
WITH NET PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS
Consumer NPV at 3% Discount Rate added with:
SCC Value of
$12/metric ton
CO2 * and
medium value
for NOX *
TSL
SCC Value of
$40.5/metric
ton CO2 * and
medium value
for NOX *
SCC Value of
$62.4/metric
ton CO2 * and
medium value
for NOX *
SCC Value of
$119.0/metric
ton CO2 * and
medium value
for NOX *
billion 2013$
1
2
3
4
5
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
0.436
0.791
1.046
0.955
(0.266)
0.563
1.004
1.326
1.313
0.237
0.657
1.162
1.536
1.580
0.612
0.902
1.574
2.079
2.273
1.587
Consumer NPV at 7% Discount Rate added with:
TSL
SCC Value of
$12/metric ton
CO2 * and
medium value
for NOX *
SCC Value of
$40.5/metric
ton CO2 * and
medium value
for NOX *
SCC Value of
$62.4/metric
ton CO2 * and
medium value
for NOX *
SCC Value of
$119.0/metric
ton CO2 * and
medium value
for NOX *
billion 2013$
1
2
3
4
5
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
0.225
0.398
0.523
0.455
(0.240)
0.351
0.611
0.803
0.813
0.263
0.445
0.769
1.012
1.080
0.638
0.690
1.181
1.555
1.773
1.613
* These label values represent the global SCC in 2015, in 2013$. The present values have been calculated with scenario-consistent discount
rates. For NOX emissions, each case uses the medium value, which corresponds to $2,684 per ton.
mstockstill on DSK4VPTVN1PROD with RULES2
Although adding the value of
customer savings to the values of
emission reductions provides a valuable
perspective, the following should be
considered. First, the national customer
savings are domestic U.S. customer
monetary savings that occur as a result
of market transactions, while the values
of emission reductions are based on
estimates of marginal social costs,
which, in the case of CO2, are based on
a global value. Second, the assessments
of customer operating cost savings and
emission-related benefits are performed
with quite different time frames for
analysis. For automatic commercial ice
makers, the present value of national
customer savings is measured for the
lifetime of units shipped from 2018
through 2047. The SCC values, on the
other hand, reflect the present value of
future climate-related impacts resulting
from the emission of one metric ton of
CO2 in each year. Because of the long
residence time of CO2 in the
atmosphere, these impacts continue
well beyond 2100.
7. 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. (42 U.S.C.
6295(o)(2)(B)(i)(VII) and 6313(d)(4))
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Jkt 235001
DOE considered LCC impacts on
identifiable groups of customers, such
as customers of different business types,
who may be disproportionately affected
by any new or amended national energy
conservation standard level. The LCC
subgroup impacts are discussed in
section V.B.1.b and in final rule TSD
chapter 11. DOE also considered the
reduction in generation capacity that
could result from the imposition of any
new or amended national energy
conservation standard level. Electric
utility impacts are presented in final
rule TSD chapter 15.
C. Conclusions/Proposed Standard
Any new or amended energy
conservation standard for any type (or
class) of covered product must be
designed to achieve the maximum
improvement in energy efficiency that
the Secretary determines is
technologically feasible and
economically justified. (42 U.S.C.
6295(o)(2)(A) and 6313(d)(4)) In
determining whether a proposed
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
6313(d)(4)) The new or amended
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Fmt 4701
Sfmt 4700
standard must also result in a significant
conservation of energy. (42 U.S.C.
6295(o)(3)(B) and 6313(d)(4))
DOE considered the impacts of
potential 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.
To aid the reader in understanding
the benefits and/or burdens of each TSL,
tables are presented to summarize the
quantitative analytical results for each
TSL, based on the assumptions and
methodology discussed herein. The
efficiency levels contained in each TSL
are described in section V.A. In addition
to the quantitative results presented in
the tables below, DOE also considers
other burdens and benefits that affect
economic justification including the
effect of technological feasibility,
manufacturer costs, and impacts on
competition on the economic results
presented. Table V.50, Table V.51, Table
V.52 and Table V.53 present a summary
of the results of DOE’s quantitative
analysis for each TSL. Results in Table
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Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
V.50 through Table V.53 are impacts
from equipment purchased in the period
from 2018 through 2047. In addition to
the quantitative results presented in the
tables, DOE also considers other
burdens and benefits that affect
economic justification of certain
customer subgroups that are
disproportionately affected by the
proposed standards. Section V.B.1.b
presents the estimated impacts of each
TSL for these subgroups.
TABLE V.50—SUMMARY OF RESULTS FOR AUTOMATIC COMMERCIAL ICE MAKERS TSLS: NATIONAL IMPACTS *
Category
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
Cumulative National Energy Savings 2018 through 2047
Quads
Undiscounted values ....................
0.081 .....................
0.136 .....................
0.179 .....................
0.229 .....................
0.321.
36.8 .......................
31.3.
Cumulative National Water Savings 2018 through 2047
billion gallons
Undiscounted values ....................
1.0 .........................
23.0 .......................
37.5 .......................
Cumulative NPV of Customer Benefits 2018 through 2047
billion 2013$
3% discount rate ...........................
7% discount rate ...........................
0.389 .....................
0.183 .....................
0.712 .....................
0.328 .....................
0.942 .....................
0.430 .....................
0.822 .....................
0.337 .....................
(0.453).
(0.406).
Industry Impacts
Change in Industry NPV (2013$
million).
Change in Industry NPV (%) ........
(7.5) to (6.6) ..........
(11.2) to (9.3) ........
(15.1) to (12.1) ......
(18.6) to (12.3) ......
(30.0) to (11.8).
(6.2) to (5.4) ..........
(9.2) to (7.7) ..........
(12.5) to (10.0) ......
(15.3) to (10.1) ......
(24.6) to (9.7).
13.97 .....................
20.67 .....................
0.04 .......................
0.18 .......................
48.55 .....................
60.47 .....................
1693.16 .................
11.83 .....................
19.63.
29.04.
0.05.
0.26.
68.23.
84.97.
2379.30.
16.62.
Cumulative Emissions Reductions 2018 through 2047 **
CO2 (MMt) .....................................
NOX (kt) ........................................
Hg (t) .............................................
N2O (kt) .........................................
N2O (kt CO2eq) .............................
CH4 (kt) .........................................
CH4 (kt CO2eq) .............................
SO2 (kt) .........................................
4.93 .......................
7.30 .......................
0.01 .......................
0.06 .......................
17.14 .....................
21.35 .....................
597.78 ...................
4.18 .......................
8.29 .......................
12.26 .....................
0.02 .......................
0.11 .......................
28.81 .....................
35.89 .....................
1004.79 .................
7.02 .......................
10.94 .....................
16.19 .....................
0.03 .......................
0.14 .......................
38.03 .....................
47.37 .....................
1326.27 .................
9.27 .......................
Monetary Value of Cumulative Emissions Reductions 2018 through 2047 †
CO2 (2013$ billion) .......................
NOX—3% discount rate (2013$
million).
NOX—7% discount rate (2013$
million).
0.036 to 0.502 .......
10.7 .......................
0.061 to 0.843 .......
18.0 .......................
0.080 to 1.113 .......
23.8 .......................
0.103 to 1.421 .......
30.4 .......................
0.144 to 1.997.
42.7.
5.4 .........................
9.2 .........................
12.1 .......................
15.4 .......................
21.7.
315 to 340 .............
376 to 464.
Employment Impacts
Net Change in Indirect Domestic
Jobs by 2022.
104 to 107 .............
196 to 204 .............
263 to 276 .............
* Values in parentheses are negative numbers.
** ‘‘MMt’’ stands for million metric tons; ‘‘kt’’ stands for kilotons; ‘‘t’’ stands for tons. CO2eq is the quantity of CO2 that would have the same
global warming potential (GWP).
† Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. Economic value of
NOX reductions is based on estimates at $2,684/ton.
TABLE V.51—SUMMARY OF RESULTS FOR AUTOMATIC COMMERCIAL ICE MAKERS TSLS: MEAN LCC SAVINGS
[2013$]
Standard level
Equipment class
mstockstill on DSK4VPTVN1PROD with RULES2
TSL 1
IMH–W–Small–B ....................................................................................
IMH–W–Med–B ......................................................................................
IMH–W–Large–B * .................................................................................
IMH–W–Large–B1 .................................................................................
IMH–W–Large–B2 .................................................................................
IMH–A–Small–B .....................................................................................
IMH–A–Large–B * ..................................................................................
IMH–A–Large–B1 ..................................................................................
IMH–A–Large–B2 ..................................................................................
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TSL 2
$175
$308
NA
NA
NA
$136
$382
$439
$76
Sfmt 4700
$175
$308
NA
NA
NA
$72
$501
$580
$76
E:\FR\FM\28JAR2.SGM
TSL 3
$214
$308
NA
NA
NA
$77
$361
$407
$110
28JAR2
TSL 4
$214
$165
NA
NA
NA
$77
$265
$294
$110
TSL 5
($534)
($63)
($172)
($200)
($80)
($393)
$55
$45
$110
Federal Register / Vol. 80, No. 18 / Wednesday, January 28, 2015 / Rules and Regulations
4745
TABLE V.51—SUMMARY OF RESULTS FOR AUTOMATIC COMMERCIAL ICE MAKERS TSLS: MEAN LCC SAVINGS—
Continued
[2013$]
Standard level
Equipment class
TSL 1
RCU–Large–B * ......................................................................................
RCU–Large–B1 ......................................................................................
RCU–Large–B2 ......................................................................................
SCU–W–Large–B ...................................................................................
SCU–A–Small–B ....................................................................................
SCU–A–Large–B ...................................................................................
IMH–A–Small–C .....................................................................................
IMH–A–Large–C ....................................................................................
RCU–Small–C ........................................................................................
SCU–A–Small–C ....................................................................................
TSL 2
$748
$743
$820
$444
$110
$163
$245
$539
$498
$224
TSL 3
$748
$743
$820
$613
$161
$400
$292
$539
$448
$278
TSL 4
$748
$743
$820
$550
$281
$439
$313
$626
$505
$290
TSL 5
$418
$391
$820
$192
$230
$71
$313
$626
$505
$290
$144
$161
($109)
$192
($145)
$71
($165)
$28
($73)
($268)
* LCC results for IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B are a weighted average of the two sub-equipment class level typical
units shown on the table, using weights provided in TSD chapter 7.
TABLE V.52—SUMMARY OF RESULTS FOR AUTOMATIC COMMERCIAL ICE MAKERS TSLS: MEDIAN PAYBACK PERIOD
Standard level
years
Equipment class
TSL 1
IMH–W–Small–B ......................................................................................
IMH–W–Med–B ........................................................................................
IMH–W–Large–B* ....................................................................................
IMH–W–Large–B1 ...................................................................................
IMH–W–Large–B2 ...................................................................................
IMH–A–Small–B .......................................................................................
IMH–A–Large–B* .....................................................................................
IMH–A–Large–B1 ....................................................................................
IMH–A–Large–B2 ....................................................................................
RCU–Large–B* ........................................................................................
RCU–Large–B1 ........................................................................................
RCU–Large–B2 ........................................................................................
SCU–W–Large–B .....................................................................................
SCU–A–Small–B ......................................................................................
SCU–A–Large–B .....................................................................................
IMH–A–Small–C ......................................................................................
IMH–A–Large–C ......................................................................................
RCU–Small–C ..........................................................................................
SCU–A–Small–C ......................................................................................
TSL 2
2.5
2.1
NA
NA
NA
3.4
2.2
1.2
7.4
1.1
0.9
3.0
1.1
2.2
1.8
1.5
0.7
0.7
0.8
TSL 3
2.5
2.1
NA
NA
NA
4.8
2.4
1.5
7.4
1.1
0.9
3.0
1.6
2.4
1.6
1.6
0.7
1.2
1.1
TSL 4
2.7
2.1
NA
NA
NA
4.7
2.3
1.5
6.9
1.1
0.9
3.0
1.8
2.6
2.1
1.7
0.7
1.2
1.5
TSL 5
2.7
5.0
NA
NA
NA
4.7
3.9
3.4
6.9
3.3
3.4
3.0
5.1
3.5
6.5
1.7
0.7
1.2
1.5
13.4
7.6
10.6
11.1
8.9
11.9
5.6
5.4
6.9
5.0
4.9
7.0
5.1
8.9
6.5
8.8
5.9
5.8
11.4
* PBP results for IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B are weighted averages of the results for the two sub-equipment class
level typical units, using weights provided in TSD chapter 7.
TABLE V.53—SUMMARY OF RESULTS FOR AUTOMATIC COMMERCIAL ICE MAKER TSLS: DISTRIBUTION OF CUSTOMER LCC
IMPACTS
Standard Level
percentage of customers (%)
Category
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TSL 1
IMH–W–Small–B
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–W–Med–B
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–W–Large–B *
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–W–Large–B1
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
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TSL 2
TSL 3
TSL 4
TSL 5
0
63
37
1
47
52
1
47
52
96
0
4
0
44
56
0
44
56
0
44
56
28
24
47
65
9
26
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
67
13
20
NA
NA
NA
Sfmt 4700
0
63
37
NA
NA
NA
NA
NA
NA
NA
NA
NA
70
13
17
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TABLE V.53—SUMMARY OF RESULTS FOR AUTOMATIC COMMERCIAL ICE MAKER TSLS: DISTRIBUTION OF CUSTOMER LCC
IMPACTS—Continued
Standard Level
percentage of customers (%)
Category
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TSL 1
IMH–W–Large–B2
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–A–Small–B
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–A–Large–B *
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–A–Large–B1
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–A–Large–B2
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
RCU–Large–B *
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
RCU–Large–B1
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
RCU–Large–B2
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
SCU–W–Large–B
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
SCU–A–Small–B
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
SCU–A–Large–B
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–A–Small–C
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
IMH–A–Large–C
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
RCU–Small–C
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
SCU–A–Small–C
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
Average of Equipment Types **
Net Cost (%) .....................................................................................
No Impact (%) ...................................................................................
Net Benefit (%) .................................................................................
TSL 2
TSL 3
TSL 4
TSL 5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
59
13
29
1
76
22
21
47
32
21
0
79
21
0
79
95
0
5
1
69
30
1
45
53
2
12
86
31
12
57
53
10
37
0
66
34
0
38
62
0
3
97
35
3
63
61
0
39
9
83
8
9
83
8
10
61
29
10
61
29
10
61
29
0
56
44
0
56
44
0
56
44
23
22
55
55
2
42
0
56
44
0
56
44
0
56
44
25
20
55
55
1
44
1
56
43
1
56
43
1
56
43
1
56
43
57
20
23
0
28
72
0
28
72
0
5
94
44
0
56
44
0
56
0
48
52
1
20
79
1
12
87
16
0
84
77
0
23
0
37
63
0
1
99
0
1
99
54
0
46
54
0
46
0
69
31
0
58
42
0
39
61
0
39
61
68
14
18
0
57
43
0
57
43
0
35
65
0
35
65
54
9
37
0
72
28
0
44
55
0
11
89
0
11
89
64
6
31
0
56
44
0
47
53
1
32
67
1
32
67
86
0
14
1
62
37
7
40
53
6
16
77
20
12
68
75
3
22
* LCC results for IMH–W–Large–B, IMH–A–Large–B, and RCU–Large–B are a weighted average of the two sub-equipment class level typical
units shown on the table.
** Average of equipment types created by weighting the class results by 2018 shipment estimates.
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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
explain why consumers appear to
undervalue energy efficiency
improvements. 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
benefits; (3) a lack of sufficient savings
to warrant delaying or altering
purchases (e.g., an inefficient
ventilation fan in a new building or the
delayed replacement of a water pump);
(4) excessive focus on the short term, in
the form of inconsistent weighting 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, consumers may trade off these
types of investments at a higher-thanexpected rate between current
consumption and uncertain future
energy cost savings. This
undervaluation suggests that regulation
that promotes energy efficiency can
produce significant net private gains (as
well as producing social gains by, for
example, reducing pollution).
While DOE is not prepared at present
to provide a fuller quantifiable
framework for estimating the benefits
and costs of changes in consumer
purchase decisions due to an amended
energy conservation standard, 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 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.74 DOE welcomes
comments on how to more fully assess
the potential impact of energy
conservation standards on consumer
choice and methods to quantify this
impact in its regulatory analysis.
TSL 5 corresponds to the max-tech
level for all the equipment classes and
offers the potential for the highest
cumulative energy savings through the
analysis period from 2018 to 2047. The
estimated energy savings from TSL 5 is
0.321 quads of energy. Because one
energy-saving design option reduces
potable water usage, potential savings
are estimated to be 31 billion gallons,
although such savings should not be
construed to be the result of a potable
water standard. DOE projects a negative
NPV for customers valued at $0.406
billion at a 7-percent discount rate.
Estimated emissions reductions are 19.6
MMt of CO2, up to 29.0 kt of NOX and
0.05 tons of Hg. The CO2 emissions have
a value of up to $2.0 billion and the
NOX emissions have a value of $21.7
million at a 7-percent discount rate.
For TSL 5, the mean LCC savings for
five equipment classes are positive,
implying a decrease in LCC, with the
decrease ranging from $28 for the IMH–
A–Large–C equipment class to $192 for
the SCU–W–Large–B equipment class.75
The results shown on Table V.53
indicates a large fraction of customers
would experience net LCC increases
(i.e., LCC costs rather than savings) from
adoption of TSL 5, with 44 to 96 percent
of customers experiencing net LCC
increases. As shown on Table V.52,
customers would experience payback
periods of 5 years or longer in all
equipment classes, and in many cases
customers would experience payback
periods exceeding the estimated 8.5 year
equipment lifetime.
At TSL 5, the projected change in
INPV ranges from a decrease of $30.0
million to a decrease of $11.8 million,
depending on the chosen manufacturer
markup scenario. The upper bound is
considered optimistic by industry
because it assumes manufacturers could
pass on all compliance costs as price
increases to their customers. DOE
recognizes the risk of negative impacts
if manufacturers’ expectations
concerning reduced profit margins are
realized. If the lower bound of the range
of impacts is reached, TSL 5 could
result in a net loss of up to 24.6 percent
in INPV for the ACIM industry.
DOE estimates that approximately 84
percent of all batch commercial ice
makers and 78 percent of all continuous
commercial ice makers on the market
will require redesign to meet standards
at TSL 5. DOE expects industry
conversion costs of $44.1 million. Also
74 Sanstad, A. Notes on the Economics of
Household Energy Consumption and Technology
Choice. 2010. Lawrence Berkeley National
Laboratory, Berkeley, CA. www1.eere.energy.gov/
buildings/appliance_standards/pdfs/consumer_ee_
theory.pdf
75 For this section of the final rule, the discussion
is limited to results for full equipment classes.
Thus, for the large equipment classes for which
DOE analyzed 2 typical unit sizes, this discussion
focuses on the weighted average or totals of the two
typical units.
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of concern, for five equipment classes,
there is only 1 manufacturer with
products that could currently meet this
standard.
After carefully considering the
analysis results and weighing the
benefits and burdens of TSL 5, DOE
finds that at TSL 5, the benefits to the
nation in the form of energy savings and
emissions reductions are outweighed by
a decrease of $0.406 billion in customer
NPV and a decrease of up to 24.6
percent in INPV. Additionally, the
majority of individual customers
purchasing automatic commercial ice
makers built to TSL 5 standards
experience negative life-cycle cost
savings, with over 90 percent of
customers of 2 equipment classes
experiencing negative life-cycle cost
savings. After weighing the burdens of
TSL 5 against the benefits, DOE finds
TSL 5 not to be economically justified.
DOE does not propose to adopt TSL 5
in this rulemaking.
TSL 4, the next highest efficiency
level, corresponds to the highest
efficiency level with a positive NPV at
a 7-percent discount rate for all
equipment classes. The estimated
energy savings from 2018 to 2047 are
0.229 quads of energy—an amount DOE
deems significant. Because one energysaving design option reduces potable
water usage, potential water savings are
estimated to be 37 billion gallons,
although such savings should not be
construed to be the result of a potable
water standard. At TSL 4, DOE projects
an increase in customer NPV of $0.337
billion (2013$) at a 7-percent discount
rate; estimated emissions reductions of
14.0 MMt of CO2, 20.7 kt of NOx, and
0.04 tons of Hg. The monetary value for
CO2 was estimated to be up to $1.4
billion. The monetary value for NOX
was estimated to be $15.4 million at a
7-percent discount rate.
At TSL 4, the mean LCC savings are
positive for all equipment classes. As
shown on Table V.51, mean LCC savings
vary from $71 for SCU–A–Large–B to
$626 for IMH–A–Large–C, which
implies that, on average, customers will
experience an LCC benefit. As shown on
Table V.53, for 7 of the 13 classes, some
fraction of the customers will
experience net costs, while for 5 classes,
1 percent or less will experience net
costs. Customers in 3 classes would
experience net LCC costs of 30 percent
or more, with the percentage ranging up
to 54 percent for one equipment class.
Median payback periods range from 0.7
years up to 6.5 years.
At TSL 4, the projected change in
INPV ranges from a decrease of $18.6
million to a decrease of $12.3 million.
If the lower bound of the range of
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impacts is reached, TSL 4 could result
in a net loss of up to 15.3 percent in
INPV for manufacturers.
DOE estimates that approximately 66
percent of all batch commercial ice
makers and 55 percent of all continuous
commercial ice makers on the market
will require redesign to meet standards
at TSL 4. At this TSL DOE expects
industry conversion costs to total $30.0
million. Additionally, for four
equipment classes, there is only 1
manufacturer with products that
currently meet the standard.
After carefully considering the
analysis results and weighing the
benefits and burdens of TSL 4, DOE
finds that at TSL 4, the benefits to the
nation in the form of energy savings and
emissions reductions plus an increase of
$0.337 billion in customer NPV are
outweighed by a decrease of up to 15.3
percent in INPV and issues regarding
availability of product from multiple
manufacturers in some product classes.
After weighing the burdens of TSL 4
against the benefits, DOE finds TSL 4
not to be economically justified. DOE
does not propose to adopt TSL 4 in this
rule.
At TSL 3, the next highest efficiency
level, estimated energy savings from
2018 through 2047 are 0.179 quads of
primary energy—an amount DOE
considers significant. Because one
energy-saving design option reduces
potable water usage, potential water
savings are estimated to be 37 billion
gallons, although such savings should
not be construed to be the result of a
potable water standard. TSL 3 was
defined as the set of efficiencies with
the highest NPV for each analyzed
equipment class. At TSL 3, DOE projects
an increase in customer NPV of $0.430
billion at a 7-percent discount rate, and
an increase of $0.942 billion at a 3percent discount rate. Estimated
emissions reductions are 10.9 MMt of
CO2, up to 16.2 kt of NOX and 0.03 tons
of Hg at TSL 3. The monetary value of
the CO2 emissions reductions was
estimated to be up to $1.1 billion at TSL
3. The monetary value of the NOX
emission reductions was estimated to be
$12.1 million at a 7-percent discount
rate.
At TSL 3, nearly all customers for all
equipment classes are shown to
experience positive LCC savings. As
shown on Table V.53 Table V.53, the
percent of customers experiencing a net
cost is 2 percent or less in 12 of 13
classes, with IMH–A–Small–B being the
exception with 21 percent of customers
experiencing a net cost. The payback
period for IMH–A–Small–B is 4.7 years,
while for all other equipment classes the
median payback periods are 3 years or
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less. LCC savings range from $77 for
IMH–A–Small–B to $748 for RCU–
Large–B.
At TSL 3, the projected change in
INPV ranges from a decrease of $15.1
million to a decrease of $12.1 million.
If the lower bound of the range of
impacts is reached, TSL 3 could result
in a net loss of up to 12.5 percent in
INPV for manufacturers.
DOE estimates that approximately 51
percent of all batch commercial ice
makers and 55 percent of all continuous
commercial ice makers on the market
will require redesign to meet standards
at TSL 3. At TSL 3, DOE expects
industry conversion costs to total $25.1
million. There are multiple
manufacturers with product that could
meet this standard at all analyzed
equipment classes.
At TSL 3, the monetized CO2
emissions reduction values range from
$0.080 to $1.113 billion. The mid-range
value used by DOE to calculate total net
benefits is the monetized CO2 emissions
reduction at $40.5 per ton in 2013$,
which for TSL 3, is $0.361 billion. The
monetized NOX emissions reductions
calculated at an intermediate value of
$2,684 per ton in 2013$ are $12.1
million at a 7-percent discount rate and
$23.8 million at a 3-percent rate. These
monetized emissions reduction values
were added to the customer NPV at 3percent and 7-percent discount rates to
obtain values of $1.326 billion and
0.803 billion, respectively, at TSL 3.
Approximately 94 percent of
customers are expected to experience
net benefits (or no impact) from
equipment built to TSL 3 levels. The
payback periods for TSL 3 are expected
to be 3 years or less for all but the IMH–
A–Small–B.
After carefully considering the
analysis results and weighing the
benefits and burdens of TSL 3, DOE
concludes that setting the standards for
automatic commercial ice makers at TSL
3 will offer the maximum improvement
in energy efficiency that is
technologically feasible and
economically justified and will result in
significant energy savings. Therefore,
DOE today is adopting standards at TSL
3 for automatic commercial ice makers.
TSL 3 is technologically feasible
because the technologies required to
achieve these levels already exist in the
current market and are available from
multiple manufacturers. TSL 3 is
economically justified because the
benefits to the nation in the form of
energy savings, customer NPV at 3
percent and at 7 percent, and emissions
reductions outweigh the costs
associated with reduced INPV and
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potential effects of reduced
manufacturing capacity.
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 these
standards address are as follows:
(1) Insufficient information and the
high costs of gathering and analyzing
relevant information leads some
customers to miss opportunities to make
cost-effective investments in energy
efficiency.
(2) In some cases the benefits of more
efficient equipment are not realized due
to misaligned incentives between
purchasers and users. An example of
such a case is when the equipment
purchase decision is made by a building
contractor or building owner who does
not pay the energy costs.
(3) There are external benefits
resulting from improved energy
efficiency of automatic commercial ice
makers that are not captured by the
users of such equipment. These benefits
include externalities related to public
health, environmental protection and
national security that are not reflected
in energy prices, such as reduced
emissions of air pollutants and
greenhouse gases that impact human
health and global warming.
In addition, DOE has determined that
today’s regulatory action is a
‘‘significant regulatory action’’ under
Executive Order 12866. DOE presented
to the Office of Information and
Regulatory Affairs (OIRA) in the OMB
for review the draft rule and other
documents prepared for this
rulemaking, including a regulatory
impact analysis (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 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
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by Executive Order 13563 to: (1)
Propose or adopt a regulation only upon
a reasoned determination that its
benefits justify its costs (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 this final rule 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 final regulatory flexibility analysis
(FRFA) 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
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has made its procedures and policies
available on the Office of the General
Counsel’s Web site (https://energy.gov/
gc/office-general-counsel).
For manufacturers of automatic
commercial ice makers, 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 by 65
FR 53533, 53544 (September 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/sites/default/files/files/
Size_Standards_Table.pdf. Commercial
refrigeration equipment manufacturing
is classified under NAICS 333415, ‘‘AirConditioning and Warm Air Heating
Equipment and Commercial and
Industrial Refrigeration Equipment
Manufacturing,’’ which includes icemaking machinery manufacturing. The
SBA sets a threshold of 750 employees
or less for an entity to be considered as
a small business for this category. Based
on this threshold, DOE present the
following FRFA analysis:
1. Description and Estimated Number of
Small Entities Regulated
During its market survey, DOE used
available public information to identify
potential small manufacturers. DOE’s
research involved industry trade
association membership directories
(including AHRI), public databases (e.g.,
AHRI Directory,76 the SBA Database 77),
individual company Web sites, and
market research tools (e.g., Dunn and
Bradstreet reports 78 and Hoovers
reports 79) to create a list of companies
that manufacture or sell products
covered by this rulemaking. DOE also
asked stakeholders and industry
representatives if they were aware of
any other small manufacturers during
76 ‘‘AHRI Certification Directory.’’ AHRI
Certification Directory. AHRI. (Available at:
https://www.ahridirectory.org/ahridirectory/pages/
home.aspx) (Last accessed October 10, 2011). See
www.ahridirectory.org/ahriDirectory/pages/
home.aspx.
77 ‘‘Dynamic Small Business Search.’’ SBA.
(Available at: See https://dsbs.sba.gov/dsbs/search/
dsp_dsbs.cfm) (Last accessed October 12, 2011).
78 ‘‘D&B|Business Information|Get Credit
Reports|888 480–6007.’’. Dun & Bradstreet
(Available at: www.dnb.com) (Last accessed October
10, 2011). See www.dnb.com/.
79 ‘‘Hoovers|Company Information|Industry
Information|Lists.’’ D&B (2013) (Available at: See
https://www.hoovers.com/) (Last accessed December
12, 2012).
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manufacturer interviews and at DOE
public meetings. DOE reviewed 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 covered automatic
commercial ice makers. DOE screened
out companies that do not offer
products covered by this rulemaking, do
not meet the definition of a ‘‘small
business,’’ or are foreign owned.
DOE identified 16 manufacturers of
automatic commercial ice makers.
Seven of those are small businesses
manufacturers operating in the United
States. DOE contacted each of these
companies, but only one accepted the
invitation to participate in a
confidential manufacturer impact
analysis interview with DOE
contractors.
In establishing today’s standard
levels, DOE has carefully considered the
impacts on small manufacturers when
establishing the standards for this
industry. DOE’s review of the industry
suggests that the five of the seven small
manufacturers identified specialize in
industrial higher capacity ‘‘tube’’,
‘‘flake’’ or ‘‘cracked’’ ice machines.
Industry literature indicates that these
types of ice makers are typically
designed to produce 2,000–40,000 lb/
day of ice, with some designs going as
low as 1,000 lb/day. Only at the lowest
end of the tube, flake, and cracked ice
platforms, typically 2,000 and 4,000 lb/
day, do these manufacturers have
products within the scope of this
rulemaking. Based on product listings
from manufacturer Web sites, DOE
estimates that approximately 15% of the
models produced by these five
manufacturers are covered product
under today’s rule.
Of the remaining two small
manufacturers, one exclusively
produces continuous ice makers, and
one exclusively produces gourmet, large
cube, ice makers. Based on publically
available information, DOE believes that
approximately two-thirds of all the
models made by the manufacturer of
continuous machines already meet the
standard, positioning it well compared
to an industry-at-large compliance rate
of approximately 50 percent.
DOE estimates that 10 percent of the
models made by the manufacturer of
gourmet, large cube machines already
meet the standard. The low percentage
indicates that this manufacturer may be
disproportionately affected by the
selected standard level, but as discussed
in section IV.B.1.f, DOE does not have
nor did it receive in response to requests
for comments sufficient specific
information to evaluate whether larger
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2. Description and Estimate of
Compliance Requirements
For the purposes of analysis, DOE
assumes that the seven small domestic
manufacturers of automatic commercial
ice makers identified account for
approximately 5 percent of industry
shipments. While small business
manufacturers of automatic commercial
ice makers have small overall market
share, some hold substantial market
share in specific equipment classes.
Several of these smaller firms specialize
in producing industrial ice machines
and the covered equipment they
manufacture are extensions of industrial
product lines that fall within the range
of capacity covered by this rule. Others
serve niche markets. Most have
substantial portions of their business
derived from equipment outside the
scope of this rulemaking, as described
further below, but are still considered
small businesses based on the SBA
limits for number of employees.
At the new and amended levels, small
business manufacturers of automatic
commercial ice makers are expected to
face negative impacts on INPV. For the
portions of their business covered by the
standard, the impacts are approximately
four times as severe as those felt by the
industry at large: a loss of 49.8 percent
of INPV for small businesses alone as
compared to a loss of 12.5 percent for
the industry at large. Where conversion
costs are driven by the number of
platforms requiring redesign at a
particular standard level, small business
manufacturers may be
disproportionately affected. Product
conversion costs including the
investments made to redesign existing
equipment to meet new or amended
standards or to develop entirely new
compliant equipment, as well as
industry certification costs, do not scale
with sales volume. As small
manufacturers’ investments are spread
over a much lower volume of
shipments, recovering the cost of
upfront investments is proportionately
more difficult. Additionally, smaller
manufacturers typically do not have the
same technical resources and testing
capacity as larger competitors.
The product conversion investments
required to comply are estimated to be
over 10 times larger than the typical
R&D expenditures for small businesses,
whereas the industry as a whole is
estimated to incur 4 times larger than
typical R&D expenditures. Where the
covered equipment from several small
manufacturers are adaptations of larger
platforms with capacities above the
4,000 lb ice/24 hour threshold, it may
not prove economical for them to invest
in redesigning such a small portion of
their product offering to meet standards.
In confidential interviews,
manufacturers indicated that many
design options evaluated in the
engineering analysis (e.g., higher
efficiency motors and compressors)
would require them to purchase more
expensive components. In many
industries, small manufacturers
typically pay higher prices for
components due to smaller purchasing
volumes while their large competitors
80 Koeller, John, P.E., and Herman Hoffman, P.E.
A Report on Potential Best Management Practices.
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receive volume discounts. However, this
effect is diminished for the automatic
commercial ice maker manufacturing
industry for two distinct reasons. One
reason relates to the fact that the
automatic commercial ice maker
industry as a whole is a low volume
industry. In confidential interviews,
manufacturers indicated that they have
little influence over their suppliers,
suggesting the volume of their
component orders is similarly
insufficient to receive substantial
discounts. The second reason relates to
the fact that, for most small businesses,
the equipment covered by this
rulemaking represents only a fraction of
overall business. Where small
businesses are ordering similar
components for non-covered equipment,
their purchase volumes may not be as
low as is indicated by the total unit
shipments for small businesses. For
these reasons, it is expected that any
volume discount for components
enjoyed by large manufacturers would
not be substantially different from the
prices paid by small business
manufacturers.
To estimate how small manufacturers
would be potentially impacted, DOE
developed specific small business
inputs and scaling factors for the GRIM.
These inputs were scaled from those
used in the whole industry GRIM using
information about the product portfolios
of small businesses and the estimated
market share of these businesses in each
equipment class. DOE used this
information in the GRIM to estimate the
annual revenue, EBIT, R&D expense,
and capital expenditures for a typical
small manufacturer and to model the
impact on INPV associated with the
production of covered product; noting
that for five of the seven small
businesses in this analysis, only 15% of
their product portfolio, which was
based on review capacity ranges of the
product offerings listed on these
manufacturers’ Web sites, is covered
product under today’s rule DOE then
compared these impacts to those
modeled for the industry at large, and
found that small manufactures could
lose up to 49.8 percent of the INPV
associated with the production of
covered product; as compared to a
reduction in small business INPV of
78.8 percent at the NOPR stage. Table
VI.1 and Table VI.2 summarize the
impacts on small business INPV at each
TSL, and Table VI.3 and Table VI.4
summarize the changes in results at TSL
3, between the NOPR and Final Rule
analysis.
Rep. The California Urban Water Conservation
Council, n.d. Web. 19 May 2014.
ice has specific consumer utility, nor to
allow separate evaluation for such
equipment of costs and benefits
associated with achieving the efficiency
levels considered in the rulemaking. In
the absence of information, DOE cannot
conclude that this type of ice has unique
consumer utility justifying
consideration of separate equipment
classes. DOE notes that manufacturers of
this equipment have the option seeking
exception relief pursuant to 41 U.S.C.
7194 from DOE’s Office of Hearings and
Appeals.
Based on a 2008 study by Koeller &
Company,80 DOE understands that the
ACIM market is dominated by four
manufacturers who produce
approximately 90 percent of the
automatic commercial ice makers for
sale in the United States. The four major
manufacturers with the largest market
share are Manitowoc, Scotsman,
Hoshizaki, and Ice-O-Matic. The
remaining 12 large and small
manufacturers account for ten percent of
domestic sales.
DOE considered comments that all
manufacturers and stakeholders made
regarding the engineering analysis and
made changes to the analysis, which are
described in some detail in section
III.IV.D. These changes reduced the
highest efficiency levels determined to
be possible using the design options
considered in the analyses and
increased the estimated costs associated
with attaining most efficiency levels.
Consequently, the most cost-effective
efficiency levels for the final rule
analysis were lower than for the NOPR.
This applied to specific equipment
classes associated with the products
sold by some of these small businesses,
for example continuous ice makers, IMH
batch ice makers, and RCU batch ice
makers. The energy standards were
consequently set at efficiency levels that
will be less burdensome to attain for the
affected small businesses.
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4751
TABLE VI.1—COMPARISON OF SMALL BUSINESS MANUFACTURERS OF AUTOMATIC COMMERCIAL ICE MAKER INPV * TO
THAT OF THE INDUSTRY AT LARGE BY TSL UNDER THE PRESERVATION OF GROSS MARGIN MARKUP SCENARIO **
TSL 1
Industry at Large—Impact on INPV (%) ..................................................
Small Businesses—Impact on INPV (%) .................................................
TSL 2
(6.2)
(18.3)
TSL 3
(9.2)
(34.2)
(12.5)
(48.8)
TSL 4
(15.3)
(51.5)
TSL 5
(24.6)
(57.2)
* Small business manufacturer INPV represents only the INPV associated with the production and sale of covered product. Many small business manufacturers produce products not covered by this rule.
** Values in parentheses are negative numbers.
TABLE VI.2—COMPARISON OF SMALL BUSINESS MANUFACTURERS OF AUTOMATIC COMMERCIAL ICE MAKER INPV * TO
THAT OF THE INDUSTRY AT LARGE BY TSL UNDER THE PRESERVATION OF EBIT MARKUP SCENARIO **
TSL 1
Industry at Large—Impact on INPV (%) ..................................................
Small Businesses—Impact on INPV (%) .................................................
TSL 2
(5.4)
(19.1)
TSL 3
(7.7)
(35.1)
(10.0)
(49.8)
TSL 4
(10.1)
(52.6)
TSL 5
(9.7)
(68.4)
* Small business manufacturer INPV represents only the INPV associated with the production and sale of covered product. Many small business manufacturers produce products not covered by this rule.
** Values in parentheses are negative numbers.
TABLE VI.3—COMPARISON OF SMALL
BUSINESS
MANUFACTURERS
OF
AUTOMATIC
COMMERCIAL
ICE
MAKER INPV * TO THAT OF THE INDUSTRY AT LARGE UNDER THE
PRESERVATION OF GROSS MARGIN
MARKUP SCENARIO **; NOPR VS.
FINAL RULE
NOPR
TSL 3
Industry at Large—
Impact on INPV
(%) .........................
Small Businesses—
Impact on INPV
(%) .........................
Final rule
TSL 3
(20.5)
(12.5)
(76.6)
(48.8)
* Small business manufacturer INPV represents only the INPV associated with the production and sale of covered product. Many
small business manufacturers produce products not covered by this rule.
** Values in parentheses are negative
numbers.
TABLE VI.4—COMPARISON OF SMALL
BUSINESS
MANUFACTURERS
OF
AUTOMATIC
COMMERCIAL
ICE
MAKER INPV * TO THAT OF THE INDUSTRY AT LARGE UNDER THE
PRESERVATION OF EBIT MARKUP
SCENARIO **; NOPR VS FINAL RULE
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NOPR
TSL 3
Industry at Large—
Impact on INPV
(%) .........................
Small Businesses—
Impact on INPV
(%) .........................
Final rule
TSL 3
(23.5)
(10.0)
(78.6)
(49.8)
* Small business manufacturer INPV represents only the INPV associated with the production and sale of covered product. Many
small business manufacturers produce products not covered by this rule.
** Values in parentheses are negative
numbers.
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3. 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 adopted
today.
4. Significant Alternatives to the Rule
The discussion above analyzes
impacts on small businesses that would
result from DOE’s new and amended
standards. In addition to the other TSLs
being considered, the rulemaking TSD
includes a regulatory impact analysis
(RIA). For automatic commercial ice
making equipment, the RIA discusses
the following policy alternatives: (1) No
change in standard; (2) consumer
rebates; (3) consumer tax credits; and (4)
manufacturer tax credits; (5) voluntary
energy efficiency targets; (6) bulk
government purchases; and (7)
extending the compliance date for small
entities. While these alternatives may
mitigate to some varying extent the
economic impacts on small entities
compared to the standards, DOE did not
consider these alternatives further
because they are either not feasible to
implement without authority and
funding from Congress, or are expected
to result in energy savings that are much
smaller (ranging from 39 percent to less
than 53 percent) than those that will be
achieved by the new and amended
standard levels. In reviewing
alternatives DOE analyzed a case in
which the voluntary programs targeted
efficiencies corresponding to final rule
TSL 3. DOE also examined standards at
lower efficiency levels, TSL 2 and TSL
1. TSL 2 achieves 25 percent lower
savings than TSL 3 and TSL 1 achieves
less than half the savings of TSL 3. (See
Table V.50 for the estimated impacts of
standards at lower TSLs.) Voluntary
programs at these levels achieve only a
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fraction of the savings achieved by
standards and would provide even
lower savings benefits. As shown in
Table VI.1 through Table VI.4, the
changes to the efficiency levels
comprising TSL 3 between the NOPR
and final rule resulted in a substantial
reduction in the impacts faced by small
businesses. To achieve further
substantial reductions in small business
impacts would force the standard down
to TSL 1 levels, at the expense of
substantial energy savings and NPV
benefits, which would be inconsistent
with DOE’s statutory mandate to
maximize the improvement in energy
efficiency that the Secretary determines
is technologically feasible and
economically justified. DOE believes
that establishing standards at TSL 3
provides the optimum balance between
energy savings benefits and impacts on
small businesses. Accordingly, DOE is
declining to adopt any of these
alternatives and is adopting the
standards set forth in this rulemaking.
(See chapter 17 of the TSD for further
detail on the policy alternatives DOE
considered.)
Additional compliance flexibilities
may be available through other means.
For example, individual manufacturers
may petition for a waiver of the
applicable test procedure. Further,
EPCA provides that a manufacturer
whose annual gross revenue from all of
its operations does not exceed
$8,000,000 may apply for an exemption
from all or part of an energy
conservation standard for a period not
longer than 24 months after the effective
date of a final rule establishing the
standard. Additionally, Section 504 of
the Department of Energy Organization
Act, 42 U.S.C. 7194, provides authority
for the Secretary to adjust a rule issued
under EPCA in order to prevent ‘‘special
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hardship, inequity, or unfair
distribution of burdens’’ that may be
imposed on that manufacturer as a
result of such rule. Manufacturers
should refer to 10 CFR part 430, subpart
E, and part 1003 for additional details.
mstockstill on DSK4VPTVN1PROD with RULES2
5. Response to Small Business
Comments and Comments of the Office
of Advocacy
The Chief Counsel of the SBA Office
of Advocacy submitted comments
regarding the impact of the proposed
standards on small businesses and
recommended that DOE use its
discretion to adopt an alternative to the
proposed standard that is achievable for
small manufacturers. This letter is
posted to the docket at https://www.
regulations.gov/#!docketDetail;D=EERE2010-BT-STD-0037.
DOE has taken several steps to
minimize the impact of the new and
amended standards on small businesses.
The comments received in response to
the proposed standards led DOE to hold
an additional public meeting and allow
stakeholders more time to submit
additional information to DOE’s
consultant pursuant to non-disclosure
agreements regarding efficiency gains
and costs of potential design options.
DOE reviewed additional market data,
including published ratings of available
ice makers, to recalibrate its engineering
analysis, and as a result, revised the
proposed TSL levels. DOE issued a
NODA to announce the availability of
the revised analysis and sought
comment from stakeholders. In this final
rule, DOE is adopting the TSL 3
presented in the NODA. As discussed
previously, the changes to the efficiency
levels comprising TSL 3 between the
NOPR and final rule resulted in a
standard that is less burdensome for
small businesses.
In addition, in reviewing all available
data sources received in response to the
proposed standards, DOE found that the
IMH–W continuous class ice makers
consume more condenser water than
DOE assumed at the NOPR stage. In
setting the standard for the continuous
class condenser water use, DOE
intended that the baseline reflect the
existing market for continuous type
units. Based on this new data, the
standard for condenser water use is set
at 10 percent below the baseline
condenser water use level for IMH–W
batch ice makers, rather than 20 percent,
as was proposed in the NOPR. As a
result, all IMH–W continuous class
models produced by small business
manufacturers are compliant with the
condenser water use standard for this
class.
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DOE notes that while any one
regulation may not impose a significant
burden on small business
manufacturers, the combined effects of
recent or impending regulations may
have consequences for some small
business manufacturers. In researching
the product offerings of small business
manufacturers covered by this
rulemaking, DOE did not identify any
that also manufacture products
impacted by the recently issued energy
conservation standards for commercial
refrigeration equipment or walk-in
coolers and freezers. DOE will continue
to work with industry to ensure that
cumulative impacts from its regulations
are not unduly burdensome.
The SBA Office of Advocacy also
recommended that DOE adopt a lower
TSL for small businesses because the
level proposed in the NOPR would have
a disproportionately negative impact on
small business manufacturers. As
discussed previously, the changes to the
analysis between the NOPR and final
rule resulted in different TSLs. As such,
the efficiency levels comprising TSL 3
as set forth in this final rule result in a
substantial reduction in the impacts
faced by small business manufacturers,
as compared to those proposed in the
NOPR. DOE also examined standards at
lower efficiency levels, TSL 2 and TSL
1. TSL 2 achieves 25 percent lower
savings than TSL 3 and TSL 1 achieves
less than half the savings of TSL 3. (See
Table V.50 for the estimated impacts of
standards at lower TSLs.) The impacts
on small manufacturers were also
considered in comparison to the
impacts on larger manufacturers to
ensure that small business would
remain competitive in the market.
Because they compete mostly in market
niches not covered by these standards,
these rules apply to about 15 percent of
these companies product in comparison
to 100 percent for large business. In
addition, for one of the remaining two
manufacturers, DOE estimates that
approximately two-thirds of its models
already meet the energy efficiency
standard and 100 percent of its models
meet the condenser water standard. In
comparison, a typical large
manufacturer will need to redesign half
of their products to meet the new and
amended standards. Pursuant to DOE’s
statutory mandate, any new or amended
standard must maximize the
improvement in energy efficiency that
the Secretary determines is both
technologically feasible and
economically justified. DOE determined
that TSL 3 will achieve significant
energy savings and is economically
justified, and therefore is adopting TSL
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3 in this final rule. DOE believes that
establishing standards at TSL 3 provides
the optimum balance between energy
savings benefits and impacts on small
businesses.
Finally, the SBA Office of Advocacy
recommended that DOE consider
extending the compliance date for small
entities. DOE notes that EPCA requires
that the amended standards established
in this rulemaking must apply to
equipment that is manufactured on or
after 3 years after the final rule is
published in the Federal Register 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. 6313(d)(3)(C)) As described
previously, the standard levels set forth
in this final rule are less stringent
relative to those proposed in the NOPR,
and fewer ice maker models will require
redesign to meet the new standard.
Therefore, DOE has determined that the
3-year period is adequate and is not
extending the compliance date for small
business manufacturers.
C. Review Under the Paperwork
Reduction Act
Manufacturers of automatic
commercial ice makers 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
automatic commercial ice makers,
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 commercial refrigeration
equipment. (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
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that collection of information displays a
currently valid OMB Control Number.
mstockstill on DSK4VPTVN1PROD with RULES2
D. Review Under the National
Environmental Policy Act of 1969
Pursuant to the National
Environmental Policy Act (NEPA) of
1969, DOE has determined that this
final rule fits within the category of
actions included in Categorical
Exclusion (CX) B5.1 and otherwise
meets the requirements for application
of a CX. See 10 CFR part 1021, App. B,
B5.1(b); 1021.410(b) and Appendix B,
B(1)–(5). This final rule fits within the
category of actions because it is a
rulemaking that establishes energy
conservation standards for consumer
products or industrial equipment, and
for which none of the exceptions
identified in CX B5.1(b) apply.
Therefore, DOE has made a CX
determination for this rulemaking, and
DOE does not need to prepare an
Environmental Assessment or
Environmental Impact Statement for
this rule. DOE’s CX determination for
this final rule is available at https://
energy.gov/nepa/categorical-exclusiondeterminations-b51.
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 this final rule.
States can petition DOE for exemption
from such preemption to the extent, and
based on criteria, set forth in EPCA. (42
U.S.C. 6297) 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
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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
(February 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
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 final
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 an
amended 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 ‘‘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
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4753
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.
DOE has concluded that this final rule
would likely require expenditures of
$100 million or more on the private
sector. Such expenditures may include:
(1) Investment in research and
development and in capital
expenditures by automatic commercial
ice maker manufacturers in the years
between the final rule and the
compliance date for the new standards,
and (2) incremental additional
expenditures by consumers to purchase
higher-efficiency automatic commercial
ice maker, 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
the final 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 notice of final rulemaking and the
‘‘Regulatory Impact Analysis’’ section of
the TSD for this final 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 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. 6295(o), 6313(d), this final rule
would establish energy conservation
standards for automatic commercial ice
maker 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’’ chapter 17 of the TSD for
today’s final rule.
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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
(March 18, 1988), that this regulation
would not result in any takings that
might require compensation under the
Fifth Amendment to the U.S.
Constitution.
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 (February 22, 2002), and DOE’s
guidelines were published at 67 FR
62446 (October 7, 2002). DOE has
reviewed this final rule under the OMB
and DOE guidelines and has concluded
that it is consistent with applicable
policies in those guidelines.
mstockstill on DSK4VPTVN1PROD with RULES2
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
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
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energy action. For any 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 concluded that this
regulatory action, which sets forth
energy conservation standards for
automatic commercial ice makers, is not
a significant energy action because the
new and amended 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 final
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
2664 (January 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 at 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 and/or
projects. The ‘‘Energy Conservation
Standards Rulemaking Peer Review
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Frm 00110
Fmt 4701
Sfmt 4700
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.
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will
report to Congress on the promulgation
of this rule prior to its effective date.
The report will state that it has been
determined that the rule is a ‘‘major
rule’’ as defined by 5 U.S.C. 804(2).
VII. Approval of the Office of the
Secretary
The Secretary of Energy has approved
publication of today’s final rule.
List of Subjects in 10 CFR Part 431
Administrative practice and
procedure, Confidential business
information, Energy conservation,
Reporting and recordkeeping
requirements.
Issued in Washington, DC, on December
31, 2014.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy
Efficiency, Energy Efficiency and Renewable
Energy.
For the reasons set forth in the
preamble, DOE amends 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.
2. Section 431.136 is revised to read
as follows:
■
§ 431.136 Energy conservation standards
and their effective dates.
(a) All basic models of commercial ice
makers must be tested for performance
using the applicable DOE test procedure
in § 431.134, be compliant with the
applicable standards set forth in
paragraphs (b) through (d) of this
section, and be certified to the
Department of Energy under 10 CFR
part 429 of this chapter.
(b) Each cube type automatic
commercial ice maker with capacities
between 50 and 2,500 pounds per 24hour period manufactured on or after
January 1, 2010 and before January 28,
2018, shall meet the following standard
levels:
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Equipment type
Type of
cooling
Ice-Making Head .........................................................................................
Ice-Making Head .........................................................................................
Water .......
Water .......
Ice-Making Head .........................................................................................
Ice-Making Head .........................................................................................
Ice-Making Head .........................................................................................
Remote Condensing (but not remote compressor) ....................................
Remote Condensing (but not remote compressor) ....................................
Remote Condensing and Remote Compressor .........................................
Remote Condensing (but not remote compressor) ....................................
Self-Contained ............................................................................................
Self-Contained ............................................................................................
Self-Contained ............................................................................................
Self-Contained ............................................................................................
Water .......
Air ............
Air ............
Air ............
Air ............
Air ............
Air ............
Water .......
Water .......
Air ............
Air ............
Harvest rate
lb ice/24
hours
<500
≥500 and
<1,436
≥1,436
<450
≥450
<1,000
≥1,000
<934
≥934
<200
≥200
<175
≥175
Maximum
energy use
kWh/100 lb ice
4755
Maximum
condenser water
use 1
gal/100 lb ice
7.8–0.0055H 2 .......
5.58–0.0011H .......
200–0.022H.
200–0.022H.
4.0 .........................
10.26–0.0086H .....
6.89–0.0011H .......
8.85–0.0038H .......
5.1 .........................
8.85–0.0038H .......
5.3 .........................
11.40–0.019H .......
7.6 .........................
18.0–0.0469H .......
9.8 .........................
200–0.022H.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
Not Applicable.
191–0.0315H.
191–0.0315H.
Not Applicable.
Not Applicable.
1 Water
use is for the condenser only and does not include potable water used to make ice.
= harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.
Source: 42 U.S.C. 6313(d).
2H
(c) Each batch type automatic
commercial ice maker with capacities
between 50 and 4,000 pounds per 24hour period manufactured on or after
January 28, 2018, shall meet the
following standard levels:
Maximum
condenser water
use
gal/100 lb ice 2
Equipment type
Type of
cooling
Harvest rate
lb ice/24
hours
Maximum
energy use
kilowatt-hours
(kWh)/100 lb ice 1
Ice-Making Head .........................................................................................
Ice-Making Head .........................................................................................
Water .......
Water .......
6.88–0.0055H .......
5.80–0.00191H .....
200–0.022H.
200–0.022H.
Ice-Making Head .........................................................................................
Water .......
4.42–0.00028H .....
200–0.022H.
Ice-Making Head .........................................................................................
Water .......
4.0 .........................
200–0.022H.
Ice-Making Head .........................................................................................
Water .......
4.0 .........................
145.
Ice-Making Head .........................................................................................
Ice-Making Head .........................................................................................
Air ............
Air ............
10–0.01233H ........
7.05–0.0025H .......
NA.
NA.
Ice-Making Head .........................................................................................
Air ............
5.55–0.00063H .....
NA.
Ice-Making Head .........................................................................................
Air ............
4.61 .......................
NA.
Remote Condensing (but not remote compressor) ....................................
Remote Condensing (but not remote compressor) ....................................
Air ............
Air ............
7.97–0.00342H .....
4.59 .......................
NA.
NA.
Remote Condensing and Remote Compressor .........................................
Remote Condensing and Remote Compressor .........................................
Air ............
Air ............
7.97–0.00342H .....
4.79 .......................
NA.
NA.
Self-Contained ............................................................................................
Self-Contained ............................................................................................
Water .......
Water .......
9.5–0.019H ...........
5.7 .........................
191–0.0315H.
191–0.0315H.
Self-Contained ............................................................................................
Water .......
5.7 .........................
112.
Self-Contained ............................................................................................
Self-Contained ............................................................................................
Air ............
Air ............
14.79–0.0469H .....
12.42–0.02533H ...
NA.
NA.
Self-Contained ............................................................................................
Air ............
< 300
≥300 and
<850
≥850 and
<1,500
≥1,500 and
<2,500
≥2,500 and
<4,000
< 300
≥ 300 and <
800
≥ 800 and <
1,500
≥ 1500 and
< 4,000
< 988
≥ 988 and <
4,000
< 930
≥ 930 and <
4,000
< 200
≥ 200 and <
2,500
≥ 2,500 and
< 4,000
< 110
≥ 110 and <
200
≥ 200 and <
4,000
7.35 .......................
NA.
1H
= harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
use is for the condenser only and does not include potable water used to make ice.
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2 Water
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(d) Each continuous type automatic
commercial ice maker with capacities
between 50 and 4,000 pounds per 24hour period manufactured on or after
January 28, 2018, shall meet the
following standard levels:
Maximum
condenser water
use
gal/100 lb ice 2
Equipment type
Type of
cooling
Harvest rate
lb ice/24
hours
Maximum
energy use
kWh/100 lb ice 1
Ice-Making Head .........................................................................................
Ice-Making Head .........................................................................................
Water .......
Water .......
6.48–0.00267H .....
4.34 .......................
180–0.0198H.
180–0.0198H.
Ice-Making Head .........................................................................................
Water .......
4.34 .......................
130.5.
Ice-Making Head .........................................................................................
Ice-Making Head .........................................................................................
Air ............
Air ............
9.19–0.00629H .....
8.23–0.0032H .......
NA.
NA.
Ice-Making Head .........................................................................................
Air ............
5.61 .......................
NA.
Remote Condensing (but not remote compressor) ....................................
Remote Condensing (but not remote compressor) ....................................
Air ............
Air ............
9.7–0.0058H .........
5.06 .......................
NA.
NA.
Remote Condensing and Remote Compressor .........................................
Air ............
9.9–0.0058H .........
5.26 .......................
NA.
NA.
Self-Contained ............................................................................................
Self-Contained ............................................................................................
Water .......
Water .......
7.6–0.00302H .......
4.88 .......................
153–0.0252H.
153–0.0252H.
Self-Contained ............................................................................................
Water .......
4.88 .......................
90.
Self-Contained ............................................................................................
Self-Contained ............................................................................................
Air ............
Air ............
14.22–0.03H .........
9.47–0.00624H .....
NA.
NA.
Self-Contained ............................................................................................
Air ............
<801
≥801 and
<2,500
≥2,500 and
<4,000
<310
≥310 and
<820
≥820 and
<4,000
<800
≥800 and
<4,000
<800
≥800 and
<4,000
<900
≥900 and
<2,500
≥2,500 and
<4,000
<200
≥200 and
<700
≥700 and
<4,000
5.1 .........................
NA.
1H
= harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
use is for the condenser only and does not include potable water used to make ice.
2 Water
Appendix
mstockstill on DSK4VPTVN1PROD with RULES2
[The following letter from the Department of
Justice will not appear in the Code of
Federal Regulations.]
U.S. Department of Justice, Antitrust
Division, William J. Baer, Acting
Assistant Attorney General, RFK Main
Justice Building, 950 Pennsylvania Ave.,
NW., Washington, DC 20530–0001,
(202)514–2401/(202)616–2645 (Fax)
December 24, 2014
Eric J. Fygi, Deputy General Counsel,
Department of Energy, Washington, DC
20585
Re: Energy Conservation Standards for
Automatic Commercial Ice Makers,
Dear Deputy General Counsel Fygi:
I am responding to your December 3, 2014
letter seeking the views of the Attorney
General about the potential impact on
competition of proposed energy conservation
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20:54 Jan 27, 2015
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standards for automatic commercial ice
makers. Your request was submitted under
Section 325(o)(2)(B)(i)(V) of the Energy
Policy and Conservation Act, as amended
(ECPA), 42 U.S.C. 6295(o)(2)(B)(i)(V), which
requires the Attorney General to make a
determination of the impact of any lessening
of competition that is likely to result from the
imposition of proposed energy conservation
standards. The Attorney General’s
responsibility for responding to requests from
other departments about the effect of a
program on competition has been delegated
to the Assistant Attorney General for the
Antitrust Division in 28 CFR §0.40(g).
In conducting its analysis the Antitrust
Division examines whether a proposed
standard may lessen competition, for
example, by substantially limiting consumer
choice, by placing certain manufacturers at
an unjustified competitive disadvantage, or
by inducing avoidable inefficiencies in
production or distribution of particular
PO 00000
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products. A lessening of competition could
result in higher prices to manufacturers and
consumers.
We have reviewed the proposed standards
contained in the Notice of Proposed
Rulemaking (79 FR 14848, March 17, 2014)
(NOPR). In light of the short time frame for
our review of the proposed standards, we
also consulted with DOE staff on the issues
raised by the proposed NOPR.
Based on this review and consultation with
DOE staff, our conclusion is that the
proposed energy conservation standards for
automatic commercial ice makers are
unlikely to have a significant adverse impact
on competition.
Sincerely,
William J. Baer
Enclosure
[FR Doc. 2015–00326 Filed 1–27–15; 8:45 am]
BILLING CODE 6450–01–P
E:\FR\FM\28JAR2.SGM
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]]>Agencies
[Federal Register Volume 80, Number 18 (Wednesday, January 28, 2015)]
[Rules and Regulations]
[Pages 4645-4756]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2015-00326]
[[Page 4645]]
Vol. 80
Wednesday,
No. 18
January 28, 2015
Part II
Department of Energy
-----------------------------------------------------------------------
10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for
Automatic Commercial Ice Makers; Final Rule
Federal Register / Vol. 80 , No. 18 / Wednesday, January 28, 2015 /
Rules and Regulations
[[Page 4646]]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket Number EERE-2010-BT-STD-0037]
RIN 1904-AC39
Energy Conservation Program: Energy Conservation Standards for
Automatic Commercial Ice Makers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Final rule.
-----------------------------------------------------------------------
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
automatic commercial icemakers (ACIM). EPCA also requires the U.S.
Department of Energy (DOE) to determine whether more-stringent
standards would be technologically feasible and economically justified,
and would save a significant amount of energy. In this final rule, DOE
is adopting more-stringent energy conservation standards for some
classes of automatic commercial ice makers as well as establishing
energy conservation standards for other classes of automatic commercial
ice makers. It has determined that the amended energy conservation
standards for these products would result in significant conservation
of energy, and are technologically feasible and economically justified.
DATES: The effective date of this rule is March 30, 2015. Compliance
with the amended standards established for automatic commercial ice
makers in this final rule is required on January 28, 2018.
ADDRESSES: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at www.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://www.regulations.gov/#!docketDetail;D=EERE-2010-BT-STD-0037.
The regulations.gov Web page will contain simple instructions on
how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms.
Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
John Cymbalsky, 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) 287-1692. Email: commercial_ice_makers@EE.Doe.Gov.
Ms. Sarah Butler, U.S. Department of Energy, Office of the General
Counsel, Mailstop GC-71, 1000 Independence Avenue SW., Washington, DC
20585-0121. Telephone: (202) 586-1777. Email: Sarah.Butler@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Discussion of the Final Rule and Its Benefits
A. Benefits and Costs to Customers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Automatic Commercial Ice
Makers
III. General Discussion
A. Equipment Classes and Scope of Coverage
B. Test Procedure
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Commercial Customers
b. Savings in Operating Costs Compared to Increase in Price
(Life Cycle Costs)
c. Energy Savings
d. Lessening of Utility or Performance of Equipment
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 of Comments
A. General Rulemaking Issues
1. Proposed Standard Levels
2. Compliance Date
3. Negotiated Rulemaking
4. Refrigerant Regulation
5. Data Availability
6. Supplemental Notice of Proposed Rulemaking.
7. Rulemaking Structure Comments
B. Market and Technology Assessment
1. Equipment Classes
a. Cabinet Size
b. Large-Capacity Batch Ice Makers
c. Regulation of Potable Water Use
d. Regulation of Condenser Water Use
e. Continuous Models
f. Gourmet Ice Machines
2. Technology Assessment
a. Alternative Refrigerants
C. Screening Analysis
a. General Comments
b. Drain Water Heat Exchanger
c. Tube Evaporator Design
d. Low Thermal Mass Evaporator Design
e. Microchannel Heat Exchangers
f. Smart Technologies
g. Motors
D. Engineering Analysis
1. Representative Equipment for Analysis
2. Efficiency Levels
a. Baseline Efficiency Levels
b. Incremental Efficiency Levels
c. IMH-A-Large-B Treatment
d. Maximum Available Efficiency Equipment
e. Maximum Technologically Feasible Efficiency Levels
3. Design Options
a. Design Options that Need Cabinet Growth
b. Improved Condenser Performance
c. Compressors
d. Evaporator
e. Interconnectedness of Automatic Commercial Ice Maker System
4. Cost Assessment Methodology
a. Manufacturing Cost
b. Energy Consumption Model
c. Revision of NOPR and NODA Engineering Analysis
E. Markups Analysis
F. Energy Use Analysis
G. Life-Cycle Cost and Payback Period Analysis
1. Equipment Cost
2. Installation, Maintenance, and Repair Costs
a. Installation Costs
b. Repair and Maintenance Costs
3. Annual Energy and Water Consumption
4. Energy Prices
5. Energy Price Projections
6. Water Prices
7. Discount Rates
8. Lifetime
9. Compliance Date of Standards
10. Base-Case and Standards-Case Efficiency Distributions
11. Inputs to Payback Period Analysis
12. Rebuttable Presumption Payback Period
H. National Impact Analysis--National Energy Savings and Net
Present Value
1. Shipments
2. Forecasted Efficiency in the Base Case and Standards Cases
3. National Energy Savings
4. Net Present Value of Customer Benefit
I. Customer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model
a. Government Regulatory Impact Model Key Inputs
b. Government Regulatory Impact Model Scenarios
3. Discussion of Comments
a. Conversion Costs
b. Cumulative Regulatory Burden
[[Page 4647]]
c. SNAP and Compliance Date Considerations
d. ENERGY STAR
e. Request for DOE and EPA Collaboration
f. Compliance With Refrigerant Changes Could Be Difficult
g. Small Manufacturers
h. Large Manufacturers
i. Negative Impact on Market Growth
j. Negative Impact on Non-U.S. Sales
k. Employment
l. Compliance With 12866 and 13563
m. Warranty Claims
n. Impact to Suppliers, Distributors, Dealers, and Contractors
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Development of Social Cost of Carbon Values
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
M. Utility Impact Analysis
N. Employment Impact Analysis
O. Regulatory Impact Analysis
V. Analytical Results
A. Trial Standard Levels
1. Trial Standard Level Formulation Process and Criteria
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 Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Amount and Significance of Energy Savings
b. Net Present Value of Customer Costs and Benefits
c. Water Savings
d. Indirect 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. Conclusions/Proposed Standard
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description and Estimated Number of Small Entities Regulated
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict With Other Rules and
Regulations
4. Significant Alternatives to the Rule
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
M. Congressional Notification
VII. Approval of the Office of the Secretary
I. Discussion of the Final Rule and Its Benefits
Title III, Part C \1\ of the Energy Policy and Conservation Act of
1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6311-6317, as
codified), established the Energy Conservation Program for Certain
Industrial Equipment, a program covering certain industrial
equipment,\2\ which includes the focus of this final rule: Automatic
commercial ice makers (ACIM).
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\1\ For editorial reasons, upon codification in the U.S. Code,
Part C was re-designated Part A-1.
\2\ 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).
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Pursuant to EPCA, any new or amended energy conservation standard
that DOE prescribes for certain products, such as automatic commercial
ice makers, shall be designed to achieve the maximum improvement in
energy efficiency that DOE determines is both technologically feasible
and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the
new or amended standard must result in significant conservation of
energy. (42 U.S.C. 6295(o)(3)(B) and 6313(d)(4))
In accordance with these and other statutory criteria discussed in
this final rule, DOE is amending energy conservation standards for
automatic commercial ice makers,\3\ and new standards for covered
equipment not yet subject to energy conservation standards. The amended
standards, which consist of maximum allowable energy use per 100 lb of
ice production, are shown in Table I.1 and Table I.2. Standards shown
on Table I.1 for batch type ice makers represent the amendments to
existing standards set for cube type ice makers at 42 U.S.C.
6313(d)(1), and new standards for cube type ice makers with expanded
harvest capacities up to 4,000 pounds of ice per 24 hour period (lb
ice/24 hours) and an explicit coverage of other types of batch
machines, such as tube type ice makers. Table I.2 provides new
standards for continuous type ice-making machines, which were not
previously currently covered by DOE's existing standards. The amended
standards include, for applicable equipment classes, maximum condenser
water usage values in gallons per 100 lb of ice production. These new
and amended standards apply to all equipment manufactured in, or
imported into, the United States, on or after January 28, 2018. (42
U.S.C. 6313(d)(2)(B)(i) and (3)(C)(i))
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\3\ EPCA as amended by EPACT 2005 established maximum energy use
and maximum condenser water use standards for cube type automatic
commercial ice makers with harvest capacities between 50 and 2,500
lb ice/24 hours. In this rulemaking, DOE is amending the legislated
energy use standards for these automatic commercial ice maker types.
DOE is not, however, amending the existing condenser water use
standards for equipment with existing condenser water standards.
Table I.1--Energy Conservation Standards for Batch Type Automatic Commercial Icemakers
[Compliance required starting January 28, 2018]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Maximum energy use kilowatt- Maximum condenser water use
Equipment type Type of cooling Harvest rate lb ice/24 hours hours (kWh)/100 lb ice * gal/100 lb ice **
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice-Making Head................. Water................... <300 6.88--0.0055H 200--0.022H.
>=300 and <850 5.80--0.00191H 200--0.022H.
>=850 and <1,500 4.42--0.00028H 200--0.022H.
>=1,500 and <2,500 4.0 200--0.022H.
>=2,500 and <4,000 4.0 145.
Ice-Making Head................. Air..................... <300 10--0.01233H NA.
>=300 and <800 7.05--0.0025H NA.
>=800 and <1,500 5.55--0.00063H NA.
>=1500 and <4,000 4.61 NA.
[[Page 4648]]
Remote Condensing (but not Air..................... >=50 and <1,000 7.97--0.00342H NA.
remote compressor).
>=1,000 and <4,000 4.55 NA.
Remote Condensing and Remote Air..................... <942 7.97--0.00342H NA.
Compressor.
>=942 and <4,000 4.75 NA.
Self-Contained.................. Water................... <200 9.5--0.019H 191--0.0315H.
>=200 and <2,500 5.7 191--0.0315H.
>=2,500 and <4,000 5.7 112.
Self-Contained.................. Air..................... <110 14.79--0.0469H NA.
>=110 and <200 12.42--0.02533H NA.
>=200 and <4,000 7.35 NA.
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* H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
** Water use is for the condenser only and does not include potable water used to make ice.
Table I.2--Energy Conservation Standards for Continuous Type Automatic Commercial Ice Makers
[Compliance required starting January 28, 2018]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Maximum energy use kWh/100 lb Maximum condenser water use
Equipment type Type of cooling Harvest rate lb ice/24 hours ice * gal/100 lb ice **
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice-Making Head................. Water................... <801 6.48--0.00267H 180--0.0198H.
>=801 and <2,500 4.34 180--0.0198H.
>=2,500 and <4,000 4.34 130.5.
Ice-Making Head................. Air..................... <310 9.19--0.00629H NA.
>=310 and <820 8.23--0.0032H NA.
>=820 and <4,000 5.61 NA.
Remote Condensing (but not Air..................... <800 9.7--0.0058H NA.
remote compressor).
>=800 and <4,000 5.06 NA.
Remote Condensing and Remote Air..................... <800 9.9--0.0058H NA.
Compressor.
>=800 and <4,000 5.26 NA.
Self-Contained.................. Water................... <900 7.6--0.00302H 153--0.0252H.
>=900 and <2,500 4.88 153--0.0252H.
>=2,500 and <4,000 4.88 90.
Self-Contained.................. Air..................... <200 14.22--0.03H NA.
>=200 and <700 9.47--0.00624H NA.
>=700 and <4,000 5.1 NA.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
** Water use is for the condenser only and does not include potable water used to make ice.
A. Benefits and Costs to Customers
Table I.3 presents DOE's evaluation of the economic impacts of the
standards set by this final rule on customers of automatic commercial
ice makers, as measured by the average life-cycle cost (LCC) savings
\4\ and the median payback period (PBP).\5\ The average LCC savings are
positive for all equipment classes for which customers are impacted by
the new and amended standards.
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\4\ Life-cycle cost of automatic commercial ice makers 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.
\5\ Payback period 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 can be found in chapter 8 of the
final rule TSD.
Table I.3--Impacts of Today's Standards on Customers of Automatic
Commercial Ice Makers
------------------------------------------------------------------------
Average LCC
Equipment class * savings 2013$ Median PBP years
------------------------------------------------------------------------
IMH-W-Small-B....................... 214 2.7
IMH-W-Med-B......................... 308 2.1
IMH-W-Large-B **.................... NA NA
IMH-W-Large-B-1................. NA NA
IMH-W-Large-B-2................. NA NA
IMH-A-Small-B....................... 77 4.7
IMH-A-Large-B **.................... 361 2.3
IMH-A-Large-B-1................. 407 1.5
IMH-A-Large-B-2................. 110 6.9
RCU-Large-B **...................... 748 1.1
[[Page 4649]]
RCU-Large-B-1................... 743 0.9
RCU-Large-B-2................... 820 3.0
SCU-W-Large-B....................... 550 1.8
SCU-A-Small-B....................... 281 2.6
SCU-A-Large-B....................... 439 2.1
IMH-A-Small-C....................... 313 1.7
IMH-A-Large-C....................... 626 0.7
RCU-Small-C......................... 505 1.2
SCU-A-Small-C....................... 290 1.5
------------------------------------------------------------------------
* Abbreviations are: IMH is ice-making head; RCU is remote condensing
unit; SCU is self-contained unit; W is water-cooled; A is air-cooled;
Small refers to the lowest harvest category; Med refers to the Medium
category (water-cooled IMH only); RCU with and without remote
compressor were modeled as one group. For three large batch
categories, a machine at the low end of the harvest range (B-1) and a
machine at the higher end (B-2) were modeled. Values are shown only
for equipment classes that have significant volume of shipments and,
therefore, were directly analyzed. See chapter 5 of the final rule
technical support document, ``Engineering Analysis,'' for a detailed
discussion of equipment classes analyzed.
** LCC savings and PBP results for these classes are weighted averages
of the typical units modeled for the large classes, using weights
provided in TSD chapter 7.
B. Impact on Manufacturers \6\
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\6\ All dollar values presented are in 2013$ discounted back to
the year 2014.
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The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from 2015 through the end of the analysis
period in 2047. Using a real discount rate of 9.2 percent, DOE
estimates that the INPV for manufacturers of automatic commercial ice
makers is $121.6 million in 2013$. Under the amended standards, DOE
expects that manufacturers may lose up to 12.5 percent of their INPV,
or approximately $15.1 million.
C. National Benefits and Costs
DOE's analyses indicate that the amended standards for automatic
commercial ice makers would save a significant amount of energy. The
lifetime energy savings for equipment purchased in the 30-year period
that begins in the year of compliance with amended and new standards
(2018-2047), \7\ relative to the base case without amended standards,
amount to 0.18 quadrillion British thermal units (quads) of cumulative
energy. This represents a savings of 8 percent relative to the energy
use of these products in the base case.
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\7\ The standards analysis period for national benefits covers
the 30-year period, plus the life of equipment purchased during the
period. In the past, DOE presented energy savings results for only
the 30-year period that begins in the year of compliance. In the
calculation of economic impacts, however, DOE considered operating
cost savings measured over the entire lifetime of products purchased
in the 30-year period. DOE has chosen to modify its presentation of
national energy savings to be consistent with the approach used for
its national economic analysis.
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The cumulative national net present value (NPV) of total customer
savings of the amended standards for automatic commercial ice makers in
2013$ ranges from $0.430 billion (at a 7-percent discount rate) to
$0.942 billion (at a 3-percent discount rate \8\). This NPV expresses
the estimated total value of future operating cost savings minus the
estimated increased installed costs for equipment purchased in the
period from 2018-2047, discounted back to the current year (2014).
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\8\ These discount rates are used in accordance with the Office
of Management and Budget (OMB) guidance to Federal agencies on the
development of regulatory analysis (OMB Circular A-4, September 17,
2003), and section E, ``Identifying and Measuring Benefits and
Costs,'' therein. Further details are provided in section IV.J.
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In addition, the amended standards are expected to have significant
environmental benefits. The energy savings described above are
estimated to result in cumulative emission reductions of 10.9 million
metric tons (MMt) \9\ of carbon dioxide (CO2), 16.2 thousand
tons of nitrogen oxides (NOX), 0.1 thousand tons of nitrous
oxide (N2O), 47.4 thousand tons of methane (CH4),
0.03 tons of mercury (Hg),\10\ and 9.3 thousand tons of sulfur dioxide
(SO2) based on energy savings from equipment purchased over
the period from 2018-2047.\11\ The cumulative reduction in
CO2 emissions through 2030 amounts to 4 MMt, which is
equivalent to the emissions resulting from the annual electricity use
of over half a million homes.
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\9\ A metric ton is equivalent to 1.1 U.S. short tons. Results
for NOX, Hg, and SO2 are presented in short
tons.
\10\ DOE calculates emissions reductions relative to the Annual
Energy Outlook 2014 (AEO2014) Reference Case, which generally
represents current legislation and environmental regulations for
which implementing regulations were available as of October 31,
2013.
\11\ 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 3.9 million metric tons CO2, 395 thousand tons
CO2eq for CH4, and 12 thousand tons
CO2eq for N2O.
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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 a recent Federal
interagency process.\12\ The derivation of the SCC value is discussed
in section IV.L. Using discount rates appropriate for each set of SCC
values, DOE estimates the net present monetary value of the
CO2 emissions reduction is between $0.08 and $1.11 billion,
expressed in 2013$ and discounted to 2014, with a value of $0.36
billion using the central SCC case represented by $40.5/t in 2015. DOE
also estimates the net present monetary value of the NOX
emissions reduction, expressed in 2013$ and discounted to 2014, is
between $2.1 and $22.0 million at a 7-percent discount rate, and
between $4.2 and $43.4 million at a 3-percent discount rate.\13\
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\12\ https://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
\13\ DOE has decided to await further guidance regarding
consistent valuation and reporting of Hg emissions before it
monetizes Hg in its rulemakings.
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Table I.4 summarizes the national economic costs and benefits
expected to result from these new and amended standards for automatic
commercial ice makers.
[[Page 4650]]
Table I.4--Summary of National Economic Benefits and Costs of Amended Automatic Commercial Ice Makers Energy
Conservation Standards *
----------------------------------------------------------------------------------------------------------------
Present value Discount rate
Category million 2013$ (%)
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings...................................................... 654 7
1,353 3
CO2 at 5% dr, average....................................................... 80 5
CO2 at 3% dr, average....................................................... 361 3
CO2 at 2.5% dr, average..................................................... 570 2.5
CO2 at 3% dr, 95th perc..................................................... 1,113 3
NOX Reduction Monetized Value (at $2,684/Ton) **............................ 12 7
24 3
Total Benefits [dagger]..................................................... 1,027 7
1,738 3
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Incremental Installed Costs................................................. 224 7
411 3
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Including CO2 and NOX Reduction Monetized Value............................. 803 7
1,326 3
----------------------------------------------------------------------------------------------------------------
* The CO2 values represent global monetized values of the SCC in 2013$ in year 2015 under several scenarios. The
values of $12, $40.5, and $62.4 per metric ton (t) are the averages of SCC distributions calculated using 5-
percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $119.0/t represents the 95th
percentile of the SCC distribution calculated using a 3-percent discount rate. The SCC time series used by DOE
incorporate an escalation factor.
** 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 the 7-percent cases are derived using the series
corresponding to SCC value of $40.5/t.
The benefits and costs of these new and amended standards, for
automatic commercial ice makers sold in 2018-2047, 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 the operation of equipment that meets the amended
standards (consisting primarily of operating cost savings from using
less energy and water, minus increases in equipment installed cost,
which is another way of representing customer NPV); and (2) the
annualized monetary value of the benefits of emission reductions,
including CO2 emission reductions.\14\
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\14\ 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 2014, 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 3 and 7 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.4. From the present value, DOE then calculated the
fixed annual payment over a 30-year period (2018 through 2047) 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.
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Although adding the values of operating savings to the values of
emission reductions provides an important perspective, two issues
should be considered. First, the national operating savings are
domestic U.S. customer monetary savings that occur as a result of
market transactions, whereas 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 over the lifetimes of automatic commercial ice
makers shipped from 2018 to 2047. The SCC values, on the other hand,
reflect the present value of some future climate-related impacts
resulting from the emission of 1 ton of CO2 in each year.
These impacts continue well beyond 2100.
Estimates of annualized benefits and costs of the amended standards
are shown in Table I.5. (All monetary values below are expressed in
2013$.) Table I.5 shows the primary, low net benefits, and high net
benefits scenarios. The primary estimate is the estimate in which the
operating cost savings were calculated using the Annual Energy Outlook
2014 (AEO2014) Reference Case forecast of future electricity prices.
The low net benefits estimate and the high net benefits estimate are
based on the low and high electricity price scenarios from the AEO2014
forecast, respectively.\15\ Using a 7-percent discount rate for
benefits and costs, the cost in the primary estimate of the standards
amended in this rule is $22 million per year in increased equipment
costs. (Note that DOE used a 3-percent discount rate along with the
corresponding SCC series value of $40.5/ton in 2013$ to calculate the
monetized value of CO2 emissions reductions.) The annualized
benefits are $65 million per year in reduced equipment operating costs,
$20 million in CO2 reductions, and $1.19 million in reduced
NOX emissions. In this case, the annualized net benefit
amounts to $64 million. At a 3-percent discount rate for all benefits
and costs, the cost in the primary estimate of the amended standards
presented in this rule is $23 million per year in increased equipment
costs. The benefits are $75 million per year in reduced operating
costs, $20 million in CO2 reductions, and $1.33 million in
reduced NOX emissions. In this case, the net benefit amounts
to $74 million per year.
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\15\ The AEO2014 scenarios used are the ``High Economics'' and
``Low Economics'' scenarios.
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DOE also calculated the low net benefits and high net benefits
estimates
[[Page 4651]]
by calculating the operating cost savings and shipments at the AEO2014
low economic growth case and high economic growth case scenarios,
respectively. The low and high benefits for incremental installed costs
were derived using the low and high price learning scenarios. The net
benefits and costs for low and high net benefits estimates were
calculated in the same manner as the primary estimate by using the
corresponding values of operating cost savings and incremental
installed costs.
Table I.5--Annualized Benefits and Costs of Proposed Standards for Automatic Commercial Ice Makers *
----------------------------------------------------------------------------------------------------------------
Low net High net
Discount rate Primary benefits benefits
(%) estimate* estimate * estimate *
million 2013$ million 2013$ million 2013$
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings.................. 7 65 62 68
3 75 71 80
CO2 at 5% dr, average **................ 5 6 6 6
CO2 at 3% dr, average **................ 3 20 20 21
CO2 at 2.5% dr, average **.............. 2.5 29 28 30
CO2 at 3% dr, 95th perc **.............. 3 62 60 64
NOX Reduction Monetized Value (at $2,684/ 7 1.19 1.16 1.22
Ton) **................................ 3 1.33 1.29 1.36
Total Benefits (Operating Cost Savings, 7 86 82 90
CO2 Reduction and NOX Reduction) 3 97 92 102
[dagger]...............................
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Total Incremental Installed Costs....... 7 22 23 21
3 23 24 22
----------------------------------------------------------------------------------------------------------------
Net Benefits Less Costs
----------------------------------------------------------------------------------------------------------------
Total Benefits Less Incremental Costs... 7 64 60 69
3 74 68 80
----------------------------------------------------------------------------------------------------------------
* The primary, low, and high estimates utilize forecasts of energy prices from the AEO2014 Reference Case, Low
Economic Growth Case, and High Economic Growth Case, respectively.
** These values represent global values (in 2013$) of the social cost of CO2 emissions in 2015 under several
scenarios. The values of $12, $40.5, and $62.4 per ton are the averages of SCC distributions calculated using
5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $119.0 per ton represents the
95th percentile of the SCC distribution calculated using a 3-percent discount rate. See section IV.L for
details. For NOX, an average value ($2,684) of the low ($476) and high ($4,893) values was used.
[dagger] Total monetary benefits for both the 3-percent and 7-percent cases utilize the central estimate of
social cost of NOX and CO2 emissions calculated at a 3-percent discount rate (averaged across three integrated
assessment models), which is equal to $40.5/ton (in 2013$).
D. Conclusion
Based on the analyses culminating in this final rule, DOE found the
benefits to the nation of the amended standards (energy savings,
consumer LCC savings, positive NPV of consumer benefit, and emission
reductions) outweigh the burdens (loss of INPV and LCC increases for
some users of this equipment). DOE has concluded that the standards in
this final rule represent the maximum improvement in energy efficiency
that is both technologically feasible and economically justified, and
would result in significant conservation of energy. (42 U.S.C. 6295(o),
6313(d)(4))
II. Introduction
The following section briefly discusses the statutory authority
underlying this final rule, as well as some of the relevant historical
background related to the establishment of amended standards for
automatic commercial ice makers.
A. Authority
Title III, Part C \16\ 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 automatic commercial ice makers, the focus of this
rule.\17\
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\16\ For editorial reasons, upon codification in the U.S. Code,
Part C was re-designated Part A-1.
\17\ 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).
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EPCA prescribed energy conservation standards for automatic
commercial ice makers that produce cube type ice with capacities
between 50 and 2,500 lb ice/24 hours. (42 U.S.C. 6313(d)(1)) EPCA
requires DOE to review these standards and determine, by January 1,
2015, whether amending the applicable standards is technically feasible
and economically justified. (42 U.S.C. 6313(d)(3)(A)) If amended
standards are technically feasible and economically justified, DOE must
issue a final rule by the same date. (42 U.S.C. 6313(d)(3)(B))
Additionally, EPCA granted DOE the authority to conduct rulemakings to
establish new standards for automatic commercial ice makers not covered
by 42 U.S.C. 6313(d)(1)), and DOE is using that authority in this
rulemaking. (42 U.S.C. 6313(d)(2)(A))
Pursuant to EPCA, 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 automatic commercial ice
makers, DOE is responsible for the entirety of this program. Subject to
certain criteria and conditions, DOE is required to develop test
procedures to measure the energy efficiency, energy use, or estimated
annual operating cost of each type or class of covered equipment. (42
U.S.C. 6314) Manufacturers of covered equipment
[[Page 4652]]
must use the prescribed DOE test procedure as the basis for certifying
to DOE that their equipment complies with the applicable energy
conservation standards adopted under EPCA and when making
representations to the public regarding the energy use or efficiency of
that equipment. (42 U.S.C. 6315(b), 6295(s)) Similarly, DOE must use
these test procedures to determine whether that equipment complies with
standards adopted pursuant to EPCA. The DOE test procedure for
automatic commercial ice makers currently appears at title 10 of the
Code of Federal Regulations (CFR) part 431, subpart H.
DOE must follow specific statutory criteria for prescribing amended
standards for covered equipment. As indicated above, any amended
standard for covered equipment must be designed to achieve the maximum
improvement in energy efficiency that is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A) and 6313(d)(4))
Furthermore, DOE may not adopt any standard that would not result in
the significant conservation of energy. (42 U.S.C. 6295(o)(3) and
6313(d)(4)) DOE also may not prescribe a standard: (1) For certain
equipment, including automatic commercial ice makers, if no test
procedure has been established for the product; or (2) if DOE
determines, by rule that such standard is not technologically feasible
or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B) and 6313(d)(4))
In deciding whether a proposed standard is economically justified, DOE
must determine whether the benefits of the standard exceed its burdens.
(42 U.S.C. 6295(o)(2)(B)(i) and 6313(d)(4)) DOE must make this
determination after receiving comments on the proposed standard, and by
considering, to the greatest extent practicable, the following seven
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 U.S. Attorney General (Attorney General), that is
likely to result from the imposition of the standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary considers relevant.
(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII) and 6313(d)(4))
EPCA, as codified, also contains what is known as an ``anti-
backsliding'' provision, which prevents the Secretary from prescribing
any amended standard that either increases the maximum allowable energy
use or decreases the minimum required energy efficiency of covered
equipment. (42 U.S.C. 6295(o)(1) and 6313(d)(4)) Also, the Secretary
may not 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. (42 U.S.C. 6295(o)(4) and 6313(d)(4))
Further, EPCA, as codified, 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 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) and
6313(d)(4) Section III.E.2 presents additional discussion about the
rebuttable presumption payback period.
Additionally, 42 U.S.C. 6295(q)(1) and 6316(a) specifies
requirements when promulgating a standard for a type or class of
covered equipment that has two or more subcategories that may justify
different standard levels. DOE must specify a different standard level
than that which applies generally to such type or class of equipment
for any group of covered products that has the same function or
intended use if DOE determines that products within such group (A)
consume a different kind of energy from that consumed by other covered
equipment within such type (or class); or (B) have a capacity or other
performance-related feature that other equipment within such type (or
class) do not have and such feature justifies a higher or lower
standard. (42 U.S.C. 6295(q)(1)) and 6316(a)) In determining whether a
performance-related feature justifies a different standard for a group
of equipment, DOE must consider such factors as the utility to the
consumer of the feature and other factors DOE deems appropriate. Id.
Any rule prescribing such a standard must include an explanation of the
basis on which such higher or lower level was established. (42 U.S.C.
6295(q)(2)) and 6316(a))
Federal energy conservation requirements generally supersede State
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a)-(c) and 6316(f)) DOE may, however,
grant waivers of Federal preemption for particular State laws or
regulations in accordance with the test procedures and other provisions
set forth under 42 U.S.C. 6297(d) and 6316(f).
B. Background
1. Current Standards
In a final rule published on October 18, 2005, DOE adopted the
energy conservation standards and water conservation standards
prescribed by EPCA in 42 U.S.C. 6313(d)(1) for certain automatic
commercial ice makers manufactured on or after January 1, 2010. 70 FR
60407, 60415-16. These standards consist of maximum energy use and
maximum condenser water use to produce 100 pounds of ice for automatic
commercial ice makers with harvest rates between 50 and 2,500 lb ice/24
hours. These standards appear at 10 CFR part 431, subpart H, Automatic
Commercial Ice Makers. Table II.1 presents DOE's current energy
conservation standards for automatic commercial ice makers.
Table II.1--Automatic Commercial Ice Makers Standards Prescribed by EPCA--Compliance Required Beginning on January 1, 2010
--------------------------------------------------------------------------------------------------------------------------------------------------------
Maximum energy use kWh/100 Maximum condenser water use
Equipment type Type of cooling Harvest rate lb ice/24 hours lb ice * gal/100 lb ice
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice-Making Head................. Water................... <500 7.8-0.0055H ** 200-0.022H.**
>=500 and <1,436 5.58-0.0011H 200-0.022H.
[[Page 4653]]
>=1,436 4.0 200-0.022H.
Air..................... <450 10.26-0.0086H Not Applicable.
>=450 6.89-0.0011H Not Applicable.
Remote Condensing (but not Air..................... <1,000 8.85-0.0038H Not Applicable.
remote compressor).
>=1,000 5.10 Not Applicable.
Remote Condensing and Remote Air..................... <934 8.85-0.0038H Not Applicable.
Compressor.
>=934 5.30 Not Applicable.
Self-Contained.................. Water................... <200 11.4-0.019H 191-0.0315H.
>=200 7.60 191-0.0315H.
Air..................... <175 18.0-0.0469H Not Applicable.
>=175 9.80 Not Applicable.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Source: 42 U.S.C. 6313(d).
* Water use is for the condenser only and does not include potable water used to make ice.
** H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.
2. History of Standards Rulemaking for Automatic Commercial Ice Makers
As stated above, EPCA prescribes energy conservation standards and
water conservation standards for certain cube type automatic commercial
ice makers with harvest rates between 50 and 2,500 lb ice/24 hours:
Self-contained ice makers and ice-making heads (IMHs) using air or
water for cooling and ice makers with remote condensing with or without
a remote compressor. Compliance with these standards was required as of
January 1, 2010. (42 U.S.C. 6313(d)(1)) DOE adopted these standards and
placed them under 10 CFR part 431, subpart H, Automatic Commercial Ice
Makers.
In addition, EPCA requires DOE to conduct a rulemaking to determine
whether to amend the standards established under 42 U.S.C. 6313(d)(1),
and if DOE determines that amendment is warranted, DOE must also issue
a final rule establishing such amended standards by January 1, 2015.
(42 U.S.C. 6313(d)(3)(A))
Furthermore, EPCA granted DOE authority to set standards for
additional types of automatic commercial ice makers that are not
covered in 42 U.S.C. 6313(d)(1). (42 U.S.C. 6313(d)(2)(A)) Additional
types of automatic commercial ice makers DOE identified as candidates
for standards to be established in this rulemaking include flake and
nugget, as well as batch type ice makers that are not included in the
EPCA definition of cube type ice makers.
To satisfy its requirement to conduct a rulemaking, DOE initiated
the current rulemaking on November 4, 2010 by publishing on its Web
site its ``Rulemaking Framework for Automatic Commercial Ice Makers.''
The Framework document is available at: https://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0037-0024.
DOE also published a notice in the Federal Register announcing the
availability of the Framework document, as well as a public meeting to
discuss the document. The notice also solicited comment on the matters
raised in the document. 75 FR 70852 (Nov. 19, 2010). The Framework
document described the procedural and analytical approaches that DOE
anticipated using to evaluate amended standards for automatic
commercial ice makers, and identified various issues to be resolved in
the rulemaking.
DOE held the Framework public meeting on December 16, 2010, at
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) equipment classes; (3) analytical approaches and methods used in
the rulemaking; (4) impacts of standards and burden on manufacturers;
(5) technology options; (6) distribution channels, shipments, and end
users; (7) impacts of outside regulations; and (8) environmental
issues. 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 automatic commercial ice makers relevant
to this rulemaking.
DOE then gathered additional information and performed preliminary
analyses to help review standards for this equipment. This process
culminated in DOE publishing a notice of another public meeting (the
January 2012 notice) to discuss and receive comments regarding the
tools and methods DOE used in performing its preliminary analysis, as
well as the analyses results. 77 FR 3404 (Jan. 24, 2012) DOE also
invited written comments on these subjects and announced the
availability on its Web site of a preliminary analysis technical
support document (preliminary analysis TSD). Id. The preliminary
analysis TSD is available at: www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0037-0026. DOE sought comments
concerning other relevant issues that could affect amended standards
for automatic commercial ice makers. Id.
The preliminary analysis TSD provided an overview of DOE's review
of the standards for automatic commercial ice makers, discussed the
comments DOE received in response to the Framework document, and
addressed issues including the scope of coverage of the rulemaking. The
document also described the analytical framework that DOE used (and
continues to use) in considering amended standards for automatic
commercial ice makers, 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
analysis TSD presented in detail each analysis that DOE had performed
for this equipment up to that point, including descriptions of inputs,
sources, methodologies, and results. These analyses were as follows:
(1) A market and technology assessment, (2) a screening analysis, (3)
an engineering analysis, (4) an energy and water use analysis, (5) a
markups analysis, (6) a
[[Page 4654]]
life-cycle cost analysis, (7) a payback period analysis, (8) a
shipments analysis, (9) a national impact analysis (NIA) and (10) a
preliminary manufacturer impact analysis (MIA).
The public meeting announced in the January 2012 notice took place
on February 16, 2012 (February 2012 preliminary analysis public
meeting). At the February 2012 preliminary analysis public meeting, DOE
presented the methodologies and results of the analyses set forth in
the preliminary analysis TSD. Interested parties provided comments on
the following issues: (1) Equipment classes; (2) technology options;
(3) energy modeling and validation of engineering models; (4) cost
modeling; (5) market information, including distribution channels and
distribution markups; (6) efficiency levels; (7) life-cycle costs to
customers, including installation, repair and maintenance costs, and
water and wastewater prices; and (8) historical shipments.
On March 17, 2014, DOE published a notice of proposed rulemaking
(NOPR) in the Federal Register (March 2014 NOPR). 79 FR 14846. In the
March 2014 NOPR, DOE addressed, in detail, the comments received in
earlier stages of rulemaking, and proposed amended energy conservation
standards for automatic commercial ice makers. In conjunction with the
March 2014 NOPR, DOE also published on its Web site the complete
technical support document (TSD) for the proposed rule, which
incorporated the analyses DOE conducted and technical documentation for
each analysis. Also published on DOE's Web site were the engineering
analysis spreadsheets, the LCC spreadsheet, and the national impact
analysis standard spreadsheet. These materials are available at: https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/29.
The standards which DOE proposed for automatic commercial ice
makers at the NOPR stage of this rulemaking are shown in Table II.2 and
Table II.3. They are provided solely for background informational
purposes and differ from the amended standards set forth in this final
rule.
Table II.2--Proposed Energy Conservation Standards for Batch Type Automatic Commercial Ice Makers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Maximum energy use kilowatt- Maximum condenser water use
Equipment type Type of cooling Harvest rate lb ice/24 hours hours (kWh)/100 lb ice * gal/100 lb ice **
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice-Making Head................. Water................... <500 5.84--0.0041H 200-0.022H.
>=500 and <1,436 3.88--0.0002H 200-0.022H.
>=1,436 and <2,500 3.6 200-0.022H.
>=2,500 and <4,000 3.6 145.
Ice-Making Head................. Air..................... <450 7.70--0.0065H NA.
>=450 and <875 5.17--0.0008H NA.
>=875 and <2,210 4.5 NA.
>=2,210 and <2,500 6.89--0.0011H NA.
>=2,500 and <4,000 4.1 NA.
Remote Condensing (but not Air..................... <1,000 7.52--0.0032H NA.
remote compressor).
Air..................... >=1,000 and <4,000 4.3 NA.
Remote Condensing and Remote Air..................... <934 7.52--0.0032H NA.
Compressor.
Air..................... >=934 and <4,000 4.5 NA.
Self-Contained.................. Water................... <200 8.55--0.0143H 191-0.0315H.
>=200 and <2,500 5.7 191-0.0315H.
>=2,500 and <4,000 5.7 112.
Self-Contained.................. Air..................... <175 12.6--0.0328H NA.
>=175 and <4,000 6.9 NA.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* H = Harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
** Water use is for the condenser only and does not include potable water used to make ice.
Table II.3--Proposed Energy Conservation Standards for Continuous Type Automatic Commercial Ice Makers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Maximum energy use kWh/100 Maximum condenser water use
Equipment type Type of cooling Harvest rate lb ice/24 hours lb ice * gal/100 lb ice **
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice-Making Head................. Water................... <900 6.08--0.0025H 160-0.0176H.
>=900 and <2,500 3.8 160-0.0176H.
>=2,500 and <4,000 3.8 116.
Ice-Making Head................. Air..................... <700 9.24--0.0061H NA.
>=700 and <4,000 5.0 NA.
Remote Condensing (but not Air..................... <850 7.5--0.0034H NA.
remote compressor).
>=850 and <4,000 4.6 NA.
Remote Condensing and Remote Air..................... <850 7.65--0.0034H NA.
Compressor.
>=850 and <4,000 4.8 NA.
Self-Contained.................. Water................... <900 7.28--0.0027H 153-0.0252H.
>=900 and <2,500 4.9 153-0.0252H.
>=2,500 and <4,000 4.9 90.
Self-Contained.................. Air..................... <700 9.2--0.0050H NA.
>=700 and <4,000 5.7 NA.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* H = Harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. 6313(d).
** Water use is for the condenser only and does not include potable water used to make ice.
[[Page 4655]]
In the March 2014 NOPR, DOE identified nineteen issues on which it
was particularly interested in receiving comments and views of
interested parties: Standards compliance dates, utilization factors,
baseline efficiency, screening analysis, maximum technology
feasibility, markups, equipment life, installation costs, open-vs
closed loop installations, ice maker shipments by type of equipment,
intermittency of manufacturer R&D and impact of standards, INPV results
and impact of standards, small businesses, consumer utility and
performance, analysis period, social cost of carbon, remote to rack
equipment, design options associated with each TSD, and standard levels
for batch type ice makers over 2,500 lb ice/hour. 79 FR 14846 at 14947-
49. After the publication of the March 2014 NOPR, DOE received written
comments on these and other issues. DOE also held a public meeting in
Washington, DC, on April 14, 2014, to discuss and receive comments
regarding the tools and methods DOE used in the NOPR analysis, as well
as the results of the analysis. DOE also invited written comments and
announced the availability of a NOPR analysis technical support
document (NOPR TSD). The NOPR TSD is available at: https://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0037-0061.
The NOPR TSD described in detail DOE's analysis of potential
standard levels for automatic commercial ice makers. The document also
described the analytical framework used in considering standard levels,
including a description of the methodology, the analytical tools, and
the relationships between the various analyses. In addition, the NOPR
TSD presented each analysis that DOE performed to evaluate automatic
commercial ice makers, including descriptions of inputs, sources,
methodologies, and results. DOE included the same analyses that were
conducted at the preliminary analysis stage, with revisions based on
comments received and additional research.
At the public meeting held on April 14, 2014, DOE presented the
methodologies and results of the analyses set for in the NOPR TSD.
Interested parties provided comments. Key issues raised by stakeholders
included: (1) Whether the energy model accurately predicts efficiency
improvements; (2) the size restrictions and applications of 22-inch
wide ice makers; (3) the efficiency distributions assumed for shipments
of icemakers; and (4) the impact on manufacturers relating to design of
icemaker models, in light of the proposed compliance date of 3 years
after publication of the final rule.
In response to comments regarding the energy model used in the
analysis, DOE held a public meeting on June 19, 2014 in order to
facilitate an additional review of the energy model, gather additional
feedback and data on the energy model, and to allow for a more thorough
explanation of DOE's use of the model in the engineering analysis. 79
FR 33877 (June 13, 2014). At that meeting, DOE presented the energy
model, demonstrated its operations, and described how it was used in
the rulemaking's engineering analysis. DOE indicated in this meeting
that it was considering modifications to its NOPR analyses based on the
NOPR comments and additional research and information gathering.
On September 11, 2014, DOE published a notice of data availability
(NODA) in the Federal Register (September 2014 NODA). 79 FR 54215. The
purpose of the September 2014 NODA was to notify industry,
manufacturers, customer groups, efficiency advocates, government
agencies, and other stakeholders of the publication of the updated
rulemaking analysis for new and/or amended energy conservation
standards for automatic ice makers. The comments received since the
publication of the March 2014 NOPR, including those received at the
April 2014 and the June 2014 public meetings, provided inputs which led
DOE to revise its analysis. Stakeholders also submitted additional
information to DOE's consultant pursuant to non-disclosure agreements
regarding efficiency gains and costs of potential design options. DOE
reviewed additional market data, including published ratings of
available ice makers, to recalibrate its engineering analysis.
Generally, the revisions to the NOPR analysis as specified in the NODA
include modifications of inputs for its engineering, LCC, and NIA
analyses, adjustments of its energy model calculations, and more
thorough considerations of size-constrained ice maker applications. The
analysis revisions addressing size-constrained applications include
development of engineering analyses for three size-constrained
equipment categories and restructuring of the LCC and NIA analyses to
consider size constraints for applicable equipment classes. DOE
encouraged stakeholders to provide comments and additional information
in response to the September NODA publication.
This final rule responds to the issues raised by commenters for the
March 2014 NOPR and the September 2014 NODA.\18\
---------------------------------------------------------------------------
\18\ A parenthetical reference at the end of a quotation or
paraphrase provides the location of the item in the public record.
---------------------------------------------------------------------------
III. General Discussion
A. Equipment Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE
divides covered equipment into equipment classes by the type of energy
use or by capacity or other performance-related features that justifies
a different standard. In making a determination whether a performance-
related feature justifies a different standard, DOE must consider such
factors as the utility to the consumer of the feature and other factors
DOE determines are appropriate. (42 U.S.C. 6295(q)) and 6316(a))
Throughout this rulemaking, DOE's analysis has been based on a set
of equipment classes derived from the existing DOE batch commercial ice
maker standards, effective as of January 1, 2010 (42 U.S.C. 6313(d)(1))
and review of the existing ice maker market. These equipment classes
form the basis of analysis and public comments. In this final rule,
equipment class names are frequently abbreviated. These abbreviations
are shown on Table III.1.
Table III.1--List of Equipment Class Abbreviations
----------------------------------------------------------------------------------------------------------------
Harvest rate lb ice/24
Abbreviation Equipment type Condenser type hours Ice type
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B............... Ice-Making Head..... Water.......... <500 Batch.
IMH-W-Med-B................. Ice-Making Head..... Water.......... >=500 and <1,436 Batch.
[[Page 4656]]
IMH-W-Large-B *............. Ice-Making Head..... Water.......... >=1,436 and <4,000 Batch.
IMH-A-Small-B............... Ice-Making Head..... Air............ <450 Batch.
IMH-A-Large-B * ** (also IMH- Ice-Making Head..... Air............ >=450 and <875 Batch.
A-Large-B-1).
IMH-A-Extended-B * ** (also Ice-Making Head..... Air............ >=875 and <4,000 Batch.
IMH-A-Large-B-2).
RCU-NRC-Small-B............. Remote Condensing, Air............ <1,000 Batch.
not Remote
Compressor.
RCU-NRC-Large-B *........... Remote Condensing, Air............ >=1,000 and <4,000 Batch.
not Remote
Compressor.
RCU-RC-Small-B.............. Remote Condensing, Air............ <934 Batch.
and Remote
Compressor.
RCU-RC-Large-B.............. Remote Condensing, Air............ >=934 and <4,000 Batch.
and Remote
Compressor.
SCU-W-Small-B............... Self-Contained Unit. Water.......... <200 Batch.
SCU-W-Large-B............... Self-Contained Unit. Water.......... >=200 and <4,000 Batch.
SCU-A-Small-B............... Self-Contained Unit. Air............ <175 Batch.
SCU-A-Large-B............... Self-Contained Unit. Air............ >=175 and <4,000 Batch.
IMH-W-Small-C............... Ice-Making Head..... Water.......... <900 Continuous.
IMH-W-Large-C............... Ice-Making Head..... Water.......... >=900 and <4,000 Continuous.
IMH-A-Small-C............... Ice-Making Head..... Air............ <700 Continuous.
IMH-A-Large-C............... Ice-Making Head..... Air............ >=700 and <4,000 Continuous.
RCU-NRC-Small-C............. Remote Condensing, Air............ <850 Continuous.
not Remote
Compressor.
RCU-NRC-Large-C............. Remote Condensing, Air............ >=850 and <4,000 Continuous.
not Remote
Compressor.
RCU-RC-Small-C.............. Remote Condensing, Air............ <850 Continuous.
and Remote
Compressor.
RCU-RC-Large-C.............. Remote Condensing, Air............ >=850 and <4,000 Continuous.
and Remote
Compressor.
SCU-W-Small-C............... Self-Contained Unit. Water.......... <900 Continuous.
SCU-W-Large-C............... Self-Contained Unit. Water.......... >=900 and <4,000 Continuous.
SCU-A-Small-C............... Self-Contained Unit. Air............ <700 Continuous.
SCU-A-Large-C............... Self-Contained Unit. Air............ >=700 and <4,000 Continuous.
----------------------------------------------------------------------------------------------------------------
* IMH-W-Large-B, IMH-A-Large-B, and RCU-NRC-Large-B were modeled in some final analyses as two different units,
one at the lower end of the harvest range and one near the high end of the harvest range in which a
significant number of units are available. In the LCC and NIA models, the low and high harvest rate models
were denoted simply as B-1 and B-2. Where appropriate, the analyses add or perform weighted averages of the
two typical sizes to present class level results.
** IMH-A-Large-B was established by EPACT-2005 as a class between 450 and 2,500 lb ice/24 hours. In this rule,
DOE analyzed this class as two ranges, which could either be considered ``Large'' and ``Very Large'' or
``Medium'' and ``Large.'' In the LCC and NIA modeling, this was denoted as B-1 and B-2.
B. Test Procedure
On December 8, 2006, DOE published a final rule in which it
incorporated by reference Air-Conditioning and Refrigeration Institute
(ARI) Standard 810-2003, ``Performance Rating of Automatic Commercial
Ice Makers,'' with a revised method for calculating energy use, as the
DOE test procedure for this equipment. 71 FR 71340. The DOE rule
included a clarification to the energy use rate equation to specify
that the energy use be calculated using the entire mass of ice produced
during the testing period, normalized to 100 lb ice produced. Id. at
71350. ARI Standard 810-2003 requires performance tests to be conducted
according to the American National Standards Institute (ANSI)/American
Society of Heating, Refrigerating, and Air-Conditioning Engineers
(ASHRAE) Standard 29-1988 (reaffirmed 2005), ``Method of Testing
Automatic Ice Makers.'' The DOE test procedure also incorporated by
reference the ANSI/ASHRAE Standard 29-1988 (Reaffirmed 2005) as the
method of test.
On January 11, 2012, DOE published a test procedure final rule
(2012 test procedure final rule) in which it adopted several amendments
to the DOE test procedure. 77 FR 1591. The 2012 test procedure final
rule included an amendment to incorporate by reference Air-
Conditioning, Heating, and Refrigeration Institute (AHRI) Standard 810-
2007 with Addendum 1 \19\ as the DOE test procedure for this equipment.
AHRI Standard 810-2007 with Addendum 1 amends ARI Standard 810-2003 to
expand the capacity range of covered equipment, provide definitions and
specific test procedures for batch and continuous type ice makers,
provide a definition for ice hardness factor, and incorporate several
new or amended definitions regarding how water consumption and capacity
are measured, particularly for continuous type machines. 77 FR at 1592-
93. The 2012 test procedure final rule also included an amendment to
incorporate by reference the updated ANSI/ASHRAE Standard 29-2009. Id.
at 1613.
---------------------------------------------------------------------------
\19\ In March 2011, AHRI published Addendum 1 to Standard 810-
2007, which revised the definition of ``potable water use rate'' and
added new definitions for ``purge or dump water'' and ``harvest
water.''
---------------------------------------------------------------------------
In addition, the 2012 test procedure final rule included several
amendments designed to address issues that were not accounted for by
the previous DOE test procedure. 77 FR at 1593 (Jan. 11, 2012). First,
DOE expanded the scope of the test procedure to include equipment with
capacities from 50 to 4,000 lb ice/24 hours.\20\ DOE also adopted
[[Page 4657]]
amendments to provide test methods for continuous type ice makers and
to standardize the measurement of energy and water use for continuous
type ice makers with respect to ice hardness. In the 2012 test
procedure final rule, DOE also clarified the test method and reporting
requirements for remote condensing automatic commercial ice makers
designed for connection to remote compressor racks. Finally, the 2012
test procedure final rule discontinued the use of the clarified energy
use rate calculation and instead required energy-use to be calculated
per 100 lb ice as specified in ANSI/ASHRAE Standard 29-2009. The 2012
test procedure final rule became effective on February 10, 2012, and
the changes set forth in the final rule became mandatory for equipment
testing starting January 7, 2013. 77 FR 1591.
---------------------------------------------------------------------------
\20\ EPCA defines automatic commercial ice maker under 42 U.S.C.
6311(19) as ``a factory-made assembly (not necessarily shipped in 1
package) that--(A) Consists of a condensing unit and ice-making
section operating as an integrated unit, with means for making and
harvesting ice; and (B) May include means for storing ice,
dispensing ice, or storing and dispensing ice.'' 42 U.S.C.
6313(d)(1) explicitly sets standards for cube type ice makers up to
2,500 lb ice/24 hours, however, 6313(d)(2) establishes authority to
set standards for other equipment types, such as those with
capacities greater than 2,500 lb ice/24 hours, provided the
equipment types meet the EPCA definition of an automatic commercial
ice maker.
---------------------------------------------------------------------------
The test procedure amendments established in the 2012 test
procedure final rule are required to be used in conjunction with new
and amended standards promulgated as a result of this standards
rulemaking. Thus, manufacturers must use the amended test procedure to
demonstrate compliance with the new and amended energy conservation
standards on the compliance date of any energy conservation standards
established as part of this rulemaking. 77 FR at 1593 (Jan. 11, 2012).
C. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a
screening analysis, which is based on information that the Department
has 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 options for improving efficiency are
technologically feasible. DOE considers a design option to be
technologically feasible if it is used by the relevant industry or if a
working prototype has been developed. Technologies incorporated in
commercially available equipment or in working prototypes were
considered technologically feasible. 10 CFR part 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), which could allow a single manufacturer to monopolize the
market.
Once DOE has determined that particular design options are
technologically feasible, DOE further 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 equipment 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) Chapter 4 of the final rule TSD discusses the results of the
screening analyses for automatic commercial ice makers. Specifically,
it presents the designs DOE considered, those it screened out, and
those that are the bases for the TSLs considered in this rulemaking.
2. Maximum Technologically Feasible Levels
When DOE adopts (or does not adopt) an amended or new energy
conservation standard for a type or class of covered equipment such as
automatic commercial ice makers, it determines the maximum improvement
in energy efficiency that is technologically feasible for such
equipment. (See 42 U.S.C. 6295(p)(1) and 6313(d)(4)) Accordingly, DOE
determined the maximum technologically feasible (``max-tech'')
improvements in energy efficiency for automatic commercial ice makers
in the engineering analysis using the design options that passed the
screening analysis.
As indicated previously, whether efficiency levels exist or can be
achieved in commonly used equipment is not relevant to whether they are
considered max-tech levels. DOE considers technologies to be
technologically feasible if they are incorporated in any currently
available equipment or working prototypes. Hence, a max-tech level
results from the combination of design options predicted to result in
the highest efficiency level possible for an equipment class, with such
design options consisting of technologies already incorporated in
automatic commercial ice makers or working prototypes. DOE notes that
it reevaluated the efficiency levels, including the max-tech levels,
when it updated its results for the NODA and final rule. See chapter 5
of the final rule TSD for the results of the analyses and a list of
technologies included in max-tech equipment. Table III.2 and Table
III.3 shows the max-tech levels determined in the engineering analysis
for batch and continuous type automatic commercial ice makers,
respectively.
Table III.2--Final Rule ``Max-Tech'' Levels for Batch Automatic
Commercial Ice Makers
------------------------------------------------------------------------
Equipment type * Energy use lower than baseline
------------------------------------------------------------------------
IMH-W-Small-B........................ 23.9%, 21.5% (22-inch wide).
IMH-W-Med-B.......................... 18.1%.
IMH-W-Large-B........................ 8.3% (at 1,500 lb ice/24 hours),
7.4% (at 2,600 lb ice/24 hours).
IMH-A-Small-B........................ 25.5%, 18.1% (22-inch wide).
IMH-A-Large-B........................ 23.4% (at 800 lb ice/24 hours),
15.8% (at 590 lb ice/24 hours,
22-inch wide), 11.8% (at 1,500
lb ice/24 hours).
RCU-Small-B.......................... Not directly analyzed.
RCU-Large-B.......................... 17.3% (at 1,500 lb ice/24 hours),
13.9% (at 2,400 lb ice/24
hours).
SCU-W-Small-B........................ Not directly analyzed.
SCU-W-Large-B........................ 29.8%.
SCU-A-Small-B........................ 32.7%.
SCU-A-Large-B........................ 29.1%.
------------------------------------------------------------------------
* IMH is ice-making head; RCU is remote condensing unit; SCU is self-
contained unit; W is water-cooled; A is air-cooled; Small refers to
the lowest harvest category; Med refers to the Medium category (water-
cooled IMH only); Large refers to the large size category; RCU units
were modeled as one with line losses used to distinguish standards.
Note: For equipment classes that were not analyzed, DOE did not develop
specific cost-efficiency curves but attributed the curve (and maximum
technology point) from one of the analyzed equipment classes.
[[Page 4658]]
Table III.3--Final Rule ``Max-Tech'' Levels for Continuous Automatic
Commercial Ice Makers
------------------------------------------------------------------------
Equipment type * Energy use lower than baseline
------------------------------------------------------------------------
IMH-W-Small-C.......................... Not directly analyzed.
IMH-W-Large-C.......................... Not directly analyzed.
IMH-A-Small-C.......................... 25.7%.
IMH-A-Large-C.......................... 23.3% lb ice.
RCU-Small-C............................ 26.6%.
RCU-Large-C............................ Not directly analyzed.
SCU-W-Small-C.......................... Not directly analyzed.
SCU-W-Large-C *........................ No units available.
SCU-A-Small-C.......................... 26.6%.
SCU-A-Large-C *........................ No units available.
------------------------------------------------------------------------
* DOE's investigation of equipment on the market revealed that there are
no existing products in either of these two equipment classes (as
defined in this final rule).
Note: For equipment classes that were not analyzed, DOE did not develop
specific cost-efficiency curves but attributed the curve (and maximum
technology point) from one of the analyzed equipment classes.
D. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from automatic
commercial ice makers purchased during a 30-year period that begins in
the year of compliance with amended standards (2018-2047). The savings
are measured over the entire lifetime of products purchased in the 30-
year period. DOE used the NIA model to estimate the national energy
savings (NES) for equipment purchased over the period 2018-2047. The
model forecasts total energy use over the analysis period for each
representative equipment class at efficiency levels set by each of the
considered TSLs. DOE then compares the energy use at each TSL to the
base-case energy use to obtain the NES. The NIA model is described in
section IV.H of this rule and in chapter 10 of the final rule TSD.
DOE used its NIA spreadsheet model to estimate energy savings from
amended standards for automatic commercial ice makers. The NIA
spreadsheet model (described in section IV.H of this preamble)
calculates energy savings in site energy, which is the energy directly
consumed by products at the locations where they are used.
Because automatic commercial ice makers use water, water savings
were quantified in the same way as energy savings.
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) AEO.
DOE also has begun to estimate full-fuel-cycle energy savings. 76
FR 51282 (August 18, 2011), as amended by 77 FR 49701 (August 17,
2012). The full-fuel-cycle (FFC) metric includes the energy consumed in
extracting, processing, and transporting primary fuels, and thus
presents a more complete picture of the impacts of energy efficiency
standards. DOE's approach is based on calculations of an FFC multiplier
for each of the fuels used by automatic commercial ice makers.
2. Significance of Savings
EPCA prohibits DOE from adopting a standard that would not result
in significant additional energy savings. (42 U.S.C. 6295(o)(3)(B) and
6313(d)(4)While the term ``significant'' is not defined in EPCA, the
U.S. Court of Appeals for the District of Columbia in Natural Resources
Defense Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985),
indicated that Congress intended significant energy savings to be
savings that were not ``genuinely trivial.'' The energy savings for all
of the TSLs considered in this rulemaking (presented in section
V.B.3.a) are nontrivial, and, therefore, DOE considers them
``significant'' within the meaning of section 325 of EPCA.
E. Economic Justification
1. Specific Criteria
As discussed in section III.E.1, EPCA provides seven factors to be
evaluated in determining whether a potential energy conservation
standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i) and
6313(d)(4) The following sections generally discuss how DOE is
addressing 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 this rule.
a. Economic Impact on Manufacturers and Commercial Customers
In determining the impacts of a potential new or amended energy
conservation standard on manufacturers, DOE first determines its
quantitative impacts using an annual cash flow approach. This includes
both a short-term assessment (based on the cost and capital
requirements associated with new or amended standards during the period
between the announcement of a regulation and the compliance date of the
regulation) and a long-term assessment (based on the costs and marginal
impacts over the 30-year analysis period). The impacts analyzed include
INPV (which values the industry based on 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
potential impacts on different types of manufacturers, paying
particular attention to impacts on small manufacturers. Third, DOE
considers the impact of new or amended standards on domestic
manufacturer employment and manufacturing capacity, as well as the
potential for new or amended standards to result in plant closures and
loss of capital investment. Finally, DOE takes into account cumulative
impacts of other DOE regulations and non-DOE regulatory requirements on
manufacturers.
For individual customers, measures of economic impact include the
changes in LCC and the PBP associated with new or amended standards.
These measures are discussed further in the following section. For
consumers in the aggregate, DOE also calculates the national net
present value of the economic impacts applicable to a particular
rulemaking.
[[Page 4659]]
DOE also evaluates the LCC impacts of potential standards on
identifiable subgroups of consumers that may be affected
disproportionately by a national standard.
b. Savings in Operating Costs Compared To Increase in Price (Life Cycle
Costs)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product compared
to any increase in the price of the covered product that are likely to
result from the imposition of the standard. (42 U.S.C.
6295(o)(2)(B)(i)(II) and 6313(d)(4) DOE conducts this comparison in its
LCC and PBP analysis.
The LCC is the sum of the purchase price of equipment (including
the cost of its installation) and the operating costs (including energy
and maintenance and repair costs) discounted over the lifetime of the
equipment. To account for uncertainty and variability in specific
inputs, such as product lifetime and discount rate, DOE uses a
distribution of values, with probabilities attached to each value. For
its analysis, DOE assumes that consumers will purchase the covered
products in the first year of compliance with amended standards.
The LCC savings and the PBP for the considered efficiency levels
are calculated relative to a base-case scenario, which reflects likely
trends in the absence of new or amended standards. DOE identifies the
percentage of consumers estimated to receive LCC savings or experience
an LCC increase, in addition to the average LCC savings associated with
a particular standard level. DOE's LCC and PBP analysis is discussed in
further detail in section IV.G.
c. Energy Savings
While significant conservation of energy is a statutory requirement
for imposing an energy conservation standard, EPCA also 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. (42 U.S.C. 6295(o)(2)(B)(i)(III) and 6313(d)(4)) DOE
uses 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 IV.H of this preamble and chapter 10 of the
final rule TSD.
d. Lessening of Utility or Performance of Equipment
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. DOE has determined that none of the
TSLs presented in today's final rule would reduce the utility or
performance of the equipment considered in the rulemaking. (42 U.S.C.
6295(o)(2)(B)(i)(IV) and 6313(d)(4)) During the screening analysis, DOE
eliminated from consideration any technology that would adversely
impact customer utility. For the results of DOE's analyses related to
the potential impact of amended standards on equipment utility and
performance, see section IV.C of this preamble and chapter 4 of the
final rule TSD.
e. Impact of Any Lessening of Competition
EPCA requires DOE to consider any lessening of competition that is
likely to result from setting new or amended standards for covered
equipment. Consistent with its obligations under EPCA, DOE sought the
views of the United States Department of Justice (DOJ). DOE asked DOJ
to provide a written determination of the impact, if any, of any
lessening of competition likely to result from the amended standards,
together with an analysis of the nature and extent of such impact. 42
U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii). DOE transmitted a copy of its
proposed rule to the Attorney General with a request that the
Department of Justice (DOJ) provide its determination on this issue.
DOJ's response, that the proposed energy conservation standards are
unlikely to have a significant adverse impact on competition, is
reprinted at the end of this rule.
f. Need of the Nation To Conserve Energy
Another factor that DOE must consider in determining whether a new
or amended standard is economically justified is the need for national
energy and water conservation. (42 U.S.C. 6295(o)(2)(B)(i)(VI) and
6313(d)(4))) The energy savings from new or amended standards are
likely to provide improvements to the security and reliability of the
Nation's energy system. Reductions in the demand for electricity may
also result in reduced costs for maintaining the reliability of the
Nation's electricity system. DOE conducts a utility impact analysis to
estimate how new or amended standards may affect the Nation's needed
power generation capacity, as discussed in section IV.M.
Amended 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 and use. DOE
conducts an emissions analysis to estimate how standards may affect
these emissions, as discussed in section IV.K. DOE reports the
emissions impacts from each TSL it considered, in section V.B.6 of this
rule. DOE also estimates the economic value of emissions reductions
resulting from the considered TSLs, as discussed in section IV.L.
g. Other Factors
EPCA allows the Secretary, in determining whether a new or amended
standard is economically justified, to consider any other factors that
the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)
and 6313(d)(4)) There were no other factors considered for this final
rule.
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii) and 6313(d)(4), EPCA
provides for a rebuttable presumption that an energy conservation
standard is economically justified if the additional cost to the
customer of equipment that meets the new or amended 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 that calculate the PBP for customers of potential new
and amended energy conservation standards. These analyses include, but
are not limited to, the 3-year PBP contemplated under the rebuttable
presumption test. However, DOE routinely conducts a full economic
analysis that considers the full range of impacts to the customer,
manufacturer, Nation, and environment, as required under 42 U.S.C.
6295(o)(2)(B)(i) and 6313(d)(4). The results of these analyses 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.G.12 of this rule and chapter 8 of the final rule TSD.
IV. Methodology and Discussion of Comments
A. General Rulemaking Issues
During the April 2014 and June 2014 public meetings, and in
subsequent written comments in response to the NOPR and NODA,
stakeholders provided input regarding general issues
[[Page 4660]]
pertinent to the rulemaking, such as issues regarding proposed standard
levels and the compliance date. These issues are discussed in this
section.
1. Proposed Standard Levels
In response to the level proposed in the NOPR (TSL 3), Manitowoc
commented that there are significant deficiencies in the models and
cost assumptions that were used to arrive at the proposed efficiency
levels and that, consequently, the selected levels are not optimal from
a life-cycle cost standpoint. (Manitowoc, Public Meeting Transcript,
No. 70 at p. 24-26) Follett commented that DOE is recommending
efficiency levels that are neither technologically nor economically
justified. (Follett, No. 84 at p. 8)
Hoshizaki and Scotsman both recommended DOE select NOPR TSL 1
(Hoshizaki, No. 86 at p. 5-6; Scotsman, Public Meeting Transcript, No.
70 Public Meeting Transcript, at p. 44-46) Scotsman stated that doing
so effective 2020 is technologically feasible, economically justified,
consistent with past regulations, and will save a significant amount of
energy. (Scotsman, Public Meeting Transcript, Public Meeting
Transcript, No. 70 at p. 44-46) Although the following comment
regarding choosing a standard level mentioned ``ELs,'' efficiency
levels, DOE believes Hoshizaki intended that this comment refer to
``TSLs,'' trial standard levels levels and DOE has interpreted the
comment accordingly. Hoshizaki stated that NOPR EL1 (interpreted as
TSL1) would garner similar savings as NOPR EL3 (interpreted as TSL3)
while reducing the burden on the industry to meet such stringent
standards in such a short amount of time. (Hoshizaki, No. 86 at p. 5-6)
Scotsman stated that they have not identified technology
combinations that are suitable for achieving any efficiency level
beyond NOPR TSL 1. (Scotsman, No. 85 at p. 8b) Scotsman added that they
do not have data indicating that their machines will be able to meet
NOPR TSL 3 using the design options under consideration. (Scotsman, No.
85 at p. 7b)
Pacific Gas and Electric Company (PG&E) and San Diego Gas and
Electric Company (SDG&E), commenting jointly, and a group including the
Appliance Standards Awareness Project (ASAP), the American Council for
an Energy-Efficient Economy (ACEEE), the Alliance to Save Energy,
Natural Resources Defense Council (NRDC), and the Northwest Power and
Conservation Council (NPCC) (Joint Commenters) both recommended that
DOE adopt a higher TSL for ACIMs. (Joint Commenters, No. 87 at p. 1-2;
PG&E and SDG&E, No. 89 at p. 1-2) ASAP noted that based on their review
of the certification database, there are products existing on the
market today that meet the proposed standard levels. (ASAP, Public
Meeting Transcript, No. 70 at p. 50-52) Joint Commenters urged DOE to
adopt TSL 5 for batch type equipment and TSL 4 for continuous type
equipment. (Joint Commenters, No. 87 at p. 1-2) PG&E and SDG&E
recommended that DOE adopt the maximum cost-effective TSL for each
equipment class noting that DOE could adopt TSLs higher than TSL 3
while maintaining a net benefit to U.S. consumers. (PG&E and SDG&E, No.
89 at p. 1-2)
Although the NODA only provided data regarding the updated analysis
and did not propose a standard level, several interested parties
provided comment regarding the appropriateness of setting the ACIM
energy conservation standard at a given NODA TSL.
In their written comment, Manitowoc stated that the NODA analysis
was an improvement over the original NOPR analysis. Manitowoc stated
that they did not believe the standard should be set at a single TSL
level for all equipment classes and suggested a different TSL level for
each equipment class. Although the following comments regarding
specific classes mention ``ELs,'' efficiency levels, DOE believes
Manitowoc intended that these comments apply to ``TSLs,'' trial
standard levels and DOE has interpreted the comment accordingly. For
IMH-A batch equipment with package widths less than 48 inches (the 48-
inch corresponds to the 1,500 lb ice/24 hour representative capacity),
Manitowoc supported an efficiency level no higher than EL 3
(interpreted as TSL3). Manitowoc suggested that DOE adopt a standard
that would be limited to 5% improvement in efficiency over baseline for
the IMH-A-B2 (48-inch wide) equipment. DOE believes Manitowoc's third
point in the comments, citing the ``IMH-small'' class refers to IMH-W-
Small-B, for which Manitowoc indicated that the standard level should
be set no higher than EL 3 (interpreted as TSL3). Manitowoc also
suggested DOE adopt standards with efficiency gains no greater than
4.7% and 3.7% efficiency gains, respectfully, for the MH-W-Large-B1
(1,500 lb ice/24 hours representative capacity) and IMH-W-Large-B2
(2,600 lb ice/24 hours representative capacity) equipment. Manitowoc
suggested that DOE adopt EL 2 (interpreted as TSL2) for the RCU-NRC-B1
(1,500 lb ice/24 hours representative capacity) and RCU-NRC-B2 (2,400
lb ice/24 hours representative capacity) equipment, as well as the SCU-
A-Small and SCU-A-Large equipment classes and for 22-inch IMH
equipment. For the RCU-NRC-Large-B1, Manitowoc indicated that the 20
percent improvement in compressor energy efficiency ratio (EER) used in
DOE's analysis for this equipment is unrealistic. For the RCU-NRC-
Large-B2, Manitowoc mentioned that the increase in condenser size
considered in the DOE analysis would present significant issues with
refrigerant charge management. For the SCU-A-Small-B class, Manitowoc
indicated that the 40% improvement in compressor EER considered in
DOE's analysis is not likely to be achieved and adding a tube row to
the condenser may not be possible. For the SCU-A-Large-B class,
Manitowoc similarly commented that the compressor EER improvement and
condenser size increases considered in DOE's analyses are unrealistic.
For the 22-inch IMH equipment, Manitowoc indicated that some of the
considered design options (increase in evaporator size and/or a drain
water heat exchanger) would not be feasible due to the compact nature
of these units. Manitowoc suggested that DOE select EL 3 (interpreted
as TSL3) for IMH-A-B small and large-1 batch equipment classes (not
including 48'' models), as well as the IMH-Small equipment class and
all other equipment classes not specifically mentioned. (Manitowoc, No.
126 at p. 1-2)
Ice-O-Matic requested that DOE select NODA TSL 3. (Ice-O-Matic, No.
121 at p. 1) Scotsman suggested that DOE select NODA TSL 2. (Scotsman,
No. 125 at p. 3) Hoshizaki suggested that DOE select NODA TSL 2 for
batch units. (Hoshizaki, No. 124 at p. 3)
ASAP encouraged DOE to adopt NODA TSL 5 for batch type remote
condensing equipment and NODA TSL 4 for all other equipment classes,
noting that these choices would be cost effective. (ASAP, No. 127 at p.
1) CA IOU suggested that DOE adopt the NODA TSL for each equipment
class that saves the most energy and has a positive NPV. CA IOU noted
that DOE could adopt a level more stringent than NODA TSL 3 for all
equipment classes while maintaining a net benefit to US consumers. (CA
IOU, No. 129 at p. 1)
DOE understands the concerns voiced by stakeholders regarding their
future ability to meet standard levels as proposed in the NOPR. DOE
must adhere to the EPCA guidelines for determining the appropriate
level of standards that were outlined in sections III.E.1. In this
Final Rule, DOE selected the TSL that best meets the EPCA
[[Page 4661]]
requirements for establishing that a standard is economically
justified. (42 U.S.C. 6295(o)(2)(B)(i) and 6313(d)(4)). Since the
publication of the NOPR, DOE has revised and updated its analysis based
on stakeholders comments received at the NOPR public meeting, comments
made during the June 19 meeting, and in written comments received in
response to the NOPR and NODA. These updates included changes in its
approach to calculating the energy use associated with groups of design
options, changes in inputs for calculations of energy use and equipment
manufacturing cost, and consideration of space-constrained
applications. After applying these changes to the analyses, the
efficiency levels that DOE determined to be cost effective changed
considerably. The NODA comments described above reveal partial industry
support for the standard levels chosen by DOE in the final rule.
DOE notes that much of the commentary regarding the selection of
efficiency levels for the standard are based on more detailed comments
regarding the feasibility of design options, the savings that these
design options can achieve, and their costs. DOE response regarding
many of these comments is provided in section IV.D.3.
2. Compliance Date
In the March 2014 NOPR analysis, DOE assumed a 3-year period for
manufacturers to prepare for compliance. DOE requested comments as to
whether a January 1, 2018 effective date provides an inadequate period
for compliance and what economic impacts would be mitigated by a later
effective date.
Following the publication of the NOPR, several manufacturers and
NAFEM expressed an expected inability to meet the proposed standard
levels within the three year compliance period. (Manitowoc, No. 92 at
p. 2-3, Scotsman, No. 85 at p. 2b, Hoshizaki, No. 86 at p. 2, NAFEM,
No. 82 at pg. 2-3) Manitowoc and Hoshizaki both commented that a 5-year
compliance period would be necessary for this rulemaking. (Manitowoc,
No. 92 at p. 2-3; Hoshizaki, No. 86 at p. 2) Scotsman commented that an
8-year compliance period would be more feasible for the technology
specification, R&D investment, performance evaluation, reliability
evaluation, and manufacturing required for product redesign. Scotsman
added that the negative economic impacts of the rule would be mitigated
by a later effective date. (Scotsman, No. 85 at p. 2b-3)
AHRI, Manitowoc, and NAFEM commented that a three year compliance
period is not adequate for this rulemaking and that DOE should extend
the compliance period to allow time for manufacturers to obtain new
components. (AHRI, Public Meeting Transcript, No. 70 at p. 18; NAFEM,
No. 82 at pg. 2-3; Manitowoc, No. 92 at p. 2 -3) NAFEM and AHRI
commented that DOE should extend the compliance period by two years.
(AHRI, No. 93 at p. 2; NAFEM, No. 82 at pg. 2-3) AHRI and Manitowoc
noted that there is a potential for Environmental Protection Agency
(EPA) Significant New Alternatives Policy (SNAP) regulations to force
further product redesign and extending the compliance period would
provide relief should refrigerant regulatory issues not be finalized in
time.\21\ (AHRI, No. 93 at p. 2; Manitowoc, No. 126 at p. 3) Emerson
urged DOE to wait until after EPA finalizes its decision on
refrigerants before starting the 3-year period given to manufacturers
to meet the new standards so manufacturers can re-design for both
energy efficiency and low global warming potential (GWP) refrigerants
in one design cycle. (Emerson, No. 122, p. 1)
---------------------------------------------------------------------------
\21\ Details regarding EPA SNAP regulations are discussed in
section IV.A.4.
---------------------------------------------------------------------------
NAFEM stated that manufacturers will only be able to achieve energy
efficiency gains up to the level of NOPR TSL 1 within the five-year
compliance timeline and that the current proposal will result in the
unavailability of ice makers with the characteristics, sizes,
capacities, and volumes that are generally available in the U.S.
(NAFEM, No. 82 at p. 2) NAFEM's comment mentions a five-year compliance
timeline, although DOE proposed a three-year timeline in the NOPR. 79
FR at 14949 (March 17, 2014).
Another concern amongst manufacturers was the belief that the
proposed standard levels were based on technology that was currently
not available. At the April 2014 NOPR public meeting, Ice-O-Matic
commented that they did not believe that the technology exists to
achieve the proposed standards in the allotted time frame. (Ice-O-
Matic, Public Meeting Transcript, No. 70 at p. 33)
Joint Commenters noted that, in balancing the stringency of the
standards with the compliance dates and manufacturer impacts, they
believe that the stringency of the standard is more important for
national energy savings than the compliance dates. (Joint Commenters,
No. 87 at p. 4)
In response to the assertion that DOE's standard levels were not
based upon currently available technologies, DOE maintains that all
technology options and equipment configurations included in its NOPR
reflect technologies currently in use in automatic commercial ice
makers. For example, DOE considered use only of compressors that are
currently commercially available and which manufacturers have indicated
are acceptable for use in ice makers in confidential discussions with
DOE's contractor. Moreover, the proposed standard levels are exceeded
by the ratings of some products that are currently commercially
available. However, the standard levels established in this final rule
are significantly less stringent than the standard levels proposed in
the NOPR, and a greater percentage of currently-available products
already meet these efficiency levels. DOE expects that this reduction
in stringency and the reduced number of products requiring redesign
means that the time required for manufacturers to achieve compliance
would be reduced.
In response to the NODA, Scotsman, Manitowoc, NAFEM, and Ice-O-
Matic all requested that the effective date for the new efficiency
standard for ACIMs be extended to 5 years after the publication of the
final rule. (Scotsman, No. 125 at p. 3; Manitowoc, No. 126 at p. 3;
NAFEM, No. 123 at p. 2; Ice-O-Matic, No. 121 at p. 1) NAFEM stated that
even with the more realistic assumptions presented in the NODA,
manufactures still require an extended timeline to obtain new
components needed to meet higher efficiency levels.
In response to the request that DOE extend the compliance date
period for automatic commercial ice makers beyond the 3 years specified
by the NOPR, DOE notes that EPCA requires that the amended standards
established in this rulemaking must apply to equipment that is
manufactured on or after 3 years after the final rule is published in
the Federal Register 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. 6313(d)(3)(C))
DOE believes that the modifications to the analysis, relative to the
NOPR, it announced in the NODA and made to the final rule will reduce
the burden on manufacturers to meet requirements established by this
rule, because the standard levels are less stringent and fewer ice
maker models will require redesign to meet the new standard. Therefore,
DOE has determined that the
[[Page 4662]]
3-year period is adequate and is not extending the compliance date for
ACIMs.
3. Negotiated Rulemaking
Stakeholders AHRI, Hoshizaki, Manitowoc, and the North American
Association of Food Equipment Manufactures (NAFEM) both suggested that
DOE use a negotiated rulemaking to develop ACIM standards. (AHRI,
Public Meeting Transcript, No. 70 at p. 15-16; AHRI, Public Meeting
Transcript, No. 128 at p. 1; Hoshizaki, Public Meeting Transcript, No.
70 at p. 38-39; Hoshizaki, Public Meeting Transcript, No. 124 at p. 3;
Manitowoc, Public Meeting Transcript, No. 70 at p. 344-345; NAFEM, No.
82 at p. 2; NAFEM, No. 123 at p. 1) NAFEM stated that a negotiated
rulemaking would ensure the level of enhanced dialogue needed for DOE
to effectively assess the rule's impact on end-users. (NAFEM, No. 82 at
p. 2) AHRI stated that there are significant issues in the analysis,
that the current direction of this rulemaking will place significant
burden on the industry, and that the completion of this rulemaking
under the current process will be difficult, expensive, and not timely.
(AHRI, Public Meeting Transcript, No. 70 at p. 15-16)
In response to the manufacturers' suggestion to use a negotiated
rulemaking to develop ACIM standards, DOE notes that this issue was
raised before the Appliance Standards and Rulemaking Federal Advisory
Committee (ASRAC) on June 6, 2014 and the ASRAC membership declined to
establish a working group to negotiate a final rule for ACIM energy
conservation standards. Several ASRAC members voiced concern of using
ASRAC at such a late stage in the rulemaking when it would be more
appropriate to raise these concerns in the normal public comment
process. (See public transcript at: https://www.regulations.gov/#!documentDetail;D=EERE-013-BT-NOC-0005-0025)
4. Refrigerant Regulation
Manitowoc noted that the EPA has proposed delisting R-404A, the
refrigerant used in nearly all currently available ice makers, for
commercial refrigeration applications. Manitowoc stated that while
commercial ice makers are not within the current scope for the SNAP
NOPR, it seems likely that ice makers could be affected by a subsequent
rulemaking. (Manitowoc, No. 126 at p. 3) Several interested parties,
including AHRI, NAFEM, Hoshizaki, Manitowoc, and Howe requested that
DOE consider the hardships associated with refrigerant choice
uncertainty caused by potential future EPA SNAP regulations in the
analysis (AHRI, Public Meeting Transcript, No. 70 at p. 16-18; NAFEM,
No. 82 at p. 7; Hoshizaki, No. 86 at p. 6-7; Howe, No. 88 at p. 2-3;
Manitowoc, Public Meeting Transcript, No. 70 at p. 286-287; Manitowoc,
No. 126 at p. 3) Manitowoc suggested that DOE do a sensitivity analysis
that examines what would happen to life-cycle costs, etc. if
manufacturers had to re-engineer twice. (Manitowoc, Public Meeting
Transcript, No. 70 at p. 286-287)
AHRI commented that the potential for SNAP rulemakings to require a
refrigerant change will necessitate major redesigns just to maintain
current efficiency levels. (AHRI, Public Meeting Transcript, No. 70 at
p. 16-18) Manitowoc and Hoshizaki also expressed concern regarding the
redesign work that would be needed if the EPA were to ban R-404A.
(Manitowoc, Public Meeting Transcript, No. 70 at p. 286-287; Hoshizaki,
No. 86 at p. 6-7) AHRI added that the burden of the potential EPA SNAP
rulemaking must be taken into account in the engineering and life-cycle
cost analyses. AHRI requested that DOE put a hold on the ACIM
rulemaking until after the next SNAP rollout is completed. (AHRI,
Public Meeting Transcript, No. 70 at p. 16-18)
AHRI also commented that the DOE should make an effort to look at
refrigerants because its cost-benefit analysis is based solely on a
refrigerant that may not exist three years from now. (AHRI, Public
Meeting Transcript, No. 70 at p. 284-285) AHRI noted that, because low-
GWP refrigerants also have lower heat transfer capability than R-404A,
coil sizes may need to further increase in order to maintain the
performance with other refrigerants, which could be infeasible if the
proposed standards are already calling for an increased coil size for
units using R-404A. (AHRI, Public Meeting Transcript, No. 70 at p. 293-
294)
Scotsman and Hoshizaki suggested that DOE and EPA collaborate so
that both the energy conservation rulemaking and the SNAP rulemaking
don't promulgate standards that are unduly burdensome. (Scotsman, No.
125 at p. 2; Hoshizaki, No. 86 at p. 6-7)
Manitowoc stated that even if the EPA takes no action on ice makers
in the next 3 years, the component supplier industry (compressors,
expansion valves, heat exchangers, etc.) will focus its efforts on
supporting the transition to hydrocarbons, HFO blends, and other
acceptable refrigerants for the refrigeration industry as the volume of
display case, reach-in, walk-in, and vending is significantly larger
than that for commercial ice machines. (Manitowoc, No. 126 at p. 3)
ASAP commented that the way that DOE is dealing with the
refrigerants issue is consistent with how it has dealt with it in all
other rulemakings. (ASAP, Public Meeting Transcript, No. 70 at p. 52-
53) Joint Commenters commented that DOE's approach of conducting their
analysis based on the most commonly-used refrigerants today is
appropriate and that it does not appear that a phase-out of R-404A
would negatively impact ice maker efficiency, given the fact that
propane, DR-33, and N-40 all have lower GWP and similar efficiency
compared to R-404A. (Joint Commenters, No. 87 at p. 4) NEEA expressed
their support for DOE's current refrigerant-neutral position. (NEEA,
No. 91 at p. 2)
In response to these comments, DOE notes that the EPA SNAP NOPR
mentioned by Manitowoc (see 79 FR 46149 (Aug. 6, 2014)) did not propose
to delist the use of R-404A for ACIMs. EPA proposed to delist R-404A
for certain retail food refrigeration applications including condensing
units. However, ACIMs do not qualify as retail food refrigeration
equipment and therefore will not be subject to SNAP regulations that
pertain to retail refrigeration applications. Further, alternate
refrigerants have not been proposed by the SNAP program for use in
ACIMs.\22\ DOE recognizes that the engineering analysis is based on the
use of R-404A, the most commonly used refrigerant in ACIMs, and that a
restriction of R-404A in ACIMs would have impacts on the design options
selected in the engineering analysis. However, DOE cannot speculate on
the outcome of a rulemaking in progress and can only consider in its
rulemakings rules that are currently in effect. Therefore, DOE has not
included possible outcomes of a potential EPA SNAP rulemaking in the
engineering or LCC analysis. This position is consistent with past DOE
rulings, such as in the 2011 direct final rule for room air
conditioners. 76 FR 22454 (April 21, 2011). DOE is aware of stakeholder
concerns that EPA may broaden the uses for which R-404A is phased out
at some point in the future. DOE is confident
[[Page 4663]]
that there will be an adequate supply of R-404A for compliance with the
standards being finalized in today's rule, however, consistent with EO
13563, Improving Regulation and Regulatory Review, DOE will prioritize
its review of the potential effects of any future phase-out of the
refrigerant R-404A (should there be one) on the efficiency standards
set by this rulemaking.
---------------------------------------------------------------------------
\22\ EPA on July 9, 2014 proposed new alternative refrigerants
for several applications, but not ACIMs. 79 FR 38811. EPA also, on
August 6, 2014, proposed delisting of refrigerants for several
applications, but not ACIMs. 79 FR 46126 (Aug. 6, 2014). The notice
did indicate that EPA is considering whether to delist use of R-404A
for ACIMs, but did not propose such action. 79 FR at 46149.
---------------------------------------------------------------------------
DOE does not have reason to believe that EPA's SNAP proposal to
delist R-404A for commercial refrigeration applications will have a
deleterious impact on the availability of components for ACIMs.
Although the component supplier industry may focus efforts on
supporting the transition to alternative refrigerants for the
commercial refrigeration industry as suggested by Manitowoc, the design
options included in this final rule are based on existing component
technology and do not assume an advancement in such components.
Therefore, DOE believes that those components currently on the market
will remain available for use by ACIM manufactures. DOE wishes to
clarify that it will continue to consider ACIM models meeting the
definition of automatic commercial ice makers to be part of their
applicable covered equipment class, regardless of the refrigerant that
the equipment uses. If a manufacturer believes that its design is
subjected to undue hardship by regulations, the manufacturer may
petition DOE's Office of Hearing and Appeals (OHA) for exception relief
or exemption from the standard pursuant to OHA's authority under
section 504 of the DOE Organization Act (42 U.S.C. 7194), as
implemented at subpart B of 10 CFR part 1003. OHA has the authority to
grant such relief on a case-by-case basis if it determines that a
manufacturer has demonstrated that meeting the standard would cause
hardship, inequity, or unfair distribution of burdens.
DOE investigated ice makers which it believes use refrigerants
other than R-404A, specifically refrigerants HFC-134a and R-410A. While
these refrigerants are also HFCs, their GWP is significantly lower than
that of R-404A,\23\ and for this reason may be less likely to be
delisted for use in ice makers under future SNAP rule revisions. Based
on the available information, DOE concludes that compliance challenges
for these alternative refrigerants are not greater than for R-404A.
Table IV.1 below presents performance data of alternative-refrigerant
ice makers and compares their energy use to the energy use associated
with TSL3 for their equipment class and capacity. Thirteen of these 31
ice makers meet the TSL3 level.
---------------------------------------------------------------------------
\23\ See https://www.epa.gov/ozone/snap/subsgwps.html.
Table IV.1--Ice Makers Using Alternative Refrigerants
--------------------------------------------------------------------------------------------------------------------------------------------------------
Harvest Energy use TSL3 Energy
Refrigerant Equipment class capacity rate Energy use percent below use (kWh/100
(lb ice/24 hr) (kWh/100 lb) baseline lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
HFC-134a....................................... SCU-A-Small-B.......................... 121 8.4 31.8 9.4
R-410A......................................... IMH-W-Small-B *........................ 302 6.1 0.6 5.2
R-410A......................................... IMH-W-Small-B.......................... 305 5.2 15.1 5.2
R-410A......................................... IMH-W-Small-B.......................... 310 5.2 14.7 5.2
R-410A......................................... IMH-W-Small-B.......................... 428 4.7 13.7 5.0
R-410A......................................... IMH-W-Small-B.......................... 430 4.7 13.5 5.0
R-410A......................................... IMH-W-Small-B.......................... 494 5 1.6 4.9
R-410A......................................... IMH-W-Med-B............................ 510 5 0.4 4.8
R-410A......................................... IMH-W-Med-B *.......................... 730 4.75 0.6 4.4
R-410A......................................... IMH-W-Med-B *.......................... 1,200 4.1 3.8 4.1
R-410A......................................... IMH-A-Small-B.......................... 222 7.5 10.2 7.3
R-410A......................................... IMH-A-Small-B.......................... 300 6.2 19.3 6.3
R-410A......................................... IMH-A-Small-B.......................... 305 6.8 11.0 6.3
R-410A......................................... IMH-A-Small-B.......................... 388 6 13.3 6.1
R-410A......................................... IMH-A-Large-B.......................... 485 6 5.6 5.8
R-410A......................................... IMH-A-Large-B.......................... 714 6.1 0.1 5.3
R-410A......................................... IMH-A-Large-B.......................... 230 7.5 9.4 6.5
R-410A......................................... IMH-A-Large-B.......................... 320 6.2 17.4 6.3
R-410A......................................... IMH-A-Large-B.......................... 310 6.8 10.5 6.3
R-410A......................................... IMH-A-Large-B.......................... 405 5.8 14.4 6.0
R-410A......................................... IMH-A-Large-B.......................... 538 6 4.7 5.7
R-410A......................................... IMH-A-Large-B.......................... 714 6.1 0.1 5.3
R-410A......................................... IMH-A-Large-B *........................ 1,100 5.3 6.7 4.9
R-410A......................................... RCU-NRC-Small-B........................ 724 5.4 11.5 5.5
R-410A......................................... RCU-NRC-Small-B........................ 720 5.4 8.8 5.5
R-410A......................................... RCU-NRC-Small-B *...................... 1,200 5 2.0 4.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Two ice makers with these ratings, one each for full-cube and half-cube ice.
5. Data Availability
AHRI, PGE/SDG&E, and NAFEM requested that DOE make data available
for stakeholder review. (AHRI, Public Meeting Transcript, No. 70 at p.
349; PG&E and SDG&E, No. 89 at p. 3; NAFEM, No. 82 at p. 2)
Specifically, AHRI requested that DOE's test results be made available
to manufacturers for review. (AHRI, Public Meeting Transcript, No. 70
at p. 349) NAFEM suggested that DOE identify the model and serial
number of components used in the engineering analysis in order to
enhance transparency. (NAFEM, No. 82 at p. 2)
AHRI and Danfoss both suggested that DOE facilitate more informal
dialog to discuss data and assumptions for the department to receive
feedback. (AHRI, Public Meeting Transcript, No. 70 at p. 342-343;
Danfoss, No. 72 at p. 1-2)
[[Page 4664]]
Danfoss recommended that DOE publish the list of all persons, companies
and organizations they have contacted in regards to this rulemaking.
(Danfoss, No. 72 at p. 1-2)
In response to stakeholders, DOE held a public meeting on June 19
to provide stakeholders with more information about the energy modeling
used in developing the NOPR analysis. 79 FR 33877 (June 13, 2014). In
addition, DOE published a NODA presenting analyses revised based on
stakeholder comments and additional research conducted after the NOPR.
79 FR 54215 (Sept. 11, 2014). DOE's contractor also engaged in
additional discussions with manufacturers under non-disclosure
agreements after publication of the NOPR in order to collect additional
information relevant to the analyses. DOE generally does not publish
test data to avoid revealing information about product performance that
may be considered trade secrets. Also for this reason, DOE does not
intend to publish the model and serial number of equipment or
components obtained, tested, and reverse-engineered during the
analysis. DOE also does not reveal the identity of companies and
organizations from which its contractor has collected information under
non-disclosure agreement.
In their written response to the NODA, AHRI expressed their belief
that DOE's current process in this rulemaking is not compliant with the
objective of using transparent and robust analytical methods producing
results that can be explained and reproduced, as required by DOE's
process rule and guidelines. AHRI expressed their belief that it has
been difficult to analyze and provide feedback on this rulemaking as
important portions such as the energy model have not been disclosed to
the public. (AHRI, No. 128 at p. 6-8)
AHRI and NAFEM requested that DOE publically release the FREEZE
model for stakeholder review. NAFEM and AHRI stated that DOE was unable
to show that the FREEZE model functioned and was unable to produce
accurate results at the June 2014 public meeting. (AHRI, No. 128 at p.
2-3; NAFEM, No. 123 at p. 1-2) AHRI stated that given the results of
the limited runs model at the June 19th meeting, they believe that
there are serious concerns about the quality and reproducibility of the
information that is not in accordance with the applicable guidelines
for ensuring and maximizing the quality, objectivity, utility and
integrity of information disseminated to the public by the Department
of Energy. AHRI added that without public release of the model, DOE
cannot demonstrate sufficient transparency about the data and methods
such that an independent reanalysis can be undertaken by a qualified
member of the public. AHRI noted that if DOE had compelling interests
that prohibit public access to the model, DOE must identify those
interests and describe and document the rigorous checks it has
undertaken to ensure reproducibility. (AHRI, No. 128 at p. 6-8)
DOE notes that stakeholders have placed great emphasis on the
FREEZE model in their responses, but this model is only part of the
analysis. Moreover, DOE has published output of the engineering
analysis on which stakeholders have had the opportunity to comment, for
both the NOPR and NODA phases. As part of the final rule documentation,
DOE presents the revised engineering analysis output.
Over the course of the rulemaking, DOE has attained additional
information regarding the efficiency improvements associated with
different design options, through public comments as well as through
confidential information exchange between DOE's contractor and
manufacturers. As a result the efforts made by all parties in preparing
and providing this additional information, the projections of
efficiency improvements associated with the design options considered
in the analysis are based more on test data than theoretical analysis.
For example, in the NODA and final rule analysis, the energy use
reduction in a batch ice maker as a result of compressor EER
improvement is based on test data provided both in written comments and
through confidential information exchange.
In the NOPR and the NODA phases, DOE has published engineering
spreadsheets that show projected energy savings associated with
specific design options for the analyses of energy use for the ice
maker models representing most of the ice maker equipment classes.
These results document the analysis and have allowed stakeholders to
review details of the analysis as a check on accuracy. DOE's
calibration of the energy use analysis results at the highest
commercially-available efficiency levels, described in section
IV.D.4.b, provides a check of the analysis, specifically ensuring that
the group of design options required to attain these highest available
efficiency levels (as predicted by the analysis) is consistent with
actual equipment. The section presents examples of maximum available
commercial units against which the energy use calculations are
calibrated for the highest analyzed efficiency levels not using
permanent magnet motors and drain water heat exchangers. DOE conducted
calibration at this efficiency level because these design options are
not generally used in commercially available units, thus preventing
calibration with commercialized units at higher efficiency levels.
These calibration comparisons, which are discussed in section IV.D.4.b
and in Chapter 5 of the TSD, show (a) that the efficiency levels
attainable without use of permanent magnet motors and drain water heat
exchangers have not been overestimated by the analysis, and (b) the
design options that are projected to be required to attain these
maximum available efficiency levels are consistent with or conservative
(more costly) as compared with the design options used in maximum-
available ice makers that are available for purchase.
DOE is not at liberty to release the FREEZE energy model to the
public because it does not own the modeling tool.
AHRI stated that DOE did not publically provide the information
necessary for affected parties to have adequate notice and ability to
comment on the results of the public meeting. AHRI stated that DOE
failed to publically state a timeframe for collecting the data it has
requested. AHRI added that the public statement issued after the public
meeting did not indicate to whom the data should be sent. AHRI stated
their belief that without the clarity of a defined comment period, or
the knowledge of the next steps in the process DOE is not following its
own process rule and the notice and comment requirements for federal
agency rulemaking. (AHRI, No. 128 at p. 6-8)
In response to AHRI's comment, DOE expressed willingness during the
NOPR public meeting, subject to potential legal restrictions, to allow
additional information exchange by stakeholders with DOE's contractor
under non-disclosure agreement. DOE also expressed willingness to
possibly publish a NODA which would allow stakeholders additional
opportunity to comment. (DOE, NOPR Public Meeting Transcript, No. 70 at
pp. 341-344) In general, any information exchange regarding a
rulemaking is strictly limited after publication of a NOPR, in order to
limit the potential for undue influence on the process from any
particular interested party. DOE allowed additional information
exchange with stakeholders and published a NODA to allow additional
opportunity for input. 79 FR 54215 (Sept. 11, 2014). Thus, contrary to
AHRI's comment, with the
[[Page 4665]]
additional public meeting and with the issuance of the NODA,
stakeholders have had several opportunities to provide input beyond the
opportunities normally provided for an energy conservation standard
rulemaking.
6. Supplemental Notice of Proposed Rulemaking
NAFEM stated that DOE should not issue a final rule because the
revisions in the NODA did not address each issue raised in response to
the NOPR analysis. (NAFEM, No. 123 at p. 1) NAFEM and AHRI both
requested that the department issue a supplemental notice of proposed
rulemaking (SNOPR) to allow manufacturers and end users enough time to
address the substantial changes in the analysis made between the NOPR
and NODA phases. (NAFEM, No. 123 at p. 1; AHRI, No. 128 at p. 2) NAFEM
stated that there are many unknowns regarding the changes made in the
NODA analysis and noted that DOE did not identify a technologically
feasible and economically justified standard level. NAFEM also
requested that DOE release the model used to determine TSL standards.
(NAFEM, No. 123 at p. 1)
In response to AHRI and NAFEM, DOE notes that the modifications
made to the analyses in the NODA were based on stakeholder
participation, and each issue raised in response to the NOPR and NODA
have been addressed in this final rule. The objective of the NODA was
to enable stakeholders to understand the changes made in the basic
analyses as a result of input received during the NOPR phase, and DOE
believes that was accomplished. Therefore, DOE does not believe that an
SNOPR is necessary for this rulemaking. In response to NAFEM's request
for DOE to release the model used to determine the TSL standard, DOE
assumes that this refers to the FREEZE model, which is discussed in
section IV.A.5. DOE is not at liberty to release the FREEZE energy
model to the public because it does not own the modeling tool.
Regarding NAFEM's comment concerning identification of a
technologically feasible and economically justified standard level, DOE
notes that the NODA did not propose a standard level. Rather the NODA's
purpose was to provide stakeholders the opportunity to comment on
revisions in DOE's analysis.
7. Rulemaking Structure Comments
A Policy Analyst at the George Washington University Regulatory
Studies Center commented on basic underpinnings of the DOE energy
conservation standards rulemaking process. Policy Analyst commented
that DOE does not explain why sophisticated, profit-motivated
purchasers of ACIMs would suffer from informational deficits or
cognitive biases that would cause them to purchase products with high
lifetime costs without demanding higher-price, higher-efficiency
products. (Policy Analyst, No. 75 at p. 5)
Policy Analyst indicated that two of the three problems identified
by DOE, lack of access to information and information asymmetry, are
not addressed by the rule, indicating that DOE's rule is flawed.
(Policy Analyst, No. 75 at p. 6) Policy Analyst added that only one of
the problems identified by DOE is addressed by any of the metrics
stated in the proposed rule: Internalizing the externality of
greenhouse gas emissions. (Policy Analyst, No. 75 at p. 7)
Policy Analyst suggested that the proposed rule should include
DOE's plans for how it will gather information to assess the success of
the rule and whether its assumptions were accurate. (Policy Analyst,
No. 75 at p. 8) Policy Analyst added that DOE should include a
timeframe for retrospective review in its final rule. (Policy Analyst,
No. 75 at p. 8)
Policy Analyst stated that DOE should pay attention to the linkages
between the rule and the measured outcomes in order to increase its
awareness of mediating factors that may have accomplished or undermined
the stated metrics absent the rule. (Policy Analyst, No. 75 at p. 8)
In response, DOE believes there are two main reasons that
purchasers of ACIM equipment would lack complete information, causing
them to, in Policy Analyst's words, ``purchase products with high
lifetime costs without demanding higher-price, higher-efficiency
products.'' The first reason is the time involved in collection and
processing of information and the second is that the available
information is incomplete. ACIM purchasers have access only to
information that is readily available, and would not have ready access
to information about additional efficiency options that could be made
available to the market. The information that is available is dispersed
in many sources, and the cost of querying all information sources takes
the form of time taken away from the primary business of the purchaser,
whether running a hotel or provision of medical care. By virtue of
simply undertaking the energy conservation standard rulemaking, DOE
provides significant information to all who are interested via the
analyses undertaken by the rulemaking.
As the energy conservation standard rulemaking has proceeded from
the initial framework phase through to the final rule phase, DOE has
solicited information, purchased, examined and tested actual ACIM
products, and performed numerous analyses to ensure assumptions are as
accurate as possible. Once a rule is finalized, DOE continues
collecting information as well as interacting with the industry, and
such activities will enable DOE to measure whether the rule is
achieving its intended results--namely increasing the efficiency of
automatic commercial ice makers.
DOE will undertake subsequent analyses of ACIM equipment in order
to meet legislative requirements for reviewing the standard by a date
no later than 5 years after the effective date of new and amended
standards established by this rulemaking. DOE follows a standard
process in energy conservation standards rulemakings, and believes as
such, that establishing plans within this final rule for gathering
information for the next proceeding is unnecessary.
B. Market and Technology Assessment
When beginning an energy conservation standards rulemaking, DOE
develops information that provides an overall picture of the market for
the equipment concerned, including the purpose of the equipment, 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, 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 equipment sold and offered for sale; (2) retail
market trends; (3) equipment 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 equipment
under examination. DOE researched manufacturers of automatic commercial
ice makers and made a particular effort to identify and characterize
small business manufacturers. See chapter 3 of the final rule TSD for
further discussion of the market and technology assessment.
[[Page 4666]]
1. Equipment Classes
In evaluating and establishing energy conservation standards, DOE
generally divides covered equipment into classes by the type of energy
used, or by capacity or other performance-related feature that
justifies a different standard for equipment having such a feature. (42
U.S.C. 6295(q) and 6316(a)) In deciding whether a feature justifies a
different standard, DOE considers factors such as the utility of the
feature to users. DOE normally establishes different energy
conservation standards for different equipment classes based on these
criteria.
Automatic commercial ice makers are divided into equipment classes
based on physical characteristics that affect commercial application,
equipment utility, and equipment efficiency. These equipment classes
are based on the following criteria:
Ice-making process
[cir] ``Batch'' icemakers that operate on a cyclical basis,
alternating between periods of ice production and ice harvesting
[cir] ``Continuous'' icemakers that can produce and harvest ice
simultaneously
Equipment configuration
[cir] Ice-making head (a single-package ice-making assembly that
does not include an ice storage bin)
[cir] Remote condensing (an ice maker consisting of an ice-making
head in which the ice is produced--but also without an ice storage
bin--and a separate condenser assembly that can be remotely installed,)
With remote compressor (compressor packaged with the
condenser)
Without remote compressor (compressor packaged with the
evaporator in the ice-making head)
[cir] Self-contained (with storage bin included)
Condenser cooling
[cir] Air-cooled
[cir] Water-cooled
Capacity range
Table IV.2 shows the 25 automatic commercial ice maker equipment
classes that DOE used for its analysis in this rulemaking. These
equipment classes were derived from existing DOE standards and
commercially available products. The final rule adjusts these capacity
ranges, based on this analysis, as a result of setting appropriate
energy use standards across the overall capacity range (50 to 4,000 lb
ice/24 hours) for a given type of equipment, such as all batch air-
cooled ice-making head units.
Table IV.2--Final Rule Automatic Commercial Ice Maker Equipment Classes Used for Analysis
----------------------------------------------------------------------------------------------------------------
Type of condenser Harvest capacity rate lb ice/24
Type of ice maker Equipment type cooling hours
----------------------------------------------------------------------------------------------------------------
Batch........................... Ice-Making Head......... Water.............. >=50 and <500
>=500 and <1,436
>=1,436 and <4,000
Air................ >=50 and <450
>=450 and <4,000
Remote Condensing (but Air................ >=50 and <1,000
not remote compressor). >=1,000 and <4,000
Remote Condensing and Air................ >=50 and <934
Remote Compressor. >=934 and <4,000
Self-Contained Unit..... Water.............. >=50 and <200
>=200 and <4,000
Air................ >=50 and <175
>=175 and <4,000
Continuous...................... Ice-Making Head......... Water.............. >=50 and <900
>=900 and <4,000
Air................ >=50 and <700
>=700 and <4,000
Remote Condensing (but Air................ >=50 and <850
not remote compressor). >=850 and <4,000
Remote Condensing and Air................ >=50 and <850
Remote Compressor. >=850 and <4,000
Self-Contained Unit..... Water.............. >=50 and <900
>=900 and <4,000
Air................ >=50 and <700
>=700 and <4,000
----------------------------------------------------------------------------------------------------------------
Batch type and continuous type ice makers are distinguished by the
mechanics of their respective ice-making processes. Continuous type ice
makers are so named because they simultaneously produce and harvest ice
in one continuous, steady-state process. The ice produced in continuous
processes is called ``flake'' ice or ``nugget'' ice, which can both be
a ``soft'' ice with high liquid water content, in the range from 10 to
35 percent, but can also be subcooled, i.e. be entirely frozen and at
temperature lower than 32[emsp14][deg]F. Continuous type ice makers
were not included in the EPACT 2005 standards and therefore were not
regulated by existing DOE energy conservation standards.
Existing energy conservation standards cover batch type ice makers
that produce ``cube'' ice, which is defined as ice that is fairly
uniform, hard, solid, usually clear, and generally weighs less than two
ounces (60 grams) per piece, as distinguished from flake, crushed, or
fragmented ice. 10 CFR 431.132 Batch ice makers alternate between
freezing and harvesting periods and therefore produce ice in discrete
batches rather than in a continuous process. After the freeze period,
hot gas is typically redirected from the compressor discharge to the
evaporator, melting the surface of the ice cubes that is in contact
with the evaporator surface, enabling them to be removed from the
evaporator. The water that is left in the sump at the end of the
icemaking part of the cycle is purged (drained from the unit), removing
with it the impurities that could decrease ice clarity form scale (the
result of dissolved solids in the incoming water coming out of
solution) on the ice maker
[[Page 4667]]
surfaces. Consequently, batch type ice makers typically have higher
potable water usage than continuous type ice makers.
After the publication of the Framework document, several parties
commented that machines producing ``tube'' ice, which is created in a
batch process with both freeze and harvest periods similar to the
process used for cube ice, should also be regulated. DOE notes that
tube ice machines of the covered capacity range that produce ice
fitting the definition for cube type ice are covered by the current
standards, whether or not they are referred to as cube type ice makers
within the industry. Nonetheless, DOE has addressed the commenters'
suggestions by emphasizing that all batch type ice machines are within
the scope of this rulemaking, as long as they fall within the covered
capacity range of 50 to 4,000 lb ice/24 hours. This includes tube ice
machines and other batch type ice machines (if any) that produce ice
that does not fit the definition of cube type ice. To help clarify this
issue, DOE now refers to all batch automatic commercial ice makers as
``batch type ice makers,'' regardless of the shape of the ice pieces
that they produce. 77 FR 1591 (Jan. 11, 2012).
During the April 2014 NOPR public meeting and in subsequent written
comments, a number of stakeholders addressed issues related to proposed
equipment classes and the inclusion of certain types of equipment in
the analysis. These topics are discussed in this section.
a. Cabinet Size
In the March 2014 NOPR, DOE indicated that it was not proposing to
create separate equipment classes for space-constrained units. DOE
requested comment on this issue in the preliminary analysis phase. Few
stakeholders commented on whether DOE should consider establishing
equipment classes based on cabinet size. Earthjustice supported such an
approach, while Manitowoc suggested that such an approach would be
complicated. (Earthjustice, Preliminary Analysis Public Meeting
Transcript, No. 42 at pp. 90-91; Manitowoc, (Manitowoc, Preliminary
Analysis Public Meeting Transcript, No. 42 at p. 91)) DOE also reviewed
size/efficiency trends of commercially available ice makers and
concluded that the data do not show a definitive trend suggesting
specific size limits for space-constrained classes. 79 FR 14846, at
14862 (March 17, 2014).
In response to the March 2014 NOPR, AHRI and NAFEM commented that
DOE did not conduct analysis for the full range of product offerings in
the market. (AHRI, No. 93 at p. 12-13; NAFEM, No. 82 at p. 4) AHRI,
NAFEM, and Manitowoc commented that DOE's analysis did not take into
account the difficulty associated with increasing cabinet volume for
22-inch models (i.e. ice makers that are 22 inches wide). (AHRI, No. 93
at p. 12-13; Manitowoc, No. 92 at p. 2; NAFEM, No. 82 at p. 4)
Manitowoc added that the engineering analysis focused on 30-inch
cabinets and that the design options may not all fit within the 22-inch
cabinet models. (Manitowoc, No. 92 at p. 2 and p. 26-27) AHRI stated
that they had data showing that 22-inch units cannot accommodate
evaporator or condenser growth without chassis growth which is not
possible for these size-restricted units. AHRI noted that DOE included
chassis size increases for some equipment classes without taking into
account in the engineering analysis the special case of 22-inch ice
makers. (AHRI, No. 93 at p. 12-13) NAFEM specifically requested that
DOE differentiate between 22-inch and 30-inch IMH-A-Small-B machines,
since 22-inch models cannot achieve increases in cabinet volume and 30-
inch models cannot be substituted for 22-inch models. (NAFEM, No. 82 at
p. 4) Hoshizaki also urged DOE to take 22-inch units into special
consideration in the analysis. (Hoshizaki, No. 86 at p. 8)
Manitowoc commented that 22-inch air-cooled ice-making heads are
growing in importance due to the shrinking size of restaurant kitchens
and that such machines cannot grow in height because they are already
very tall. Manitowoc asserted that this product category may disappear
if efficiency standards require significant chassis size growth.
(Manitowoc, Public Meeting Transcript, No. 70 at p. 162-164)
However, the Northwest Energy Efficiency Alliance (NEEA) stated
that they believe that DOE appropriately considered the issues
concerning increased chassis size, citing DOE's consideration of
chassis size increase only for three of the twenty-two classes
analyzed, and the fact that DOE considered only increases in height,
not increases in footprint. (NEEA, No. 91 at p. 1-2)
DOE has maintained its position from the NOPR and has not created a
new equipment class for 22-inch ACIMs. However, in response to
commenters DOE revised the NOPR analysis to consider the size
restrictions and applications of 22-inch wide ice makers in its revised
analysis. Specifically, DOE has developed cost-efficiency curves for
22-inch width units in the IMH-A-Small-B, IMH-A-Large-B, and IMH-W-
Small-B equipment classes. These curves were used in the LCC and NIA
analyses in the evaluation of efficiency levels for classes for which
22-inch ACIMs are an important category. The LCC and NIA analyses were
also revised to more carefully consider the impact of size restrictions
in applications for 30-inch units--this is discussed in greater detail
in section IV.G.2. Ultimately these revisions in the analyses led to
selection of less stringent efficiency levels for some of the affected
classes.
b. Large-Capacity Batch Ice Makers
In the November 2010 Framework document for this rulemaking, DOE
requested comments on whether coverage should be expanded from the
current covered capacity range of 50 to 2,500 lb ice/24 hours to
include ice makers producing up to 10,000 lb ice/24 hours. All
commenters agreed with expanding the harvest capacity coverage, and all
but one of the commenters supported or accepted an upper harvest
capacity cap of 4,000 lb ice/24 hours, which would be consistent with
the current test procedure, AHRI Standard 810-2007. Most commenters
categorized ice makers with harvest capacities above 4,000 lb ice/24
hours as industrial rather than commercial. Since the publication of
the framework analysis, DOE revised the test procedure, with the final
rule published in January 2012, to include all batch and continuous
type ice makers with capacities between 50 and 4,000 lb ice/24 hours.
77 FR 1591, 1613-14. In the 2012 test procedure final rule, DOE noted
that 4,000 lb ice/24 hours represented a reasonable limit for
commercial ice makers, as larger-sized ice makers were generally used
for industrial applications and testing machines up to 4,000 lb was
consistent with AHRI 810-2007. 77 FR 1591 (Jan. 11, 2012). To be
consistent with the majority of the framework comments, during the
preliminary analysis DOE discussed setting the upper harvest capacity
limit to 4,000 lb ice/24 hours, even though there are few ice makers
currently produced with capacities ranging from 2,500 to 4,000 lb ice/
24 hours. 77 FR 3404 (Jan. 24, 2012) DOE proposed in the March 2014
NOPR to set efficiency standards that include all ice makers in this
extended capacity range and has maintained this position in this final
rule.
PG&E and SDG&E commented that they support the inclusion of
previously unregulated equipment classes into the scope of this
rulemaking, including equipment with a capacity range up to 4,000 lb/24
hour. (PG&E and SDG&E,
[[Page 4668]]
No. 89 at p. 1) However, Hoshizaki, NAFEM, and AHRI commented that DOE
should refrain from regulating products with capacities above 2,500 lb
ice/24 hours, if there are not enough models in this category for DOE
to directly evaluate. (Hoshizaki, No. 86 at p. 9; Hoshizaki, No. 124 at
p. 2; AHRI, No. 93 at p. 16; NAFEM, No. 123 at p. 2) Hoshizaki
commented that large units perform differently than small units in the
ways that their compressors and condensers interact. Hoshizaki
requested that DOE not add higher levels to the standard extended
beyond 2,000 lb ice/24 hours, but have a flat level no more stringent
than the standard at 2,000 lb ice/24 hours for higher capacity
equipment. (Hoshizaki, No. 124 at p. 2)
DOE acknowledges that there are currently few automatic commercial
ice makers with harvest capacities above 2,500 lb ice/24 hours.
However, AHRI has extended the applicability of its test standard, AHRI
Standard 810-2007 with Addendum 1, ``Performance Rating of Automatic
Commercial Ice Makers,'' to ice makers up to 4,000 lb ice/24 hours.
Likewise, DOE extended the applicability of its test procedure to the
same range. 77 FR 1591 (January 11, 2012). Stakeholders have not cited
reasons that ice makers with capacities greater than 2,000 lb ice/24
hours would not be able to achieve the same efficiency levels as those
producing 2,000 lb ice/24 hours. Because it is possible that batch-type
ice makers with harvest capacities from 2,500 to 4,000 lb ice/24 hours
will be manufactured in the future, DOE does not find it unreasonable
to set standards in this rulemaking for batch type ice makers with
harvest capacities in the range up to 4,000 lb ice/24 hours. Therefore,
DOE maintains its position to include large-capacity batch type ice
makers in the scope of this rulemaking. In response to Hoshizaki's
comment, DOE notes that each product class has flat levels, i.e.
efficiency levels that do not vary with harvest capacity, beyond 2,000
lb ice/24 hours.
c. Regulation of Potable Water Use
Under EPACT 2005, water used for ice--referred to as potable
water--was not regulated for automatic commercial ice makers.
The amount of potable water used varies significantly among batch
type automatic commercial ice makers (i.e., cube, tube, or cracked ice
machines). Continuous type ice makers (i.e., flake and nugget machines)
convert essentially all of the potable water to ice, using roughly 12
gallons of water to make 100 lb ice. Batch type ice makers use an
additional 3 to 38 gallons of water in the process of making 100 lb
ice. This additional water is referred to as ``dump or purge water''
and is used to cleanse the evaporator of impurities that could
interfere with the ice-making process.
As indicated in the preliminary analysis and NOPR, DOE is not
setting potable water limits for automatic commercial ice makers.
The Natural Resource Defense Council (NRDC) commented that they
previously urged the Department to propose standards for potable water
use in batch type ice makers and that failure to do so is short-
sighted, given the increasing severity of drought conditions in many
states, and may cause states to consider their own water use standards
for ice makers. (NRDC, No. 90 at p. 54-1) NRDC urged DOE to reconsider
its decision not to evaluate and set standards for potable water use.
NRDC noted that EPCA was amended in 1992 explicitly to include water
conservation as one of its purposes. (NRDC, No. 90 at p. 1)
PG&E and SDG&E also recommended that DOE establish a maximum
potable water use requirement. PG&E and SDG&E also added that in the
event that DOE maintains that there is ambiguity in EPACT 2005 on
whether DOE is required to regulate water usage and uses its discretion
not to mandate a potable water standard PG&E and SDG&E request that DOE
comment whether states are preempted from establishing such a standard.
(PG&E and SDG&E, No. 89 at p. 4)
In response to comments from NRDC, and PG&E and SDG&E, DOE was not
given a specific mandate by Congress to regulate potable water. EPCA,
as amended, explicitly gives DOE the authority to regulate water use in
showerheads, faucets, water closets, and urinals (42 U.S.C. 6291(6),
6295(j) and (k)), clothes washers (42 U.S.C. 6295(g)(9)), dishwashers
(42 U.S.C. 6295(g)(10)), commercial clothes washers (42 U.S.C.
6313(e)), and batch (cube) commercial ice makers. (42 U.S.C. 6313(d))
With respect to batch commercial ice makers (cube type machines),
however, Congress explicitly set standards in EPACT 2005 at 42 U.S.C.
6313(d)(1) only for condenser water and noted in a footnote to the
table setting the standards that potable water use was not
included.\24\ Congress thereby recognized both types of water, and did
not provide direction to DOE with respect to potable water standards.
This ambiguity gives the DOE considerable discretion to regulate or not
regulate potable water. The U.S. Supreme Court has determined that,
when legislative intent is ambiguous, a government agency may use its
discretion in interpreting the meaning of a statute, so long as the
interpretation is reasonable.\25\ In the case of ice makers, EPACT 2005
is ambiguous on the subject of whether DOE must regulate water usage
for purposes other than condenser water usage in cube-making machines,
and DOE has chosen to use its discretion not to mandate a standard in
this case. Pursuant to 42 U.S.C. 6297(b) and (c), preemption applies
with respect to covered products and no State regulation concerning
energy efficiency, energy use, or water use of such covered product
shall be effective with respect to such product unless the State
regulation meets the specified criteria under these provisions.
---------------------------------------------------------------------------
\24\ Footnote to table at 42 U.S.C. 6313(d)(1).
\25\ Nat'l Cable & Telecomms. Ass'n v. Brand X Internet Servs.,
545 U.S. 967, 986 (2005) (quoting Chevron U.S.A. Inc. v. Natural
Res. Def. Council, Inc., 467 U.S. 837, 845 (1984)).
---------------------------------------------------------------------------
DOE elected to not set potable water limits for automatic
commercial ice makers in order to allow manufacturers to retain
flexibility in this aspect of ice maker design. The regulation of ice
maker energy use does in itself make high levels of potable water use
untenable because energy use does increase as potable water use
increases, since the additional water must be cooled down, diverting
refrigeration capacity from the primary objective of cooling and
freezing the water that will be delivered from the machine as ice.
DOE notes that ENERGY STAR has adopted potable water limits for
ENERGY STAR-compliant ice makers at 15 gal/100 lb ice for continuous
equipment classes, 20 gal/100 lb ice for IMH and RCU batch classes, and
25 gal/100 lb ice for SCU batch classes.\26\
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\26\ https://www.energystar.gov/index.cfm?c=comm_ice_machines.pr_crit_comm_ice_machines.
---------------------------------------------------------------------------
d. Regulation of Condenser Water Use
As previously noted in section II.B.1, EPACT 2005 prescribes
maximum condenser water use levels for water-cooled cube type automatic
commercial ice makers. (42 U.S.C. 6313(d)) \27\ For units not currently
covered by the standard (continuous machines of all harvest rates and
batch machines with harvest rates exceeding 2,500 lb ice/24 hours),
there currently are no limits on condenser water use.
---------------------------------------------------------------------------
\27\ The table in 42 U.S.C. 6313(d)(1) states maximum energy and
condenser water usage limits for cube type ice machines producing
between 50 and 2,500 lb of ice per 24 hour period (lb ice/24 hours).
A footnote to the table states explicitly the water limits are for
water used in the condenser and not potable water used to make ice.
---------------------------------------------------------------------------
[[Page 4669]]
In the preliminary analysis and the NOPR, DOE indicated its intent
to primarily focus the automatic commercial ice maker rulemaking on
energy use. DOE also noted that DOE is not bound by EPCA to
comprehensively evaluate and propose reductions in the maximum
condenser water consumption levels, and likewise has the option to
allow increases in condenser water use, if this is a cost-effective way
to improve energy efficiency.
In the preliminary analysis, DOE stated that EPCA's
anti[hyphen]backsliding provision in section 325(o)(1), which lists
specific products for which DOE is forbidden from prescribing amended
standards that increase the maximum allowable water use, does not
include ice makers. However in response to the preliminary analysis,
Earthjustice asserted that DOE lacks the authority to relax condenser
water limits for water-cooled ice makers. Earthjustice argued that the
failure of section 325(o)(1) to specifically call out ice maker
condenser water use as a metric that is subject to the statute's
prohibition against the relaxation of a standard is not determinative.
On the contrary, Earthjustice maintained that the plain language of
EPCA shows that Congress intended to apply the anti[hyphen]backsliding
provision to ice makers. Earthjustice commented that section 342(d)(4)
requires DOE to adopt standards for ice[hyphen]makers ``at the maximum
level that is technically (DOE interprets the comment to mean
technologically) feasible and economically justified, as provided in
[section 325(o) and (p)].'' (42 U.S.C. 6313(d)(4)) Earthjustice stated
that, by referencing all of section 325(o), the statute pulls in each
of the distinct provisions of that subsection, including, among other
things, the anti[hyphen]backsliding provision, the statutory factors
governing economic justification, and the prohibition on adopting a
standard that eliminates certain performance characteristics. By
applying all of section 325(o) to ice[hyphen]makers, section 342(d)(4)
had already made the anti[hyphen]backsliding provision applicable to
condenser water use, according to Earthjustice. Finally, Earthjustice
stated that even if DOE concludes that the plain language of EPCA is
not clear on this point, the only reasonable interpretation is that
Congress did not intend to grant DOE the authority to relax the
condenser water use standards for ice makers. Earthjustice added that
the anti-backsliding provision is one of EPCA's most powerful tools to
improve the energy and water efficiency of appliances and commercial
equipment, and Congress would presumably speak clearly if it intended
to withhold its application to a specific product. (Earthjustice, No.
47 at pp. 4-5)
In the NOPR DOE maintained that the 42 U.S.C. Sec. 6295(o)(1) anti-
backsliding provisions apply to water in only a limited set of
residential appliances and fixtures. Therefore, an increase in
condenser water use would not be considered backsliding under the
statute. Nevertheless, the DOE did not include increases in condenser
water use as a technology option for the NOPR, NODA, and final rule.
In response to the NOPR, NRDC stated that they disagree that DOE
may lawfully relax water use standards. NRDC added that even if DOE
were correct in stating that EPCA's anti-backsliding provision does not
apply, as explored in EarthJustice's comment, DOE cannot relax the
water efficiency levels set by Congress itself. (NRDC, No. 90 at p. 1)
In this rule, DOE is not revising its NOPR position regarding the
application of anti-backsliding to ACIM condenser water use.
Nevertheless, DOE did not consider design options that would represent
increase in condenser water use in its final rule analysis.
e. Continuous Models
The EPACT 2005 amendments to EPCA did not set standards for
continuous type ice makers. Pursuant to EPCA, DOE is required to set
new or amended energy conservation standards for automatic commercial
ice makers to: (1) Achieve the maximum improvement in energy efficiency
that is technologically feasible and economically justified; and (2)
result in significant conservation of energy. (42 U.S.C. 6295(o)(2)(A)
and (o)(3)(B); 6313(d)(4))
Hoshizaki stated that due to their small market share, continuous
models should be considered separately from batch machines. (Hoshizaki,
No, 124 at p. 1)
DOE notes that it has conducted analysis for continuous models as
part of separate equipment classes than batch type models and has set
different energy standards for them.
f. Gourmet Ice Machines
AHRI stated that this rulemaking has ignored the niche market of
gourmet ice cubes. AHRI stated that gourmet ice cubes are two to three
times larger than standard ice cubes. They are also harder and denser
than conventional machine-made ice and require more energy to produce.
AHRI noted that this issue impacts small business manufacturers. (AHRI,
No. 128 at p. 5)
In response to AHRI's comment regarding gourmet ice makers, DOE has
not conducted separate analysis for such equipment. DOE has, however,
considered small business impacts, as discussed in section IV.J.3.f.
DOE notes that the ACIM rulemaking has provided stakeholders many
opportunities to provide comment on the issues that would be important
to consider in the analysis, including potential equipment classes
associated with different types of ice, whether different types of ice
provide specific utility that would be the basis of considering
separate equipment classes, and any other issues associated with such
ice that might affect the analysis. DOE does not have nor did it
receive in response to requests for comments sufficient specific
information to evaluate whether larger ice has specific consumer
utility, nor to allow separate evaluation for such equipment of costs
and benefits associated with achieving the efficiency levels considered
in the rulemaking. In the absence of information, DOE cannot conclude
that this type of ice has unique consumer utility justifying
consideration of separate equipment classes. DOE notes that
manufacturers of this equipment have the option seeking exception
relief pursuant to 41 U.S.C. 7194 from DOE's Office of Hearings and
Appeals.
2. Technology Assessment
As part of the market and technology assessment, DOE developed a
comprehensive list of technologies to improve the energy efficiency of
automatic commercial ice makers, shown in Table IV.3. Chapter 3 of the
final rule TSD contains a detailed description of each technology that
DOE identified. DOE only considered in its analysis technologies that
would impact the efficiency rating of equipment as tested under the DOE
test procedure. The technologies identified by DOE were carried through
to the screening analysis, which is discussed in section IV.C.
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The section below addresses the potential consideration of another
technology option.
a. Alternative Refrigerants
The Environmental Investigation Agency (EIA Global) urged DOE to
include hydrocarbon refrigerants as an ACIM technology option. EIA
Global expressed their concern that DOE's analysis will be incomplete
without the inclusion of hydrocarbon refrigerants and that the high
global warming potential (GWP) of current ACIM refrigerants will
further damage the stability of the climate, thus offsetting the
efficiency gains associated with standards. (EIA Global, No. 80 at p.
1)
EIA Global commented that it is likely that EPA will include
hydrocarbons as acceptable ACIM refrigerants in the near future and
urged DOE to bring a SNAP petition to do so. EIA Global added that
accepting hydrocarbons for use in ACIMs with charge sizes of 150g or
less is highly likely and that according to a United Nations
Environment Programme (UNEP) report, such refrigerants have lower
viscosity, resulting in improved cooling efficiency and reducing energy
consumption by 18 percent. (EIA Global, No. 80 at p. 2) EIA Global
noted that DOE should set standards that anticipate future
alternatives, rather than being limited to what is available today.
(EIA Global, No. 80 at p. 4-5)
EIA Global stated that including hydrocarbon refrigerants in the
analysis will be of little burden to DOE because Scotsman, Hoshizaki,
and Manitowoc already sell hydrocarbon machines throughout Europe and
other international markets and noted that these three manufacturers
have observed energy savings associated with use of these refrigerants.
(EIA Global, No. 80 at p. 1-4)
In response to EIA Global's comments, DOE notes that hydrocarbon
refrigerants have not yet been approved by the EPA SNAP program and
hence cannot be considered as a technology option in DOE's analysis.
DOE also notes that, while it is possible that HFC refrigerants
currently used in automatic commercial ice makers may be restricted by
future rules, DOE cannot speculate on the outcome of a rulemaking in
progress and can only consider in its rulemakings rules that are
currently in effect. Therefore, DOE has not included possible outcomes
of a potential EPA SNAP rulemaking. This position is consistent with
past DOE rulings, such as in the 2014 final rule for commercial
refrigeration equipment. 79 FR 17725 (March 28, 2014) DOE notes that
recent proposals by the EPA to allow use of hydrocarbon refrigerants or
to impose new restrictions on the use of HFC refrigerants do not
address automatic commercial ice maker applications. 79 FR 46126
(August 6, 2014) 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 other relevant agencies, will continue to work with
industry and other stakeholders to identify safer and more sustainable
alternatives to HFCs while
[[Page 4671]]
evaluating energy efficiency standards for this equipment. As mentioned
in section IV.A.4, if a manufacturer believes that its design is
subjected to undue hardship by regulations, the manufacturer may
petition DOE's Office of Hearing and Appeals (OHA) for exception relief
or exemption from the standard pursuant to OHA's authority under
section 504 of the DOE Organization Act (42 U.S.C. 7194), as
implemented at subpart B of 10 CFR part 1003. OHA has the authority to
grant such relief on a case-by-case basis if it determines that a
manufacturer has demonstrated that meeting the standard would cause
hardship, inequity, or unfair distribution of burdens.
C. Screening Analysis
In the technology assessment section of this final rule, DOE
presents an initial list of technologies that can improve the energy
efficiency of automatic commercial ice makers. The purpose of the
screening analysis is to evaluate the technologies that improve
equipment efficiency to determine which of these technologies is
suitable for further consideration in its analyses. To do this, DOE
uses four screening criteria--design options will be removed from
consideration if they are not technologically feasible; are not
practicable to manufacture, install, or service; have adverse impacts
on product utility or product availability; or have adverse impacts on
health or safety. 10 CFR part 430, subpart C, appendix A, section
(4)(a)(4). See chapter 4 of the final rule TSD for further discussion
of the screening analysis. Another consideration is whether a design
option provides a unique pathway towards increasing energy efficiency
and that pathway is a proprietary design that a manufacturer can only
get from one source. In this instance, such design option would be
eliminated from consideration because it would require manufacturers to
procure it from a sole source. Table IV.4 shows the EPCA criteria and
additional criteria used in this screening analysis, and the design
options evaluated using the screening criteria.
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[[Page 4672]]
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[[Page 4673]]
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BILLING CODE 6450-01-C
a. General Comments
Manitowoc expressed its agreement with the screening analysis.
(Manitowoc, No. 92 at p. 3) However, Scotsman requested that the
following additional criteria be used in the screening analysis: Impact
on end-user facility and operations, impact on end-user profit-
generating beverage sales, impact on machine footprint, impact on end-
user ``repair existing'' or ``purchase new'' decision hierarchy, impact
on ACIM service and installation network support capability, and impact
on manufacturer component tooling/fixture obsolescence prior to
depreciation. (Scotsman, No. 85 at p. 3b-4b)
In response to Scotsman comment, DOE notes that while DOE's
screening analysis specifically focuses on the four criteria identified
in the process rule (see 10 CFR part 430, subpart C, appendix A,
section (4)(a)(4)), some of the suggested screening criteria outlined
in Scotsman's comment are taken into account in other parts of the
analysis. Specifically, impacts to end user facility and operations,
including installations costs, are considered in the life cycle cost
analysis described in section IV.G. Impacts regarding manufacturing
tooling are examined in the manufacturing impact analysis described in
section IV.J.
b. Drain Water Heat Exchanger
Batch ice makers can benefit from drain water thermal exchange that
cools the potable water supply entering the sump, thereby reducing the
energy required to cool down and freeze the water. Technological
feasibility is demonstrated by one commercially available drain water
thermal heat exchanger that is currently sold only for aftermarket
installation. This product is designed to be installed externally to
the ice maker, and both drain water and supply water are piped through
the device.
Drain water heat exchangers, both internally mounted and externally
mounted, are design options that can increase the energy efficiency of
automatic commercial ice makers. The current test procedures would give
manufacturers credit for efficiency improvement of drain water heat
exchangers, including externally mounted drain water heat exchangers as
long as they are provided with the machine and the installation
instructions for the machine indicate that the heat exchangers are part
of the machine and must be installed as part of the overall
installation.
In response to the NODA, Manitowoc stated that drain water heat
exchangers have not been proven in the industry (DOE assumes that this
comment addresses issues such as their reliability rather than their
potential for energy savings) and their use is likely to result in
lower reliability due to issues with fouling and clogging associated
with mineral particles that naturally accumulate in the dump water for
batch cycle machines. Manitowoc also added that the high costs for
drain water heat exchangers are not justified by their efficiency
gains. (Manitowoc, No. 126 at p. 2) AHRI stated that a drain water heat
exchanger cannot reasonably be implemented in a 22-inch IMH-A-Small-B
unit. (AHRI, No. 128 at p. 2)
DOE notes that drain water heat exchangers have been discussed as a
possible technology option from the framework stage of this rulemaking.
DOE has investigated the feasibility of drain water heat exchangers
through review of product literature, patents, reports on
installations, and product teardowns, and has also conducted testing to
evaluate the claims of efficiency improvement for the technology. While
fouling of the heat exchanger is a potential concern based on the
higher mineral concentration in dump water, heat exchangers designed
for use with ice makers have been designed with electrically insulated
gaskets to substantially reduce deposition of particulates on heat
exchanger surfaces.\28\ Moreover, drain water heat exchangers would
also benefit from typical maintenance of ice machines that includes
dissolution of such mineral deposits on all components that come into
contact with potable water. DOE is not aware of data showing that the
units sold have substantial reliability issues as a consequence of
fouling in retrofit applications. Further, Manitowoc has not provided
information or test data showing that they would reduce reliability.
DOE also notes that answering the question of whether the inclusion of
a drain water heat exchanger is cost-effective is a goal of the DOE
analyses and is not considered during the screening analysis. DOE has
examined the added cost of a drain water heater along with the energy
savings resulting from its use and has found drain water heat
exchangers to be cost justified for certain equipment classes.
---------------------------------------------------------------------------
\28\ Welch, D.L., et al., U.S. Patent No. 5,555,734, Sep. 17,
1996.
---------------------------------------------------------------------------
In response to AHRI's comment suggesting that drain water heat
exchangers may not fit in a 22-inch IMH-A-Small-B cabinet, DOE notes
that the heat exchanger would be mounted outside the unit, rather than
enclosed within the cabinet. If AHRI's comment did not mean to indicate
that the objection was to placement of the heat exchanger within the
unit, the comment also did not make clear why such a component could
not be implemented specifically for a 22-inch wide unit.
In response to AHRI's comment suggesting that drain water heat
exchangers may not fit in a 22-inch IMH-A-Small-B cabinet, DOE notes
that the heat exchanger would be mounted outside the unit, rather than
enclosed within the cabinet. If AHRI's comment did not mean to indicate
that the objection was placement of the heat exchanger within the unit,
the comment also did not make clear why such a component could not be
implemented
[[Page 4674]]
specifically for a 22-inch wide unit. DOE did screen in this
technology.
c. Tube Evaporator Design
Among the technologies that DOE considered were tube evaporators
that use a vertical shell and tube configuration in which refrigerant
evaporates on the outer surfaces of the tubes inside the shell, and the
freezing water flows vertically inside the tubes to create long ice
tubes that are cut into smaller pieces during the harvest process. Some
of the largest automatic commercial ice makers in the RCU-NRC-Large-B
and the IMH-W-Large-B equipment classes use this technology. However,
DOE concluded that implementation of this technology for smaller
capacity ice makers would significantly impact equipment utility, due
to the greater weight and size of these designs, and to the altered ice
shape. DOE noted that available tube ice makers (for capacities around
1,500 lb ice/24 hours and 2,200 lb ice/24 hours) were 150 to 200
percent heavier than comparable cube ice makers. Based on the impacts
to utility of this technology, DOE screened out tube evaporators from
consideration in this analysis.
d. Low Thermal Mass Evaporator Design
DOE's analysis did not consider low thermal mass evaporator
designs. Reducing evaporator thermal mass of batch type ice makers
reduces the heat that must be removed from the evaporator after the
harvest cycle, and thus decreases refrigeration system energy use. DOE
indicated during the preliminary analysis that it was concerned about
the potential proprietary status of such evaporator designs, since DOE
is aware of only one manufacturer that produces equipment with such
evaporators. DOE has not altered its decision to screen out this
technology in its analysis.
e. Microchannel Heat Exchangers
Through discussions with manufacturers, DOE has determined that
there are no instances of energy savings associated with the use of
microchannel heat exchangers in ice makers. Manufacturers also noted
that the reduced refrigerant charge associated with microchannel heat
exchangers can be detrimental to the harvest performance of batch type
ice makers, as there is not enough charge to transfer heat to the
evaporator from the condenser.
DOE contacted microchannel manufacturers to determine whether there
were energy savings associated with use of microchannel heat exchangers
in automatic commercial ice makers. These microchannel manufacturers
noted that investigation of microchannel was driven by space
constraints rather than efficiency.
Because the potential for energy savings is inconclusive, based on
DOE analysis as well as feedback from manufacturers and heat exchanger
suppliers, and based on the potential utility considerations associated
with compromised harvest performance in batch type ice makers
associated with this heat exchanger technology's reduced refrigerant
charge, DOE screened out microchannel heat exchangers as a design
option in this rulemaking.
f. Smart Technologies
While there may be energy demand benefits associated with use of
``smart technologies'' in ice makers in that they reduce energy demand
(e.g., shift the refrigeration system operation to a time of utility
lower demand), DOE is not aware of any commercialized products or
prototypes that also demonstrate improved energy efficiency in
automatic commercial ice makers. Demand savings alone do not impact
energy efficiency, and DOE cannot consider technologies that do not
offer energy savings as measured by the DOE test procedure. Since the
scope of this rulemaking is to consider energy conservation standards
that increase the energy efficiency of automatic commercial ice makers
this technology option has been screened out because it does not save
energy as measured by the test procedure.
g. Motors
Manufacturers Follett and Manitowoc provided comment regarding the
use of higher efficiency motors in ACIMs. Follett stated that they are
not aware of gear motors more efficient than the hypoid motors they
use. (Follett, No. 84 at p. 5) Manitowoc stated that they do not
consider brushless direct-current (DC) fan motors to be cost effective.
(Manitowoc, Public Meeting Transcript, No. 70 at p. 157-159)
In response to Follett's comment, DOE notes that its consideration
of motor efficiency applies to the prime mover portion of the motor,
not the gear drive. Gear motor assemblies include both a motor which
converts electricity to shaft power and a gear drive, which converts
the high rotational speed of the motor shaft to the rotational speed
required by the auger. DOE screened in higher efficiency options for
the motor, but did not consider higher-efficiency gear drives. In
response to Manitowoc, the cost-effectiveness of a given technology,
such as DC fan motors, is not a factor that is considered when
screening technologies.
D. Engineering Analysis
The engineering analysis determines the manufacturing costs of
achieving increased efficiency or decreased energy consumption. DOE
historically has used the following three methodologies to generate the
manufacturing costs needed for its engineering analyses: (1) The
design-option approach, which provides the incremental costs of adding
to a baseline model design options that will 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.
As discussed in the Framework document, preliminary analysis, and
NOPR analysis, DOE conducted the engineering analyses for this
rulemaking using an approach that combines the efficiency level, design
option, and reverse engineering approaches to develop cost-efficiency
curves for automatic commercial ice makers. DOE established efficiency
levels defined as percent energy use lower than that of baseline
efficiency products. DOE's engineering analysis is based on
illustrating a typical design path to achieving the specified
percentage efficiency improvements at each level through the
incorporation of a group of design options. Finally, DOE developed
manufacturing cost models based on reverse engineering of products to
develop baseline manufacturer production costs (MPCs) and to supplement
incremental cost estimate associated with efficiency improvements.
DOE directly analyzed 19 ice maker configurations representing
different classes, capacities, and physical sizes. To develop cost-
efficiency curves, DOE collected information from multiple sources to
characterize the manufacturing cost and energy use reduction of each of
the design options or grouping of design options. DOE conducted an
extensive review of product literature on hundreds of ice makers and
selected 50 of them for testing and reverse engineering.
To gather cost and performance information of different ice maker
[[Page 4675]]
design strategies, DOE conducted interviews with ice maker
manufacturers and component vendors of compressors and fan motors
during the preliminary, NOPR, NODA, and final phases of the rulemaking
Cost information from the vendor interviews and discussions with
manufacturers provided input to the manufacturing cost model. DOE
determined incremental costs associated with specific design options
from vendor information, discussion with manufacturers, and the cost
model. DOE calculated energy use reduction based on test data, data
provided in comments, data provided in manufacturer interviews, and
using the FREEZE program, The reverse engineering, equipment testing,
vendor interviews, and manufacturer interviews provided input for the
energy analysis. Information about specific ice makers also provided
equipment examples against which the modeling results could be
calibrated. The final incremental cost estimates and the energy
modeling results together constitute the energy efficiency curves
presented in the final rule TSD chapter 5.
The cost-efficiency relationships were derived from current market
designs so that efficiency calculations could be verified by ratings or
testing. Another benefit of using market designs is that the efficiency
performance can be associated with the use of particular design options
or design option groupings. The cost of these design option changes can
then be isolated and also verified. In earlier stages of the rule DOE
had limited information on current market designs and relied on the
FREEZE model to supplement and extend its design-option energy modeling
analysis. For the NODA and Final Rule, DOE has expanded its knowledge
base of market designs through its own program of testing and reverse
engineering, but also received test and design information from ice
maker manufacturers. The cost-efficiency curves are now based on these
market designs, test data obtained both through DOE testing and from
manufacturers, specific information about component performance (e.g.
motor efficiency) on which stakeholders have been able to comment, and
in some instances use of the FREEZE model. DOE limited the projected
efficiency levels for groups of design options found in available
equipment to the maximum available efficiency levels associated with
the specific classes. The groups of design options that DOE's analysis
predicted would be required to attain these maximum efficiency levels
were consistent with those of the maximum available ice makers or were
found to provide a conservative estimate of cost compared to the market
designs of equal efficiency employing different design option groups to
attain the level.
Additional details of the engineering analysis are available in
chapter 5 of the final rule TSD.
1. Representative Equipment for Analysis
In performing its engineering analysis, DOE selected representative
units within specific equipment types to serve as analysis points in
the development of cost-efficiency curves. DOE selected models that
were representative of the typical offerings within a given equipment
class. DOE sought to select models having features and technologies
typically found in both the minimum and maximum efficiency equipment
currently available on the market.
DOE received several comments from interested parties regarding
those equipment classes not directly analyzed in the NOPR. Follett
commented that they object to the fact that only one RCU-Large-C was
purchased for testing, given that it represents nearly half of
Follett's sales. Follett added that they also object to the fact that
DOE did not analyze IMH-W-Small-C, IMH-W-Large-C, RCU-Small-C, and RCU-
Large-C, which comprise a significant portion of Follett's revenue.
Follett expressed its fear that DOE's approach could require Follett to
enact design changes that are neither technologically feasible nor
economically justified. (Follett, No. 84 at p. 7-8) Follett added that
all manufacturers have unique designs that should be noted during
reverse engineering analyses. (Follett, No. 84 at p. 8) Similarly,
Hoshizaki commented that DOE only analyzed less than 1% of available
units and that analysis did not include testing to validate proposed
design changes. (Hoshizaki, No. 86 at p. 1)
Ice-O-Matic noted that half cube machines represent a significant
portion of the industry and expressed concern that DOE did not attempt
to analyze half cube machines. (Ice-O-Matic, No. 121 at p. 3)
In response to Ice-o-Matic, DOE notes that it focused its analysis
on full cube machines based on the observation that half cube machines
may have an efficiency advantage over full cube machines. For some
models that are available in both versions, the energy use ratings are
different, and generally the half-dice version has lower energy. This
is consistent with the fact that the additional copper strips that
divide the full-cube cells into two half-cube cells also provide
additional heat transfer surface area that can enhance ice maker
performance.
In response to Follett and Hoshizaki's comments, DOE is limited in
time and resources, and as such, cannot directly analyze all models.
DOE responded to NOPR comments regarding lack of analysis of continuous
RCU units by adding direct analysis of a continuous RCU configuration
with capacity of 800 lb ice/24 hours. This capacity is near the border
between the small and large RCU continuous classes, hence it provides
representation for both capacity ranges. DOE reviewed Follett's
available continuous RCU ice maker data, as listed in the ENERGY
STAR(copyright) database, and found that nearly all of the models meet
the standard set in this rule. Of the two that don't, one has adjusted
energy use within 1 percent of the standard, and one has energy use
within 6 percent.
DOE disagrees with Hoshizaki's statement that DOE analyzed less
than one percent of available units and believes it mischaracterizes
DOE's analysis. DOE identified 656 current ice maker models in its
research of available databases and Web sites. DOE did not analyze
Hoshizaki batch ice makers, due to their proprietary evaporator
design--hence the 91 Hoshizaki batch models would not have been
considered in DOE's analysis for this reason. DOE developed 19
analyses, 3.4 percent of the remaining 565 models. Moreover, DOE
asserts that the range of models analyzed provides a good
representation of ice maker efficiency trends. DOE carefully selected
the analyzed units to represent 13 of the 25 ice maker equipment
classes listed in Table IV.2 representing roughly 93 percent of ice
maker shipments.
DOE does not generally conduct prototype testing to verify the
energy savings projections associated with specific design changes. For
this, DOE has requested data from stakeholders who have done such work.
DOE received such test data, some of it through confidential
information exchange with its contractor, and considered this data in
the analysis. Further, DOE also considered test data and design details
of commercially available ice makers, which it used to calibrate its
projections of energy reductions associated with groups of design
options.
In many cases, DOE leveraged information found by directly
analyzing similar product classes to supplement the analysis of those
secondary equipment classes which were not
[[Page 4676]]
directly analyzed. These similar equipment classes are listed in Table
IV.6. The details of why these equipment classes were chosen can be
found in chapter 5 of the final rule TSD.
Table IV.6--Directly Analyzed Equipment Classes Used To Develop
Standards for Secondary Classes
------------------------------------------------------------------------
Analyzed equipment class
Secondary equipment class associated with efficiency level
for secondary equipment class
------------------------------------------------------------------------
RCU-NRC-Small-B..................... RCU-NRC-Large-B.
RCU-RC-Small-B...................... RCU-NRC-Large-B.
RCU-RC-Large-B...................... RCU-NRC-Large-B.
SCU-W-Small-B....................... SCU-W-Large-B.
IMH-W-Small-C....................... IMH-A-Small-C.
IMH-W-Large-C....................... IMH-A-Large-C.
RCU-NRC-Large-C..................... RCU-NRC-Small-C.
RCU-RC-Small-C...................... RCU-NRC-Small-C.
RCU-RC-Large-C...................... RCU-NRC-Small-C.
SCU-W-Small-C....................... SCU-A-Small-C.
SCU-W-Large-C....................... SCU-A-Small-C.
SCU-A-Large-C....................... SCU-A-Small-C.
------------------------------------------------------------------------
2. Efficiency Levels
a. Baseline Efficiency Levels
EPCA, as amended by the EPACT 2005, prescribed the following
standards for batch type ice makers, shown in Table IV.7, effective
January 1, 2010. (42 U.S.C. 6313(d)(1)) For the engineering analysis,
DOE used the existing batch type equipment standards as the baseline
efficiency level for the equipment types under consideration in this
rulemaking. Also, DOE applied the standards for equipment with harvest
capacities up to 2,500 lb ice/24 hours as baseline efficiency levels
for the larger batch type equipment with harvest capacities between
2,500 and 4,000 lb ice/24 hours, which are currently not regulated. DOE
applied two exceptions to this approach, as discussed below.
For the IMH-W-Small-B equipment class, DOE slightly adjusted the
baseline energy use level to close a gap between the IMH-W-Small-B and
the IMH-W-Medium-B equipment classes. For equipment in the IMH-A-Large-
B equipment class with harvest capacity above 2,500 lb ice per 24
hours, DOE chose a baseline efficiency level equal to the current
standard level at the 2,500 lb ice per 24 hours capacity. In its
analysis, DOE is treating the constant portion of the IMH-A-Large-B
equipment class as a separate equipment class, IMH-A-Extended-B.
As noted in section IV.B.1.d DOE is not proposing adjustment of
maximum condenser water use standards for batch type ice makers. The
section also generally discusses DOE regulation of condenser water.
First, DOE's authority does not extend to regulation of water use,
except as explicitly provided by EPCA. Second, DOE determined that
increasing condenser water use standards to allow for more water flow
in order to reduce energy use is not cost-effective. The details of
this analysis are available in chapter 5 of the final rule TSD.
For water-cooled batch equipment with harvest capacity less than
2,500 lb ice per 24 hours, the baseline condenser water use is equal to
the current condenser water use standards for this equipment.
For water-cooled equipment with harvest capacity greater than 2,500
lb ice per 24 hours, DOE set maximum condenser water standards equal to
the current standard level for the same type of equipment with a
harvest capacity of 2,500 lb ice per 24 hours--the proposed standard
level would not continue to drop as harvest capacity increases, as it
does for equipment with harvest capacity less than 2,500 lb ice per 24
hours.
Table IV.7--Baseline Efficiency Levels for Batch Ice Makers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Maximum energy use kWh/100 lb Maximum condenser water use
Equipment type Type of cooling Harvest rate lb ice/24 hours ice * gal/100 lb ice
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice--Making Head................ Water................... <500 7.80--0.0055H ** 200--0.022H.
>=500 and <1,436 5.58--0.0011H 200--0.022H.
>=1,436 4.0 145.
Air..................... <450 10.26--0.0086H Not Applicable.
>=450 and <2,500 6.89--0.0011H Not Applicable.
>=2,500 4.1 Not Applicable.
Remote Condensing (but not Air..................... <1,000 8.85--0.0038H Not Applicable.
remote compressor). >=1,000 5.10 Not Applicable.
Remote Condensing and Remote Air..................... <934 8.85--0.0038H Not Applicable.
Compressor. >=934 5.30 Not Applicable.
Self--Contained................. Water................... <200 11.4--0.019H 191--0.0
>=200 7.60 For <2,500: 191--0.0315H.
For >=2,500: 112.
Air..................... <175 18.0--0.0469H Not Applicable.
>=175 9.80 Not Applicable.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Water use is for the condenser only and does not include potable water used to make ice.
** H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.
Source: 42 U.S.C. 6313(d).
Currently there are no DOE energy standards for continuous type ice
makers. During the preliminary analysis, DOE developed baseline
efficiency levels using energy use data available from several sources,
as discussed in chapter 3 of the preliminary TSD. DOE chose baseline
efficiency levels that would be met by nearly all ice makers
represented in the databases, using ice hardness assumptions of 70 for
flake ice makers and 85 for nugget ice makers, since ice hardness data
was not available at the time. For the NOPR analysis, DOE used
available information published in the AHRI Directory of Certified
Product Performance, the California Energy Commission, the ENERGY STAR
program, and vendor Web sites, to update its icemaker ratings database
(``DOE icemaker ratings database''). The AHRI published equipment
ratings including ice hardness data, measured as prescribed by ASHRAE
29-2009, which is incorporated by reference in the DOE test procedure.
DOE recreated
[[Page 4677]]
its baseline efficiency levels for continuous type ice makers based on
the available AHRI data, considering primarily the ice makers for which
ice hardness data were available. DOE also adjusted the harvest
capacity break points for the continuous equipment classes based on the
new data.
The baseline efficiency levels used in the NOPR analysis for
continuous type ice makers are presented in Table IV.8. For the remote
condensing equipment, the large-capacity remote compressor and large-
capacity non-remote compressor classes have been separated and are
different by 0.2 kWh/100 lb, identical to the batch equipment
differential for the large batch classes.
Table IV.8--NOPR Baseline Efficiency Levels for Continuous Ice Maker Equipment Classes
--------------------------------------------------------------------------------------------------------------------------------------------------------
Maximum energy use kWh/100 lb Maximum condenser water use *
Equipment type Type of cooling Harvest rate lb ice/24 hours ice * gal/100 lb ice
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice-Making Head................. Water................... Small (<900) 8.1-0.00333H 160-0.0176H.
Large (>=900) 5.1 <=2,500: 160-0.0176H.
>2,500: 116.
Air..................... Small (<700) 11.0-0.00629H Not Applicable.
Large (>=700) 6.6 Not Applicable.
Remote Condensing (Remote Air..................... Small (<850) 10.2-0.00459H Not Applicable.
Compressor). Large (>=850) 6.3 Not Applicable.
Remote Condensing (Non-remote Air..................... Small (<850) 10.0-0.00459H Not Applicable.
Compressor). Large (>=850) 6.1 Not Applicable.
Self-Contained.................. Water................... Small (<900) 9.1-0.00333H 153-0.0252H.
Large (>=900) 6.1 <=2,500:
153-0.0252H.
>2,500: 90.
Air..................... Small (<700) 11.5-0.00629H
Large (>=700) 7.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
* H = harvest capacity in lb ice/24 hours
After the publication of the NOPR and the NOPR public meeting, DOE
received two comments from interested parties regarding its
establishment of baseline models.
In response to the NOPR, Scotsman commented that there is not
sufficient historical data (greater than 1 year) to establish
continuous type baselines with statistical confidence. Scotsman added
that the current ASHRAE standard is biased against low-capacity
machines, and therefore does not accurately represent the energy usage
of the machine when corrected for hardness factor. (Scotsman, No. 85 at
p. 3b)
DOE has found multiple sources of information regarding the energy
efficiency of continuous ice machines on the market. As noted
previously, DOE investigated information published in the AHRI
Directory of Certified Product Performance, the California Energy
Commission, the ENERGY STAR program, and vendor Web sites to inform the
establishment of a baseline for continuous models. In regards to
Scottsman's comment that the standard is biased against low capacity
machines, DOE has set its baseline levels while considering continuous
model energy use that has been adjusted using the current ASHRAE test
standard. If the test is biased against low-capacity machines, this
bias should be reflected in the data and already be accounted for in
the selected baseline levels.
Hoshizaki stated that they believe the baseline levels presented in
the NOPR are too harsh for continuous equipment as it leaves many
ENERGY STAR units unable to meet the minimum energy efficiency
baseline. Hoshizaki noted that DOE based its analysis on the 2012 AHRI
listing. Hoshizaki requested that DOE reassess the baseline data for
all current continuous models as many more units have since been listed
on AHRI's Web site. (Hoshizaki, No. 86 at p. 2-3) Similarly, Follett
commented that some of the data on continuous type ice makers were not
available in 2012, since they were not a part of the ENERGY STAR
program until 2013, and that the baseline line might move up if recent
data was added to the plot. (Follet, Public Meeting Transcript, No. 70
at p. 76-78) PGE/SDG&E commented that they support DOE's updating their
database with new data from all sources, including the CEC, AHRI, and
NRCan databases. (PG&E and SDG&E, No. 89 at p. 3)
In response to Hoshizaki's comment about ENERGY STAR-rated
continuous models, for which there are currently no federal standard
levels that would clearly represent the baseline efficiency levels, DOE
revised its continuous class baselines so that no ENERGY STAR-rated
continuous models have energy use higher than the baseline. The revised
baseline efficiency levels for the continuous SCU classes are shown in
Table IV.9 below. However, DOE notes that baseline efficiency levels
are not required to be set at a level with which all commercially
available equipment would be compliant. There are some IMH-W models and
some IMH-A models that have energy use higher than the selected
baseline levels--this is illustrated in the comparison of equipment
data and efficiency levels in Chapter 3 of the TSD. DOE selected
baseline efficiency levels that provide a good representation of the
highest energy use exhibited by models available on the market with the
exclusion of a few outliers (i.e. models exhibiting very different
energy use than the majority of models).
[[Page 4678]]
Table IV.9--Modified Baseline Efficiency Levels for SCU Continuous Ice Maker Equipment Classes
--------------------------------------------------------------------------------------------------------------------------------------------------------
Maximum energy use kWh/100 Maximum condenser water use
Equipment type Type of cooling Harvest rate lb ice/24 hours lb ice * * gal/100 lb ice
--------------------------------------------------------------------------------------------------------------------------------------------------------
Self-Contained.................. Water................... Small (<900) 9.5--0.00378H 153--0.0252H.
Large (>=900) 6.1 <=2,500:
153--0.0252H
>2,500: 90.
Air..................... Small (<200) 16.3--0.03H Not Applicable.
Large (>=200 and 11.84--0.0078H Not Applicable.
< 700)
Extended (>= 700) 6.38 Not Applicable.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* H = harvest capacity in lb ice/24 hours.
In response to the comments related to data sources DOE notes that
it has continued to update the analysis with new data as it becomes
available. This includes new information published in the AHRI
Directory of Certified Product Performance, the California Energy
Commission and the ENERGY STAR program.
In response to the NODA analysis, Hoshizaki again stated that DOE
has not conducted enough analysis to accurately portray the baseline
efficiency levels of continuous models (Hoshizaki, No. 124 at p. 1)
NAFEM also stated that the NODA continuous unit baselines do not
reflect the current models in the marketplace. (NAFEM, No. 123 at p. 2)
DOE has evaluated all available data sources in its determination
of the baseline efficiency levels for continuous units. However, as
stated above, DOE notes that the baseline level selected is not
necessarily the least efficient equipment on the market. As part of
this review of data sources, DOE has modified the baseline condenser
water use levels for IMH-W continuous classes such that they are 10
percent below the IMH-W batch baseline water use levels.
b. Incremental Efficiency Levels
For each of the 11 analyzed batch type ice-maker equipment classes
and the four analyzed continuous ice maker equipment classes, DOE
established a series of incremental efficiency levels for which it has
calculated incremental costs. DOE chose these classes to be
representative of all ice-making equipment classes, and grouped non-
analyzed equipment classes with similar analyzed equipment classes
accordingly in the downstream analysis. Table IV.10 shows the selected
incremental efficiency levels considered in the final rule analysis for
batch ice makers, and Table IV.11 shows the incremental efficiency
levels considered for continuous ice makers.
Table IV.10--Incremental Efficiency Levels for Batch Ice Maker Equipment Classes Considered in the Final Rule Analysis
--------------------------------------------------------------------------------------------------------------------------------------------------------
Harvest capacity rate lb ice/24
hours
Equipment type * ------------------------------------ EL 2 ** EL 3 EL 3A EL 4 EL 4A EL 5 (%) EL 6 (%) EL 7 (%)
Representative (%) *** (%) *** (%)
Range capacity
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Small-B............................... <500 300 10 15 20 24 .......... ..........
.................. .............. .......... .......... 22 .......... .......... ..........
IMH-W-Med-B................................. >=500 and <1,436 850 10 15 18 .......... .......... ..........
IMH-W-Large-B............................... >=1,436 1,500 8 .......... .......... .......... .......... ..........
IMH-W-Large-B............................... >=1,436 2,600 7 .......... .......... .......... .......... ..........
IMH-A-Small-B............................... <450 300 10 15 20 25 26 ..........
18
IMH-A-Large-B............................... >=450 800 10 15 20 23 .......... ..........
16
IMH-A-Large-B............................... >=450 1,500 10 12 .......... .......... .......... ..........
--------------------------------------------------------------------------------------------------------------------------------------------------------
RCU-NRC-Small-B............................. .................. Not Directly Analyzed
--------------------------------------------------------------------------------------------------------------------------------------------------------
RCU-NRC-Large-B............................. >=1,000 1,500 10 15 17 .......... .......... ..........
RCU-NRC-Large-B............................. >=1,000 2,400 10 14 .......... .......... .......... ..........
--------------------------------------------------------------------------------------------------------------------------------------------------------
RCU-RC-Small-B.............................. <934 Not Directly Analyzed
--------------------------------------------------------------------------------------------------------------------------------------------------------
RCU-RC-Large-B.............................. >=934 Not Directly Analyzed
--------------------------------------------------------------------------------------------------------------------------------------------------------
SCU-W-Small-B............................... >200 Not Directly Analyzed
--------------------------------------------------------------------------------------------------------------------------------------------------------
SCU-W-Small-B............................... >=200 300 10 15 20 25 30 ..........
SCU-A-Small-B............................... <175 110 10 15 20 25 30 33
[[Page 4679]]
SCU-A-Large-B............................... >=175 200 10 15 20 25 29 ..........
--------------------------------------------------------------------------------------------------------------------------------------------------------
* See Table III.1 for a description of these abbreviations.
** EL = efficiency level; EL 1 is the baseline efficiency level, while EL 2 through EL 7 represent increased efficiency levels.
*** DOE considered intermediate efficiency levels 3A and 4A for some equipment classes.
Table IV.11--Incremental Efficiency Levels for Continuous Type Ice Maker Equipment Classes Considered in the Final Rule Analysis
--------------------------------------------------------------------------------------------------------------------------------------------------------
Harvest capacity lb ice/24 hours
------------------------------------ EL 2 **
Equipment Type * Representative (%) EL 3 (%) EL 4 (%) EL 5 (%) EL 6 (%)
Range capacity
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Small-C........................................... <900 Not Directly Analyzed
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Large-C........................................... >=900 Not Directly Analyzed
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-A-Small-C........................................... <700 310 10 15 20 25 26
IMH-A-Large-C........................................... >=700 820 10 15 20 23 ..........
RCU-Small-C............................................. <850 800 10 15 20 25 27
--------------------------------------------------------------------------------------------------------------------------------------------------------
RCU-Large-C............................................. >=850 Not Directly Analyzed
--------------------------------------------------------------------------------------------------------------------------------------------------------
SCU-W-Small-C........................................... <900 Not Directly Analyzed
--------------------------------------------------------------------------------------------------------------------------------------------------------
SCU-W-Large-C........................................... >=900 No existing products on the market
--------------------------------------------------------------------------------------------------------------------------------------------------------
SCU-A-Small-C........................................... <700 220 10 15 20 25 27
--------------------------------------------------------------------------------------------------------------------------------------------------------
SCU-A-Large-C........................................... >=700 No existing products on the market
--------------------------------------------------------------------------------------------------------------------------------------------------------
* See Table III.1 for a description of these abbreviations.
** EL 1 is the baseline efficiency level, while EL 2 through EL 6 represent increased efficiency levels.
In response to the NODA, Hoshizaki stated that ``there are no
models that achieve the NODA levels in SCU-A, IMH-W large, or RCU-A
large'' equipment classes. Hoshizaki added that these same levels were
not analyzed for cost curves. (Hoshizaki, No. 124 at p. 1)
As discussed above in section IV.D.1, DOE's analysis for the RCU
class was at a representative capacity of 800 lb ice/24 hours, intended
to provide representation for both small and large classes, by being at
a capacity level in the large range but within 100 lb ice/24 hours of
the small range. Continuous ice maker data that DOE collected from
publicly available sources does show that nearly all ice makers meet
the baseline efficiency levels considered in the analysis. Not all meet
the efficiency levels eventually designated as TSL 3 for the final
rule, but some ice makers over a broad capacity range in each of the
cited classes (SCU-A-C, IMH-W-C, RCU-RC-C, and RCU-NRC-C) do meet this
level, shown in Table IV.12 through Table IV.15. A comparison of the
levels achieved by commercially available ice makers with the
considered TSL levels is shown graphically in Chapter 3 of the TSD.
Table IV.12--Air-Cooled, Self-Contained, Continuous Units Meeting the Final Rule Standard
--------------------------------------------------------------------------------------------------------------------------------------------------------
Adjusted energy
Manufacturer Model Harvest capacity use (kWh/100 lb Standard (kWh/100 Hardness factor
(lb ice/24 hours) ice) lb ice)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Hoshizaki................................. F-330BAH-C.................. 222 7.99 8.08 84.5
Hoshizaki................................. F-330BAH.................... 238 7.56 7.98 69.8
Manitowoc................................. RNS0385A-161................ 248 7.75 7.92 86
Scotsman.................................. MDT5N25WS-1#................ 455 4.99 6.63 75
Hoshizaki................................. DCM-751BWH.................. 631 5.21 5.53 88.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4680]]
Table IV.13--Water-Cooled, Ice Making Head, Continuous Units Meeting the Final Rule Standard
--------------------------------------------------------------------------------------------------------------------------------------------------------
Adjusted energy
Manufacturer Model Harvest capacity use (kWh/100 lb Standard (kWh/100 Hardness factor
(lb ice/24 hours) ice) lb ice)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice-O-Matic............................... GEM0450W.................... 429 4.66 5.33 (*)
Follet.................................... HC *700W **................. 535 4.43 5.05 (*)
Ice-O-Matic............................... GEM0655W.................... 578 4.2 4.94 (*)
Ice-O-Matic............................... MFI0805W.................... 604 4.26 4.87 (*)
Hoshizaki................................. F-801MWH.................... 635 4.48 4.78 75.1
Ice-O-Matic............................... GEM0650W.................... 633 3.86 4.79 (*)
Ice-O-Matic............................... MFI0800W.................... 740 3.93 4.50 (*)
Ice-O-Matic............................... GEM0956W.................... 877 3.54 4.34 (*)
Ice-O-Matic............................... GEM0955W.................... 927 3.71 4.34 (*)
Ice-O-Matic............................... MFI1256W.................... 959 3.54 4.34 (*)
Ice-O-Matic............................... MFI1255W.................... 1000 3.41 4.34 (*)
Follet.................................... HCE1400W**.................. 1150 4.31 4.34 (*)
Ice-O-Matic............................... RN-1409W.................... 1318 4.27 4.34 (*)
Ice-O-Matic............................... RN1409W-261................. 1318 4.15 4.34 88
Follet.................................... HCC1400W ***................ 1374 4.28 4.34 (*)
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Ice hardness factor assumed to be 70 for flake ice makers and 85 for nugget ice makers.
Table IV.14--Remote Condensing, Not Remote Compressor, Continuous Units Meeting the Final Rule Standard
--------------------------------------------------------------------------------------------------------------------------------------------------------
Adjusted energy
Manufacturer Model Harvest capacity use (kWh/100 lb Proposed standard Hardness factor
(lb ice/24 hours) ice) (kWh/100 lb ice)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ice-O-Matic............................... GEM0650R.................... 550 6.41 6.51 (*)
Ice-O-Matic............................... GEM0956R.................... 825 4.77 4.915 (*)
Ice-O-Matic............................... MFI1256R.................... 950 4.79 5.06 (*)
Scotsman.................................. N1322R-32#.................. 1030 5.04 5.06 74
Scotsman.................................. F1222R-32#.................. 1050 4.97 5.06 60
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Ice hardness factor assumed to be 70 for flake ice makers and 85 for nugget ice makers.
Table IV.15--Remote Condensing, Remote Compressor, Continuous Units Meeting the Final Rule Standard
--------------------------------------------------------------------------------------------------------------------------------------------------------
Adjusted energy
Manufacturer Model Harvest capacity use (kWh/100 lb Standard (kWh/100 Hardness factor
(lb ice/24 hours) ice) lb ice)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Follet.................................... HCD700RBT................... 566 5.44 6.62 88
Manitowoc................................. RFS1278C-261................ 958 5.11 5.26 72
Follet.................................... HCD1400R ***................ 1184 4.87 5.26 (*)
Follet.................................... HCF1400RBT.................. 1195 4.59 5.26 89.4
Follet.................................... HCD1650R ***................ 1284 5.24 5.26 (*)
Follet.................................... HCF1650RBT.................. 1441 4.14 5.26 89.9
Manitowoc................................. RFS2378C-261................ 1702 5.18 5.26 68
Ice-O-Matic............................... MFI2406LS................... 2000 4.27 5.26 (*)
Scotsman.................................. FME2404RLS.................. 2000 3.54 5.26 (*)
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Ice hardness factor assumed to be 70 for flake ice makers and 85 for nugget ice makers.
c. IMH-A-Large-B Treatment
The existing DOE energy conservation standard for large air-cooled
IMH cube type ice makers is represented by an equation for which
maximum allowable energy usage decreases linearly as harvest rate
increases from 450 to 2,500 lb ice/24 hours. In the NOPR, DOE proposed
efficiency levels for this class that maintain a constant energy use in
kwh per 100 pounds of ice at large capacities to the extent that this
approach does not violate EPCA's anti-backsliding provision. 79 FR at
14877 (March 17, 2014).
DOE did not receive any comments on the approach described in the
NOPR. Therefore, DOE maintained this approach for the final rule.
d. Maximum Available Efficiency Equipment
DOE considered the most-efficient equipment available on the
market, known as maximum available equipment. For many batch equipment
classes, the maximum available equipment uses proprietary or screened-
out technology options that DOE did not consider in its engineering
analysis, such as low thermal-mass evaporators and tube evaporators for
batch type ice makers. Hence, DOE considered only batch maximum
available equipment that does not include these technologies. These
maximum available efficiency levels are shown in Table IV.16. This
information is based on DOE's icemaker ratings database (see data in
chapter 3 of the final rule TSD). The efficiency levels are represented
as an energy use percentage reduction compared to the energy use of
baseline-efficiency equipment. For some batch equipment classes, DOE
has presented maximum available efficiency levels at different capacity
levels or for 22-inch wide ice makers.
[[Page 4681]]
Table IV.16--Efficiency Levels for Maximum Available Equipment Without
Screened Technologies in Batch Ice Maker Equipment Classes
------------------------------------------------------------------------
Equipment class Energy use lower than baseline
------------------------------------------------------------------------
IMH-W-Small-B.......................... 19.2%, 16.9% (22-inch wide).
IMH-W-Med-B............................ 14.3%.
IMH-W-Large-B.......................... 5% (at 1,500 lb ice/24 hours),
2.5% (at 2,600 lb ice/24
hours).
IMH-A-Small-B.......................... 19.3%, 16.6% (22-inch wide).
IMH-A-Large-B.......................... 16.1% (at 800 lb ice/24 hours)
5.5% (at 590 lb ice/24 hours,
22-inch wide) 6.0% (at 1,500
lb ice/24 hours).
RCU-Small-B............................ 25.8%.
RCU-Large-B............................ 15.7% (at 1,500 lb ice/24
hours), 14.9% (at 2,400 lb ice/
24 hours).
SCU-W-Small-B.......................... 26.2%.
SCU-W-Large-B.......................... 27.6%.
SCU-A-Small-B.......................... 24.9%.
SCU-A-Large-B.......................... 26.4%.
------------------------------------------------------------------------
Efficiency levels for maximum available equipment in the continuous
type ice-making equipment classes are shown in Table IV.17. This
information is based on a survey of product databases and manufacturer
Web sites (see data in chapter 3 of the final rule TSD). The efficiency
levels are represented as an energy use percentage reduction compared
to the energy use of baseline-efficiency equipment.
Table IV.17--Efficiency Levels for Maximum Available Equipment for
Continuous Type Ice Maker Equipment Classes
------------------------------------------------------------------------
Equipment class Energy use lower than baseline
------------------------------------------------------------------------
IMH-W-Small-C.......................... 16.5%.
IMH-W-Large-C.......................... 12.2% (at 1,000 lb ice/24
hours), 8.6% (at 1,800 lb ice/
24 hours).
IMH-A-Small-C.......................... 28.0%.
IMH-A-Large-C.......................... 35.7% (at 820 lb ice/24 hours),
lb ice.
RCU-Small-C............................ 18.4%.
RCU-Large-C............................ 18.5%.
SCU-W-Small-C.......................... 18.7% *.
SCU-W-Large-C.......................... No equipment on the market *.
SCU-A-Small-C.......................... 29.3%.
SCU-A-Large-C.......................... No equipment on the market *.
------------------------------------------------------------------------
* DOE's inspection of currently available equipment revealed that there
are no available products in the defined SCU-W-Large-C and SCU-A-Large-
C equipment classes at this time.
In response to the maximum available efficiency levels presented in
the NODA AHRI suggested that DOE review the max available unit for the
22-inch IMH-A-Small-B equipment class which is cited at 17% as they
believe the unit may contain proprietary design options. (AHRI, No. 128
at p. 3)
DOE maintains that the representative 22-inch unit for the IMH-A-
Small-B equipment class did not contain any proprietary designs--
specifically, the model analyzed does not include any proprietary or
screened options such as low-thermal-mass evaporators or tube-ice
evaporators. Table IV.18 lists 22-inch ice makers of this class that
are in DOE's ice maker database. DOE calculated an efficiency level
equal to 12.3% for such a unit with design options included in maximum
available equipment. There are three available units with higher
efficiency level. Therefore, DOE has maintained the maximum available
level for this equipment class in the final rule engineering analysis.
Table IV.18--22-Inch IMH-A-Small-B Models
----------------------------------------------------------------------------------------------------------------
Contains proprietary
or screened
Harvest capacity rate (lb ice/24 hours) Rated energy use Percent efficiency technology (e.g.,
(kWh/100 lb ice) level low-thermal-mass or
tube evaporators)?
----------------------------------------------------------------------------------------------------------------
249........................................ 8.10 0.2 No.
290........................................ 7.23 6.9 No.
225........................................ 7.49 10.0 No.
335........................................ 6.64 10.0 No.
360........................................ 6.45 10.0 No.
310........................................ 6.80 10.5 No.
305........................................ 6.80 11.0 No.
230........................................ 7.32 11.6 No.
278........................................ 6.90 12.3 Yes.
214........................................ 7.20 14.5 No.
370........................................ 5.90 16.6 No.
255........................................ 6.60 18.2 No.
324........................................ 5.80 22.4 Yes.
----------------------------------------------------------------------------------------------------------------
e. Maximum Technologically Feasible Efficiency Levels
When DOE adopts an amended or new energy conservation standard for
a type or class of covered equipment such as automatic commercial ice
makers, it determines the maximum improvement in energy efficiency that
is technologically feasible for such equipment. (See 42 U.S.C.
6295(p)(1) and 6313(d)(4)) DOE determined maximum technologically
feasible (``max-tech'') efficiency levels for automatic commercial ice
makers in the engineering analysis by considering efficiency
improvement beyond the maximum available levels associated with two
design options that are generally not used in commercially available
equipment, brushless DC motors and drain water heat exchangers. DOE has
not screened out these design options--cost-effectiveness is not one of
the screening criteria (see section IV.C). Table IV.19 and Table IV.20
show the max-tech levels determined in the NOPR engineering analysis
for batch and continuous type automatic commercial ice makers,
respectively. These max-tech levels do not consider use of screened
technology, specifically low-thermal-mass evaporators and tube ice
evaporators.
[[Page 4682]]
Table IV.19--Final Rule Max-Tech Levels for Batch Automatic Commercial
Ice Makers
------------------------------------------------------------------------
Percent energy use lower than
Equipment type * baseline
------------------------------------------------------------------------
IMH-W-Small-B.......................... 23.9%, 21.5% (22 inch wide).
IMH-W-Med-B............................ 18.1%.
IMH-W-Large-B.......................... 8.3% (at 1,500 lb ice/24
hours), 7.4% (at 2,600 lb ice/
24 hours).
IMH-A-Small-B.......................... 25.5%, 18.1% (22 inch wide).
IMH-A-Large-B.......................... 23.4% (at 800 lb ice/24 hours),
15.8% (at 590 lb ice/24 hours,
22 inch wide), 11.8% (at 1,500
lb ice/24 hours).
RCU-Small-B............................ Not directly analyzed.
RCU-Large-B............................ 17.3% (at 1,500 lb ice/24
hours), 13.9% (at 2,400 lb ice/
24 hours).
SCU-W-Small-B.......................... Not directly analyzed.
SCU-W-Large-B.......................... 29.8%.
SCU-A-Small-B.......................... 32.7%.
SCU-A-Large-B.......................... 29.1%.
------------------------------------------------------------------------
* IMH is ice-making head; RCU is remote condensing unit; SCU is self-
contained unit; W is water-cooled; A is air-cooled; Small refers to
the lowest harvest category; Med refers to the Medium category (water-
cooled IMH only); Large refers to the large size category; RCU units
were modeled as one with line losses used to distinguish standards.
Note: For equipment classes that were not analyzed, DOE did not develop
specific cost-efficiency curves but attributed the curve (and maximum
technology point) from one of the analyzed equipment classes.
Table IV.20--Final Rule Max-Tech Levels for Continuous Automatic
Commercial Ice Makers
------------------------------------------------------------------------
Percent energy use lower than
Equipment type baseline
------------------------------------------------------------------------
IMH-W-Small-C.......................... Not directly analyzed.
IMH-W-Large-C.......................... Not directly analyzed.
IMH-A-Small-C.......................... 25.7% [dagger].
IMH-A-Large-C.......................... 23.3% (at 820 lb ice/24 hours).
RCU-Small-C............................ 26.6% [dagger].
RCU-Large-C............................ Not directly analyzed.
SCU-W-Small-C.......................... Not directly analyzed.
SCU-W-Large-C *........................ No units available.
SCU-A-Small-C.......................... 26.6% [dagger].
SCU-A-Large-C *........................ No units available.
------------------------------------------------------------------------
* DOE's investigation of equipment on the market revealed that there are
no existing products in either of these two equipment classes (as
defined in this NOPR).
** For equipment classes that were not analyzed, DOE did not develop
specific cost-efficiency curves but attributed the curve (and maximum
technology point) from one of the analyzed equipment classes
[dagger] Percent energy use lower than baseline.
Several stakeholders provided comment regarding the maximum
technological efficiency levels presented in the NOPR.
PG&E recommended that DOE continue to update its product database
to ensure that max-tech levels are set appropriately. (PG&E and SDG&E,
No. 89 at p. 3-4) Manitowoc stated that examples of currently available
models that are near the max-tech levels are not generally
representative of the full range of models in each equipment class,
explaining that small-capacity ice makers can attain higher efficiency
levels than large-capacity ice makers built using the same package
size. (Manitowoc, No. 92 at p. 3) AHRI commented that the maximum
technologically feasible efficiency levels presented in the NOPR
analysis were overestimated by up to 13% for at least 10 equipment
classes. AHRI added that the FREEZE energy model has been proven
invalid through testing, citing two examples of testing to evaluate the
efficiency improvement associated with switching to a higher-EER
compressor in which the observed efficiency improvement was
significantly less than the NOPR projections of efficiency improvement
associated with compressor switching. (AHRI, No. 93 at p. 5-6)
In response to the comment provided by PGE DOE notes that it has
continued to update the product database with new data as it becomes
available.
In response to Manitowoc, DOE notes that its analysis has
considered multiple capacity levels for key classes. Also, although DOE
agrees that higher efficiency levels may be more difficult to attain by
higher-capacity ice makers, DOE has investigated the trend of
efficiency level as a function of harvest capacity and package size and
concluded that there are no consistent trends in the available data
that would indicate which capacities should be analyzed for each
specific package size. 79 FR at 14871-3 (March 17, 2014). DOE notes
that while Manitowoc's comment indicates that higher efficiency levels
may be easier to attain for a smaller-capacity unit in a given package
size, the comment does not indicate which classes and capacities in
DOE's analysis represent capacities for which attaining higher
efficiency would be so much easier that equipment with these
characteristics would not be representative of their classes. An
example review of the relationship of harvest capacity rate, efficiency
level, and package size in volume (cubic feet) is shown in Table IV.21
for IMH air-cooled batch ice makers. The data shown does not include
ice makers with proprietary evaporator technology, nor does it include
ice makers that produce large-size (gourmet) ice cubes. The data show
that higher efficiency levels do not necessarily correlate either with
larger package sizes or the smallest harvest capacity rates--the
maximum 20.7% efficiency level is associated with a relatively small
8.3 cubic foot volume and a 530 lb ice/24 hour capacity rate.
Table IV.21--Relationship Between Harvest Capacity Rate, Efficiency Level, and Volume for IMH Air-Cooled Batch
Ice Makers Between 300 and 600 lb Ice/24 Hours
----------------------------------------------------------------------------------------------------------------
Energy use Percent
Harvest capacity rate (lb ice/24 hours) (kWh/100 lb efficiency Volume (cu ft)
ice) level * (%)
----------------------------------------------------------------------------------------------------------------
305............................................................. 6.80 11.0 6.7
310............................................................. 6.80 10.5 6.7
335............................................................. 6.64 10.0 6.7
360............................................................. 6.45 10.0 6.7
370............................................................. 5.90 16.6 7.0
380............................................................. 6.70 4.2 7.0
404............................................................. 6.10 10.1 7.3
357............................................................. 6.30 12.4 8.3
358............................................................. 5.95 17.1 8.3
368............................................................. 6.10 14.0 8.3
[[Page 4683]]
448............................................................. 6.10 4.8 8.3
448............................................................. 6.10 4.8 8.3
530............................................................. 5.00 20.7 8.3
530............................................................. 5.00 20.7 8.3
366............................................................. 6.00 15.6 8.5
459............................................................. 5.80 9.2 8.5
590............................................................. 5.90 5.5 8.9
300............................................................. 6.20 19.3 9.1
316............................................................. 6.36 15.7 9.1
320............................................................. 6.20 17.4 9.1
335............................................................. 5.97 19.1 9.1
370............................................................. 5.94 16.1 9.1
388............................................................. 6.00 13.3 9.1
390............................................................. 5.79 16.2 9.1
405............................................................. 5.80 14.4 9.1
410............................................................. 5.73 14.9 9.1
485............................................................. 6.00 5.6 9.1
490............................................................. 5.41 14.8 9.1
538............................................................. 6.00 4.7 9.1
555............................................................. 5.29 15.8 9.1
300............................................................. 6.50 15.4 9.6
380............................................................. 5.80 17.0 9.6
400............................................................. 6.40 6.2 9.6
528............................................................. 6.00 4.9 9.6
486............................................................. 5.30 16.6 17.6
----------------------------------------------------------------------------------------------------------------
* Percent energy use less than baseline energy use.
In response to AHRI, DOE notes that modifications have been made to
the engineering analysis to incorporate new data provided by interested
parties regarding the expected energy savings resulting from the
incorporation of design options. These modifications have resulted in a
reevaluation of max-tech levels for several equipment classes. See
chapter 5 of the final rule TSD for the results of the analyses and a
list of technologies included in max-tech equipment. Table IV.22 below
compares the max-tech levels of AHRI's NOPR comment to DOE's NOPR phase
max-tech levels, the maximum available efficiency levels, and the max-
tech levels of DOE's final rule analysis. The final-rule max-tech
levels are higher than the AHRI max-tech levels in only three classes,
IMH-W-Small-B, IMH-A-Small-B, and RCU-NRC-Large-B1 (1,500 lb ice/24
hour representative capacity). AHRI's comment mentions that certain
design options were removed from consideration as part of AHRI's
``correction'' of the DOE analysis. These design option changes are
described in Exhibit 3 of the comment. (AHRI, No. 93 at p. 24).
For IMH-A-Small-B, AHRI eliminated ``increase in evaporator area by
51% (with chassis growth)''. Efficiency improvement of 12.8 percent is
attributed to this design option in the final rule analysis, accounting
for more than the 7 percent difference between the DOE and AHRI max-
tech projections. For IMH-W-Small-B, AHRI similarly eliminated design
options involving increase in chassis size. AHRI indicated that design
options that increase package size should not be considered for these
classes because they include 22-inch units, which AHRI claimed to be
space-constrained. DOE retained consideration of these design options
for the final rule analysis, conducting additional analysis for 22-inch
wide models, and considering the installation cost impacts of the
larger chassis size for a representative population of units where some
rebuilding of the surrounding space would be required to accommodate
the larger size (see section IV.G.2) DOE considers package size
increase a potential for added cost, rather than a reduction in utility
that must be screened out of the analysis, since added cost is not one
of the four screening criteria. (see 10 CFR 430, subpart C, appendix A,
section (4)(a)(4)) For RCU-NRC-Large-B1, DOE's final rule max-tech
efficiency level is only 1 percent higher than the AHRI max-tech level,
and the maximum available efficiency levels is equal to the AHRI max-
tech level. For this class, AHRI modified the performance improvement
associated with higher-EER compressors. DOE's analysis uses ice maker
efficiency improvement attributable to compressor improvement slightly
better than assumed by AHRI--DOE's estimate is based on a larger
dataset of test data, evaluating the ice maker efficiency improvement
possible by using improved compressors.
Table IV.22--Comparison of AHRI Max Tech Levels With DOE NOPR and Final Rule Max Tech Levels
--------------------------------------------------------------------------------------------------------------------------------------------------------
Representative DOE NOPR max tech DOE final rule
Equipment class capacity (lb ice/ AHRI max tech (% (% below Max available (% max tech (%
24 hours) below baseline) baseline) below baseline) below baseline)
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Small-B............................................ 300 18 29 19 24
[[Page 4684]]
IMH-W-Med-B.............................................. 850 18 21 14 18
IMH-W-Large-B-1.......................................... 1500 15 17 5 8
IMH-W-Large-B-2.......................................... 2600 14 15 2.5 7
IMH-A-Small-B............................................ 300 19 31 19 26
IMH-A-Large-B-1.......................................... 800 25 29 16 16
IMH-A-Large-B-2.......................................... 1500 18 20 6 12
RCU-NRC-Large-B-1........................................ 1500 16 21 16 17
RCU-NRC-Large-B-2........................................ 2400 18 21 15 14
SCU-W-Large-B............................................ 300 30 30 28 30
SCU-A-Small-B............................................ 110 39 39 31 33
SCU-A-Large-B............................................ 200 35 35 26 29
IMH-A-Small-C............................................ 310 26 31 28 26
IMH-A-Large-C............................................ 820 30 30 36 23
SCU-A-Small-C............................................ 110 28 28 24 27
--------------------------------------------------------------------------------------------------------------------------------------------------------
In response to AHRI's comment that the FREEZE model has been proven
to be invalid, DOE notes that this comment is based on tests
illustrating the ice maker efficiency improvement associated with two
examples of switch to higher-EER compressors. AHRI points to only one
of the design options considered in the DOE's analysis, for which DOE
updated its analysis. DOE has modified its treatment of compressors in
the analysis, basing the calculation of ice maker efficiency
improvement on test data provided both by the AHRI comment and other
data provided confidentially by manufacturers to DOE's contractor.
Based on the data DOE reviewed, the ice maker energy use reduction
associated with improvement in compressor EER averages 57 percent of
the compressor energy use reduction expected based on the EER
improvement--DOE used this ratio for its analysis of batch ice makers
for the final rule. Hence, this particular issue with the engineering
analysis has been addressed through changes in DOE's approach in both
the NODA and final rule analyses.
3. Design Options
After conducting the screening analysis and removing from
consideration the technologies described above, DOE considered the
inclusion of the remaining technologies as design options in the final
rule engineering analysis. The technologies that were considered in the
engineering analysis are listed in Table IV.23, with indication of the
equipment classes to which they apply.
[GRAPHIC] [TIFF OMITTED] TR28JA15.003
a. Design Options That Need Cabinet Growth
Some of the design options considered by DOE in its technology
assessment could require an increased cabinet size. Examples of such
design options include increasing the surface area of the evaporator or
condenser, or both. Larger heat exchangers would enable the refrigerant
circuit to operate with an increased evaporating temperature and a
decreased
[[Page 4685]]
condensing temperature, thus reducing the temperature lift imposed on
the refrigeration system and hence the compressor power input. In some
cases the added refrigerant charge associated with increasing heat
exchanger size could also necessitate the installation of a refrigerant
receiver to ensure proper refrigerant charge management in all
operating conditions for which the unit is designed, thus increasing
the need for larger cabinet size.
In the preliminary analysis, DOE did not consider design options
that increase cabinet size. However, in the NOPR DOE changed the
approach and considered design options that increase cabinet size for
certain equipment classes: IMH-W-Small-B, IMH-A-Small-B, IMH-A-Large-B
(800 lb ice/24 hours representative capacity), and IMH-A-Small-C. DOE
only applied these design options for those equipment classes where the
representative baseline unit had space to grow relative to the largest
units on the market. DOE also considered size increase for the remote
condensers of RCU classes.
In response to the March 2014 NOPR, several manufacturers noted
that the size of icemakers is limited in certain applications.
Manitowoc commented that not all end users can accept larger or taller
ice-making cabinets. (Manitowoc, Public Meeting Transcript, No. 70 at
p. 133) Ice-O-Matic commented that customers want ice machines that are
able to produce more ice in a smaller physical space and that such ice
makers will be difficult to make if standards necessitate design
options that require cabinet growth. (Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 29-31)
Scotsman and AHRI both noted that cabinet size increases would
require users to either enlarge the space in the kitchen to accommodate
a larger unit or to repair older ice makers rather than buying new ones
or to make due with a smaller capacity ice maker. (AHRI, No. 93 at p.
7-8; Scotsman, Public Meeting Transcript, No. 70 at p. 126-127)
Manitowoc, Ice-O-Matic, and AHRI each stated that incorporating design
options that may increase the size of automatic commercial ice makers
will increase the likelihood that consumers refurbish rather than
replace their existing units. (Manitowoc, Public Meeting Transcript,
No. 70 at p. 129-130; Ice-O-Matic, Public Meeting Transcript, No. 70 at
p. 32-33; AHRI, No. 93 at p. 7-8) Scotsman, Manitowoc and Follett all
agreed that large ice makers would have an impact in installation
costs. (Scotsman, No. 85 at p. 5b-6b; Manitowoc, No. 92 at p. 3;
Follett, No. 84 at p. 6) Follett commented that maintenance costs will
increase because larger components will reduce serviceability and
energy-efficient components, such as a lower horsepower auger motor,
may not be as robust. (Follet, No. 70 at p. 132-133)
AHRI commented that design options which increase chassis size
should not be considered for IMH-A-Small-B, IMH-A-Large-B, IMH-W-Small-
B, and IMH-W-Med-B classes, as 22-inch units wide units account for 18%
of all ice makers sold in the US. AHRI added that if design options
which increase cabinet size are not screened out for these product
classes, there will likely be an adverse impact on product
availability. (AHRI, No. 93 at p. 4)
In contrast, PGE/SDG&E commented that they support DOE's decision
to include in the engineering analysis design options that increase
chassis size. (PG&E and SDG&E, No. 89 at p. 3) The Joint Commenters
expressed their belief that DOE has appropriately considered size
increases in their engineering analysis and that those customers who
have smaller units today could purchase a taller unit with the same
capacity, a smaller-capacity unit, or two smaller-capacity units.
(Joint Commenters, No. 87 at p. 3)
In response to the NODA analysis, CA IOU stated their support of
DOE including technically (DOE interprets this to mean technologically)
feasible design options that may increase chassis sizes in certain
cases. (CA IOU, No. 129 at p. 2)
DOE recognizes that the size of ice makers is limited in certain
applications. DOE notes that many of the equipment classes analyzed do
not require any cabinet growth to reach higher efficiency levels. DOE
considered design options involving package size increase for IMH-A-
Large-B, IMH-A-Small-B, and IMH-W-Med units. For the final rule
analyses, DOE did not consider design options which necessitate a
cabinet size increase for IMH-A-Small-C units. DOE adjusted the
analysis of installation costs to consider the impact of added costs
associated with renovation to accommodate size increase for the few
equipment classes for which DOE did consider size increase. The life
cycle cost analysis, described in section IV.G.2 details how these
added installation costs were considered in the analysis.
Table IV.24 lists the equipment classes for which DOE considered
design options that involve increase in chassis size in the final rule
analysis.
Table IV.24--Analyzed Equipment Classes Where DOE Analyzed Size-
Increasing Design Options in the Final Rule Analysis
------------------------------------------------------------------------
Harvest capacity Used design options
Unit lb ice/24 hours that increased size?
------------------------------------------------------------------------
IMH-A-Small-B................. 300 Yes.
IMH-A-Large-B (med)........... 800 Yes.
IMH-A-Large-B (large)......... 1,500 No.
IMH-W-Small-B................. 300 Yes.
IMH-W-Med-B................... 850 No.
IMH-W-Large-B................. 2,600 No.
RCU-XXX-Large-B (med)......... 1,500 For the remote
condenser, but not
for the ice-making
head.
RCU-XXX-Large-B (large)....... 2,400 For the remote
condenser, but not
for the ice-making
head.
SCU-A-Small-B................. 110 No.
SCU-A-Large-B................. 200 No.
SCU-W-Large-B................. 300 No.
IMH-A-Small-C................. 310 No.
IMH-A-Large-C (med)........... 820 No.
SCU-A-Small-C................. 110 No.
------------------------------------------------------------------------
Note: ``XXX'' refers to ``RC'' or ``NRC'' for each of the entries with
``XXX''.
[[Page 4686]]
b. Improved Condenser Performance
During the NOPR analysis, DOE considered size increase for the
condenser to reduce condensing temperature and compressor power input.
DOE requested comment on use of this design option and on the
difficulty of implementing it in ice makers with size constraints.
Follet commented that 10[emsp14][deg]F is the practical limit for
the temperature difference between the ambient air and the hot gas in
the condenser. Follet added that it is possible to increase the surface
area, but either no meaningful efficiency is gained, or the size of the
condenser would have to increase to the point that it would not fit
into tight spaces. (Follet, No. 84 at p. 5)
DOE did not consider any condenser sizes that would result in
condensing temperatures as close as 10[emsp14][deg]F to the ambient
temperatures for air-cooled icemakers.
Stakeholders AHRI, Hoshizaki, Follet, and Ice-O-Matic noted that
improved condenser performance would likely require an increase in
cabinet size. (AHRI, No. 93 at p. 4; Hoshizaki, Public Meeting
Transcript, No. 70 at p. 128-129; Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 32-33; Follet, No. 84 at p. 5)
In response to concerns about the potential need to increase
cabinet size to make space for larger condensers, DOE agrees that
increasing condenser size may require also increasing cabinet size. DOE
has limited cabinet size increases to just three equipment classes,
IMH-A-Large-B, IMH-A-Small-B, and IMH-W-Small-B. Furthermore, the
specific size increases considered for these ice makers do not involve
size increase beyond the size of ice makers that are currently being
sold. The specific size increases considered are presented in Chapter 5
of the TSD. In addition, the life cycle cost analysis considers
additional installation cost associated with a proportion of ice makers
sold as replacements that, with the new larger sizes, will not fit in
the existing spaces where the old ice makers are located (see section
IV.G.2.a).
Manitowoc commented regarding condenser size increase for water-
cooled ice makers that increasing water-cooled surface area can reduce
the condensing temperature and cause the ice machine to be unable to
harvest the ice at low inlet water temperature conditions, which
affects the performance of models in northern regions. (Manitowoc,
Public Meeting Transcript, No. 70 at p. 108-110)
DOE is aware that increasing condenser surface area may have an
impact on the ice machine's ability to harvest ice. As discussed in the
NOPR, DOE generally avoided consideration of very low condensing
temperatures in its analysis, using 101[emsp14][deg]F as a guideline
lower limit. The analysis also considered the increase in harvest cycle
energy use--Section IV.D.4 describes how the longer harvest times were
addressed in the engineering analysis.
Manitowoc noted that the NODA EL3 level for the RCU-NRC-B2
equipment class assumes a 19-inch increase in condenser width with an
additional condenser row. Manitowoc asserted that an increase this
large could lead to significant refrigerant charge issues. Therefore,
Manitowoc suggested that NODA EL2 be selected for this equipment class.
(Manitowoc, No. 126 at p. 2)
In the final rule DOE modified the engineering analysis for this
class and has eliminated one of the two condenser size increase steps
in the final rule engineering analysis. DOE notes that the final
condenser size is still smaller on the basis of refrigerant volume per
harvest capacity rate than the largest remote condenser for an RCU ice
maker observed in DOE's review of units purchased for reverse
engineering. Therefore, DOE has confidence that the refrigerant
management challenges are manageable for the maximum condenser size
considered in the analysis.
Manitowoc also noted that adding a condenser row in the SCU-A-
Small-B class may not be possible due to the small volume available in
the compact chassis required for these models. Similarly, a 9''
increase in condenser width for the SCU-A-Large-B may be unrealistic.
(Manitowoc, No. 126 at p. 2) In selecting these design options, DOE
reviewed the spatial constraints and condenser sizes within both
reverse-engineered units used as the basis for energy use calculations
for these classes. While the space underneath the ice storage bins of
these units is limited in height, there is sufficient room for the
width and depth increases that DOE considered. Based on data gathered
from these teardowns, DOE concluded that these condenser size design
options were feasible for these units.
c. Compressors
Several interested parties provided comment regarding the
feasibility of incorporating more efficient compressors in ACIMs. AHRI
urged DOE to reevaluate the feasibility of implementing more efficient
compressors into the IMH-A-Small-C product class, which Follett has
found are too small to fit larger compressors. (AHRI, No. 93 at p. 4)
Follett also individually commented that they independently evaluated a
more efficient compressor for IMH-A-Small-C and that its size made it
infeasible given the restrictions of the Follett chassis. (Follet, No.
84 at p. 8)
In response to AHRI and Follet's assertion that higher efficiency
compressors may not fit within the chassis of IMH-A-Small-C, DOE's
analysis of this class was based on use of a Copeland RST45C1E-CAV
compressor, which is no larger than the compressor used in the model
upon which DOE based the analysis. Hence, DOE concluded that use of
this higher-efficiency compressor would not require an increase in the
package size. DOE notes that it did avoid consideration of the highest-
efficiency compressors for 22-inch wide classes when these compressors
clearly are physically larger than the available space allows. In
particular, DOE did not consider use of high-efficiency Bristol
compressor in these cases, because Bristol compressors are generally
larger than other available compressors.
Several commenters, including AHRI, NEEA, Danfoss, and Ice-O-Matic
each noted that the harvest process of automatic commercial ice makers
needs to be considered when evaluating increased compressor efficiency
as a design option. (AHRI, No. 93 at p. 4; NEEA, No. 91 at p.1;
Danfoss, Public Meeting Transcript, No. 70 at p. 152-153; Ice-O-Matic,
Public Meeting Transcript, No. 70 at p. 160-161) Danfoss and Ice-O-
Matic commented that ice machines differ significantly from other
compressor-based applications in that, when harvesting ice, it is
desirable to have a less efficient compressor because the waste heat
helps harvest the ice. (Danfoss, Public Meeting Transcript, No. 70 at
p. 152-153; Ice-O-Matic, Public Meeting Transcript, No. 70 at p. 160-
161)
In response, DOE has adjusted its calculation of energy savings
associated with improved compressor efficiency in the NODA and final
rule analyses. Specifically, DOE considered all available data for
tests involving compressor replacement for batch ice makers. This
included the two examples provided in AHRI's NOPR comment. (AHRI, No.
93 at pp. 25-30) It also included information provided confidentially
to DOE's contractor. DOE reviewed the data to determine if it could be
used to robustly predict any trends of ice maker performance impacts
compared with compressor EER improvements that might vary as a function
of key parameters such as ice maker class, capacity, compressor
manufacturer, but no such trends were
[[Page 4687]]
evident. DOE used the data to develop an estimate of ice maker energy
use reduction as a fraction of compressor energy use reduction--this
value averaged 0.57 for the data set. DOE used this factor to calculate
ice maker energy use reduction for all of the batch analyses for the
NODA and final rule. Applying this approach significantly reduced the
energy savings associated with improved-EER compressors for batch ice
makers in the NODA and final rule analyses.
Howe commented that variable-speed compressors are most effective
at saving energy under part-load conditions, which is not taken into
account in the DOE test procedure. Therefore, such components would be
operating at or near maximum capacity during DOE tests, thus canceling
their positive measurable benefit. (Howe, No. 88 at p. 1)
In response to Howe's comment regarding variable speed compressors,
DOE did not consider the use of variable-speed compressors in the
analysis.
Several interested parties submitted additional concerns about the
feasibility of implementing design options involving increases in
compressor efficiency. NAFEM commented that high-efficiency compressor
motors for automatic commercial ice makers will not be available for
the foreseeable future and that the investment required was not
available for products with shipments as low as automatic commercial
ice makers (150,000/year) and that DOE must account for their
unavailability in its analysis. (NAFEM, No. 82 at p. 10)
In response, DOE considered only compressors that are currently
offered for use by compressor manufacturers. All of the compressors
considered in the analysis are currently commercially available and are
acceptable for use in ice makers as indicated by manufacturers in
confidential discussions with DOE's contractor. Hence, DOE does not
need to consider the development of new compressors with higher-
efficiency motors. The compressors considered in the analysis are
listed in the compressor database. (Compressor Database, No. 135)
In response to the NODA, Manitowoc noted that the RCU-NRC-B1
equipment class assumes an increase in compressor EER of 20% which
Manitowoc stated could not be achieved without resorting to radical
design changes and possibly the use of permanent magnet motor
technology. (Manitowoc, No. 126 at p. 3) Additionally, Manitowoc stated
that for SCU-A-Small-B and SCU-Large-B, increases in compressor EER of
40% and 25%, respectively, are unlikely to be achieved. (Manitowoc, No.
126 at p. 2)
For the RCU-NRC-Large-B-1 class, DOE based the analysis on a unit
with a compressor having a rated EER of 7.16 Btu/Wh. In order to
represent baseline performance, a less-efficient available compressor
was used in the analysis. For the final rule, DOE modified its analysis
to reflect a lower efficiency level for the unit which is the basis of
the analysis. Hence, DOE has reduced the compressor EER improvement
considered for this class from 20 percent to 10.7 percent.
For the SCU-A-Small-B class, DOE based the analysis on an ice maker
having a compressor with a rated EER of 3.3 Btu/Wh. The analysis
considered use of an available compressor having a rated EER of 4.6
Btu/Wh, a 39 percent improvement. Compressors having both these levels
of EER exist, and hence the 39 percent improvement in EER from 3.3 to
4.6 can be achieved.
For the SCU-A-Large-B class, DOE based the analysis on an ice maker
model having a compressor with a rated EER of 4.68 Btu/Wh. DOE modeled
the baseline by considering a lower EER of 4.23 Btu/Wh. Compressors
within the appropriate capacity range at this EER level do exist. The
highest-EER considered for this analysis is 5.2 Btu/Wh, which is
achieved by an available compressor of appropriate capacity--this
represents 23 percent improvement in EER, slightly less than the cited
25 percent. Compressors having both these levels of EER considered in
the analysis exist, and hence the 23 percent improvement in EER from
4.23 to 5.2 can be achieved.
In response to the NODA analysis for equipment class SCU-A-Small-C,
AHRI noted that DOE increased the ``percent energy use reduction'' from
8.5% in the NOPR to 10.91% in the NODA for the same design option,
``Changed compressor EER from 4.7 to 5.5''. AHRI requested that DOE
provide justification for this change. (AHRI, No. 128 at p.3) In the
NODA, DOE had calculated continuous ice maker percentage savings as 75%
of the compressor energy savings (0.75 x (1-4.7/5.5) = 0.109), rather
than using the results of the FREEZE model to represent the compressor
energy savings. However, the ice maker upon which the SCU-A-Small-C
analysis was based has a greater proportion of auger and fan energy use
than typical continuous units. Hence, DOE agrees that an increase in
the savings projection to 10.9% is unrealistic, and has changed the
projection.
For the final rule analysis, DOE also did not use the FREEZE model,
and instead assumed that the compressor energy use reduction would be
5% less than would be expected, based on the EER increase. The
compressor energy use for the unit started at 72% of unit energy use,
and the design options considered prior to consideration of the
improved-EER compressor already reduced energy use to 90.7% of baseline
energy use. Hence, DOE recalculated the savings for this design option
as 0.95 x (1-4.7/5.5) x 0.72 x 0.907 = 0.09 = 9%.
d. Evaporator
Follett commented that increasing the length or width of continuous
type evaporators would increase cabinet size. (Follet, Public Meeting
Transcript, No. 70 at p. 90-91) Follett also commented that increasing
the height of the continuous type evaporator is not feasible because,
in 75% of Follett's automatic commercial ice makers, the evaporator is
horizontal. Therefore, any evaporator growth would increase the
icemaker footprint so that it could no longer fit on standard beverage
dispensers. (Follett, No. 84 at p. 5-6)
DOE notes that it did not consider evaporator size increase as a
design option for continuous ice makers in the final rule engineering
analysis.
In response to the NODA, AHRI noted that IMH-W-Small-C units
typically use the same chassis as their IMH-A-Small-B counterparts and
should also be considered as space constrained units. Specifically,
AHRI recommended screening out the increased evaporator size for this
product class on the basis that the chassis could not withstand the
corresponding 4-inch increase in width. AHRI added that if evaporator
size increase option is kept for IMH-W-Small-C units, a more realistic
cost must be associated with this design option. (AHRI, No. 128 at p.
2)
In response to AHRI's comment, DOE notes that the typical use of
the same cabinet as IMH-A-Small-B does not mean there is no possible
cabinet size increase. Nevertheless DOE has eliminated this design
option step from the analysis for the IMH-A-Small-C. The evaporator
size increase was considered in the NOPR analysis in conjunction with a
condenser size increase. In the final rule analysis, this step in the
analysis now considers only the condenser size increase.
AHRI stated in its NODA comments that an 18 percent size increase
in evaporator area cannot reasonably be implemented in 22-inch IMH-A-
Small-B units. (AHRI, No. 128 at p. 2). DOE developed its 22-inch IMH-
A-Small-B analysis by removing from the 30-inch
[[Page 4688]]
chassis analysis for IMH-A-Small-B those design options that would not
fit in a 22-inch chassis. The baseline evaporator used in the model
upon which DOE based this analysis has a plate area that is relatively
small. Hence, the 18 percent size increase can fit within the chassis
of a 22-inch unit. In fact, the maximum-available 22-inch unit of this
class has an evaporator that is somewhat larger than the largest
evaporator size considered for the analysis. Hence, DOE concludes that
it did not consider excessive increase in evaporator size for the 22-
inch IMH-A-Small-B analysis.
In response to the NODA, Manitowoc stated that for IMH-A-Small-B
units, a 51% increase in evaporator surface area is not always possible
in the chassis sizes used in the industry and concluded that the max
efficiency level that should be considered is EL3. (Manitowoc, No. 126
at p. 1)
DOE agrees that the design option mentioned by Manitowoc, a 51%
increase in evaporator surface area for IMH-A-Small-B units would
require a growth in cabinet size. Consequently, DOE considered such a
growth in the engineering analysis. DOE notes that the NODA TSL 3
efficiency level for this class, 18% less energy than baseline, can be
achieved with an evaporator growth less than 51%--DOE estimates that
this would require evaporator size growth of 38%.
Manitowoc stated that the IMH-small class would likely require
chassis growth to add evaporator area. (Manitowoc, No. 126 at p. 2).
DOE assumes that this refers to the IMH-W-Small-B class and agrees that
some increase in chassis size may be required to support increases in
evaporator size. DOE notes that IMH-W-Small-B is one of the classes for
which DOE considered increase in chassis size.
e. Interconnectedness of Automatic Commercial Ice Maker System
Several commenters noted that the addition of a certain design
option may necessitate an alteration in the remaining automatic
commercial ice maker components. AHRI stated their concern with DOE's
component analysis, noting that a change in one component impacts other
components and therefore the entire price and efficiency of the entire
automatic commercial ice maker system. (AHRI, No. 128 at p. 2)
Similarly, Scotsman stated that the manufacture product cost increase
estimates do not account for system impacts when components are
changed. In most cases it is inaccurate to estimate product cost
changes by specific component as changing any component within the
refrigeration system will require changes to other components in order
to optimize performance efficiency. (Scotsman, No. 125 at p. 2)
Similarly, Howe commented that component efficiency increases are not
additive and not necessarily proportional when used in combination.
(Howe, No. 88 at p. 2)
As explained in the NOPR, DOE had attempted to conduct an
efficiency-level analysis rather than a design-option approach.
However, the efficiency-level analysis did not produce consistent
results, in some cases indicating that higher-efficiency units are less
expensive. Therefore, DOE went forward with the design option approach
and solicited comments from interested parties regarding the impact a
specific design option may have on the entire system. DOE's contractor
received some information regarding the potentially higher costs
associated with change of some components, for which it may have
underestimated overall cost increase in the NOPR phase--this
information has been incorporated into the final rule analysis.
However, absent more specific information regarding these interactions,
DOE cannot speculate on other changes that may have been appropriate to
address this issue.
Manitowoc commented that putting a larger evaporator in an ice
machine would increase refrigerant charge, thus necessitating an
accumulator, or rendering a compressor unreliable during harvest. Such
a change would also increase the mass of the evaporator, thus requiring
more energy to heat it up and cool it back down. (Manitowoc, Public
Meeting Transcript, No. 70 at p. 142-143)
DOE has not considered evaporator sizes (on the basis of evaporator
size per ice maker capacity in lb ice/24 hours) larger than those of
ice makers on the market. DOE has not observed use of accumulators and
hence concludes that the evaporator sizes considered would not require
one. While Manitowoc commented in the NOPR public meeting on the
potential for added harvest time or harvest energy use for larger
evaporators, they did not provide details in written comments showing
how this effect might impact savings associated with larger
evaporators. DOE notes that a larger evaporator would operate with
warmer evaporating temperature during the freeze cycle, and this effect
would reduce the heat required to warm the evaporator during the
harvest cycle. Without data to quantify this effect, DOE's analysis
assumed that harvest energy use would scale proportionally with
evaporator area. Hence, the increase in mass of the evaporator has been
accounted for in the estimation of the energy use reduction associated
with the design option.
Follett commented that the evaporator, auger motor, and compressor
must all be sized to balance one another and that these components
cannot easily be swapped out for other off-the-shelf components.
(Follett, No. 84 at p. 5) Follett noted that increasing evaporator
diameter is not feasible because it will increase the required torque,
necessitating a larger motor that will draw more power and negate any
efficiency gains. (Follet, No. 84 at p. 6)
DOE is no longer considering evaporator size increase as a design
option for continuous ice makers. However, DOE notes that the
engineering analysis has attempted to consider the interconnectedness
of the system components wherever possible. For example, for air cooled
condenser growth, fan power was increased to maintain a constant
airflow through a larger condenser.
Hoshizaki commented that there is a lot of trial and error involved
in pairing compressors with condensers while maintaining machine
reliability. (Hoshizaki, Public Meeting Transcript, No. 70 at p. 159-
160)
DOE realizes that there may be trial and error when pairing
components. DOE solicited feedback from manufactures regarding the
appropriateness of the use of specific compressors in the analysis. DOE
did not identify any specific limitations in compressor/condenser
pairings that it considered in its analysis in any comments or in
interviews with manufacturers.
4. Cost Assessment Methodology
In this rulemaking, DOE has adopted a combined efficiency level,
design option, and reverse engineering approaches to develop cost-
efficiency curves. To support this effort, DOE developed manufacturing
cost models based heavily on reverse engineering of products to create
a baseline MPC. DOE estimated the energy use of different design
configurations using an energy model with input data based on reverse
engineering, automatic commercial ice maker performance ratings, and
test data. DOE combined the manufacturing cost and energy modeling to
develop cost-efficiency curves for automatic commercial ice maker
equipment based to the extent possible on baseline-efficiency equipment
selected to represent their equipment classes (in some cases, analyses
were based on equipment with efficiency levels higher than baseline).
Next, DOE derived
[[Page 4689]]
manufacturer markups using publicly available automatic commercial ice
maker industry financial data, in conjunction with manufacturer
feedback. The markups were used to convert the MPC-based cost-
efficiency curves into Manufacturer Selling Price (MSP)-based curves.
The engineering analyses are summarized in an ``Engineering
Results'' spreadsheet, developed initially for the NOPR phase (NOPR
Engineering Results Spreadsheet, No. 59). This document was modified
for the NODA (Engineering Analysis Spreadsheet--NODA, No. 112) and
subsequently for the final rule (Final Rule Engineering Analysis
Spreadsheet, No. 134)
Stakeholder comments regarding DOE's NOPR and NODA engineering
analyses addressed the following broad areas:
1. Estimated costs in many cases were lower than manufacturers'
actual costs.
2. Estimated efficiency benefits of many modeled design options
were greater than the actual benefits, according to manufacturers'
experience with equipment development.
3. DOE should validate its energy use model based on comparison
with actual equipment test data.
These topics are addressed in greater detail in the sections below.
a. Manufacturing Cost
In response to the manufacturer costs presented in the NOPR,
several stakeholders indicated that the incremental costs presented in
the NOPR were optimistic. Specifically, AHRI, Follet, Manitowoc, and
Danfoss stated the belief that DOE underestimated the incremental costs
of its proposed design options. (AHRI, No. 93 at p. 4; Follet, No. 84
at p. 5; Danfoss, No. 72 at p. 3; Manitowoc, No. 98 at p. 1-2)
Scotsman commented that their data on the efficiency and costs
associated with compressor upgrade, BLDC motors, larger heat
exchangers, and drain water heat exchangers do not match the
assumptions used by DOE in its analysis. (Scotsman, No. 85 at p. 4b)
Manitowoc commented that DOE significantly underestimates the cost
associated with heat exchanger growth, higher compressor EER, and high-
efficiency fan and pump motors. (Manitowoc, No. 98 at p. 1-2) Manitowoc
also noted that their costs were not consistent with those found in the
TSD, particularly in cases involving evaporator or cabinet growth
(Manitowoc, Public Meeting Transcript, No. 70 at p. 116-117)
DOE has revised and updated its analysis based on data provided in
comments and made available through non-disclosure agreements. These
updates included changes in its approach to calculating the energy use
associated with groups of design options, changes in inputs for
calculations of energy use, and changes in calculated equipment
manufacturing cost. Comments related to the manufacturing costs of
specific design options are described in the sections below.
NAFEM and Hoshizaki stated that the cost curves were not analyzed
to demonstrate what can be achieved in five years. (NAFEM, No. 123 at
p. 2; Hoshizaki, No. 123 at p. 1)
In response to NAFEM and Hoshizaki's comment, DOE notes that the
costs in the cost curves are intended to be representative of today's
technology and current market prices.
Compressor Costs
AHRI, Danfoss, and Hoshizaki stated that DOE's assumption that a
10% compressor efficiency increase could be achieved for a 5% price
increase is flawed. (AHRI, Public Meeting Transcript, No. 70 at p. 20-
21; Danfoss, No. 72 at p. 3; Hoshizaki, No. 86 at p. 9) AHRI and
Danfoss stated that a more realistic assumption would be a 1-2%
efficiency improvement for a 5% price increase. (Danfoss, No. 72 at p.
3; AHRI, Public Meeting Transcript, No. 70 at p. 20-21) AHRI and NAFEM
both requested that the relationship between cost and compressor EER
should be corrected to reflect the approach adopted by the final CRE
rulemaking. (AHRI, No. 93 at p. 15; NAFEM, No. 82 at p. 4-5) Follet
also asserted that it is unrealistic to assume that the full efficiency
gain of a more efficient compressor will be realized at the costs
assumed by DOE in the NOPR. (Follet, No. 84 at p. 5) In response to the
NODA, AHRI stated that there was no explanation as to why the
compressor costs changed as compared to the NOPR. AHRI noted that the
NODA compressor costs were still not consistent with the approach used
in the CRE rulemaking. (AHRI, No. 128 at p. 2)
DOE maintains its position that the cost-EER relationship used in
the CRE rulemaking was based on future improvements over existing EER
levels. For example, the CRE final rule indicates that ``manufacturers
and consumers expressed concern over DOE's assumptions regarding the
advances in compressor technology anticipated before the compliance
date.'' 79 FR 17726, 17760 (March 28, 2014). Compressor suppliers and
OEMs commented that, ``if a 10% compressor efficiency improvement were
possible for a 5% cost increase, then it is most likely that
manufacturers would have already adopted this technology''. Id. The
statement implies that manufacturers have not adopted the technology.
In the automatic commercial ice maker NOPR public meeting, Danfoss, a
compressor supplier, commented, ``these are mature technologies.
They've been around 50 or 60 years. If that sort of efficiency
improvement could be made available, it would have . . . we would have
already done it.'' The comments insinuate that DOE was contemplating
use of a technology that is not available and that the compressor
manufacturers have not used. For the automatic commercial ice maker
analysis, DOE did not consider future technologies. Rather, it
considered only compressor options that are currently being offered by
compressor suppliers. In some cases, baseline ice makers are using
compressors with relatively low efficiencies compared to the levels
that are available. It is for these cases that DOE has been projecting
the possibility of large potential for compressor efficiency
improvements. DOE has requested compressor cost data that would allow
evaluation of the relationship between actual prices paid by automatic
commercial ice maker manufacturers for the compressors and the EER
levels of the compressors, indicating that this data might be provided
confidentially to DOE's contractor. However, sufficient cost data to
allow a regression analysis to determine the efficiency-cost
relationship has not been made available. Based on limited data
supplied confidentially to DOE's contractor during the NOPR phase, DOE
initially concluded that cost does not vary significantly with EER. In
addition, DOE received some feedback during interviews with
manufacturers that the 10% improvement for 5% cost relationship is
reasonable. DOE at that time adopted this relationship in order to
avoid projecting zero cost increase associated with EER increase.
Nevertheless, DOE has modified its approach to calculating
improvement in compressor efficiency to consider the stakeholders'
comments. The analysis calculates the cost associated with compressor
EER improvement in two ways and uses the higher of these costs. The
first approach is the 10% improvement for 5% cost used in the NOPR
analysis. The second approach applies the 5% cost associated with the
[[Page 4690]]
2% improvement that the commenters cited, which DOE applied to the
analysis as if the last 2% of compressor efficiency improvement is
future efficiency improvement that would cost the cited 5%. For
example, if the compressor efficiency improvement is 10%, this approach
treated the first 8% of efficiency improvement to be associated with
currently available compressors with no cost differences, and the last
2% (from 8% to 10% improvement) as being associated with future
compressor improvement with a 5% cost premium.
Follett disputed the NOPR engineering result that showed a 20%
decrease in energy use at a cost of $61 for the IMH-A-Large-C class.
Follet noted that at an incremental cost of $60, they tested a unit
utilizing an ECM motor and a compressor with a 5% increase in
efficiency, but were only able to achieve a 9% decrease in energy use.
(Follet, No. 84 at p. 8) AHRI also noted this work, indicating that
Follett experienced less than half the efficiency gain predicted by DOE
in the NOPR when switching from an SPM to an ECM motor and using a
compressor with a 5% higher EER. AHRI further noted that, while DOE's
analysis considered a 24% improvement in compressor EER, the best
compressor that Follett was able to find improved the EER only 5%.
(AHRI, No. 93 at p. 4)
DOE notes that these comments do not indicate the initial energy
use of the tested unit, only that the 9 percent efficiency improvement
was insufficient to attain the NOPR-proposed efficiency level. Further,
the comments do not indicate the initial EER of the compressor used in
the Follett product. Since the NOPR phase, DOE has adjusted both its
energy modeling as well as its cost estimates, so as to mitigate this
issue. Based on new data collected through the NODA and final rule
phases, DOE has completed new cost efficiency curves, such that the MSP
increase for the final rule analysis associated with a 20% decrease in
energy use for the IMH-A-Large-C class is $488. The increase is so
large because, for the final rule analysis, use of design options other
than a permanent magnet gear motor to power the auger increase
efficiency less than 20% (roughly 18%), and the estimated cost of the
higher-efficiency auger motor is very high. While it is difficult to
determine whether the analysis is fully consistent with Follett's test
data, DOE believes that its revised analysis sufficiently addresses
this issue (the cost per percent improvement for the analysis is now
$24/% ($488/20%), whereas the cost per percent improvement for
Follett's cited experience is $7/% ($60/9%)). DOE does note that this
Follett example does show that continuous ice machines experience
energy use reductions at least consistent with the compressor
efficiency improvements--Follett did not indicate the reduction in
motor input wattage when switching from the shaded pole to the ECM
motor, but if the ice maker energy use reduction for the motor change
was 5%, one would conclude that the energy use reduction for the
compressor change was 4%, or 80% of the 5% improvement in compressor
EER--this contrasts markedly with some of the information provided in
stakeholder comments about the relationship between batch ice maker
energy use and compressor EER improvement. (see, e.g., AHRI, No. 93 at
pp. 25-30)
Evaporator Costs
Hoshizaki and Manitowoc stated the DOE underestimated the cost of
increasing the evaporator size in the NOPR analysis, for both batch and
continuous ice makers. Specifically, regarding the 50% evaporator size
increase considered for the IMH-A-Small-B analysis, Hoshizaki commented
that a 50% increase in evaporator height would result in a 50% MPC
increase. (Hoshizaki, No. 86 at p. 9) For this design option, DOE
calculated a $48 cost increase to the initial evaporator cost of $88 in
the NOPR analysis. Manitowoc stated that the cost presented in the NOPR
for a 50% larger evaporator is half of what they would see as a
manufacturer. Manitowoc noted that this is partially because they only
make 4000-5000 models per year of a particular cabinet size and thus do
not have as much purchasing power as an appliance manufacturer.
(Manitowoc, Public Meeting Transcript, No. 70 at p. 171-174)
In the NODA and final rule analyses, DOE adjusted the costs related
to increasing the size of the evaporator. DOE received information from
manufacturers through non-disclosure agreements regarding the expected
costs associated with increasing the size of the evaporator and has
adjusted the analysis to reflect the new data. DOE's MPC increase
projection for the same evaporator size increase for the IMH-A-Small-B
class is now $101.
As noted in section IV.D.3.d, AHRI commented that a more realistic
cost estimate is required for the evaporator increase design option for
IMH-W-Small-C units as they often use the same chassis as their IMH-A-
Small counterparts. Specifically, AHRI stated that manufacturers have
conservatively estimated that a 17% increase in evaporator size should
be 117% percent of the original evaporator's cost. (AHRI, No. 128 at p.
2) DOE believes this comment may apply to the IMH-A-Small-C class
rather than IMH-W-Small-C, since the 17% evaporator growth was
considered in the NOPR analysis for the air-cooled class. In the NOPR
phase, DOE calculated an MPC increase of $153 for the evaporator size
increase and a condenser size increase considered in the same step of
the analysis. Seventeen percent of the $1,252 contribution to MPC of
the initial evaporator is $213.
DOE acknowledges that the 17% evaporator growth would require
chassis size increase for the specific model upon which the IMH-A-
Small-C analysis is based, if implemented by increasing the length of
the auger/evaporator. As noted previously, DOE modified the analysis
and is no longer considering evaporator size increases as a design
option for any continuous units, including IMH-W-Small-C.
In response to the NODA analysis, Hoshizaki, AHRI, Manitowoc, and
NAFEM stated that increasing the evaporator by 18% with no chassis
growth is not possible for 22-inch IMH-A-Small-B machines. (Hoshizaki,
No. 124 at p. 2; AHRI, No. 128 at p. 2; Manitowoc, No. 126 at p. 2;
NAFEM, No. 123 at p. 2) Hoshizaki added that such a change would
require tooling, panel changes, and kits to fit on the machine.
Hoshizaki and NAFEM noted that these changes would cost more than the
$34 stated in the NODA. (Hoshizaki, No. 124 at p. 2; NAFEM, No. 123 at
p. 2)
DOE reviewed the cabinet size of the representative 22-inch IMH-A-
Small-B unit and found that it had space for an 18% evaporator
increase. DOE notes that the final size of the 18% larger evaporator
considered in the analysis is still smaller than evaporators found in
some 22-inch units of the same equipment class. Hence, DOE believes
that an 18% growth in evaporator size is possible and has maintained
this design option in the final rule.
Condenser Costs
Commenting on the NODA analysis for the IMH-W-Small-B, Hoshizaki
and NAFEM stated that increasing the water-cooled condenser length by
48% would require a larger cost increase than $40 stated in the NODA.
(Hoshizaki, No. 124 at p. 2; NAFEM, No. 123 at p. 2) Hoshizaki noted
that they currently are using the largest condenser offered by their
supplier, and increasing its size would necessitate a special design.
(Hoshizaki, No. 124 at p. 2)
[[Page 4691]]
In the NODA phase, DOE evaluated a 48% condenser size increase for
the representative IMH-W-Small-B unit of 22-inch width--based on a
review of typical coaxial water-cooled condenser offerings from typical
suppliers of these units, DOE has concluded that this might be a non-
standard size water-cooled condenser. In the final rule analysis for
this unit, DOE has adjusted its water-cooled condenser options to be
more consistent with standard condenser sizes, based on review of
commercially available components. Therefore, for the IMH-W-Small-B, 22
inch wide unit, DOE adjusted the analysis to instead utilize a 59%
larger condenser. The estimated MPC increase for this design option in
the final rule analysis is $58.
Regarding the NODA analysis for the IMH-A-Small-C, Hoshizaki stated
that cost of increasing the evaporator area by 17% and the condenser
height by 4 inches would be much higher than the $150 presented in the
NODA. Hoshizaki added that 22-inch wide machines could not accommodate
4 inches of height growth and would require a change in chassis.
Hoshizaki noted that condensers are standard parts from the catalogs of
suppliers and there are no condensers that would match this change.
(Hoshizaki, No. 124 at p. 2)
DOE is no longer considering evaporator growth for continuous
units. The representative unit for this equipment class has a condenser
with core height of 10 inches, width of 12 inches and a depth of 3
inches. The chassis height is 21\7/8\ inches and the chassis width is
22 inches. The representative unit has space for the condenser size
increases considered in the analysis. Based on discussions with
manufacturers and heat exchanger suppliers, DOE has found that there is
flexibility in the design of air-cooled condensers, as long as the
design conforms to the use of standard tube pitch (distances between
the tubes) patterns, fin style, and fin densities. The analysis
considered no change in these design parameters that would make the
condenser a non-standard design.
In response to the NODA analysis for the SCU-W-Large-B class, AHRI
commented on the changes in condenser size and the associated
efficiency improvement as compared to the NOPR analysis. AHRI noted
that in the NOPR analysis, DOE considered a size increase of 39%, which
was estimated to reduce energy us use 11.2%, while in the NODA a
condenser size increase of 112% led to estimated energy savings of
16.7%. AHRI stated that such an increase in condenser size would cause
issues with performance outside of rating conditions due to the large
increase in refrigerant charge. AHRI recommended that DOE reconsider
this design option. (AHRI, No. 128 at p. 3)
In response, DOE modified the analysis for the SCU-W-Large-B for
the final rule analysis, in which DOE considers a condenser size
increase of 50%, with associated energy savings of 5.5%.
Purchasing Power and Component Costs
Several commenters noted that the scale of the ice maker industry
is too small to qualify for the price discounts seen by the appliance
markets on specialized parts. (Hoshizaki, No. 86 at p. 7-8; Danfoss,
Public Meeting Transcript, No. 70 at p. 175-176) Danfoss stated that
the small scale of the industry is a barrier to implementing new
technologies and that the investment necessary to produce high-
efficiency compressors in these volumes is not feasible in the
foreseeable future. (Danfoss, No. 72 at p. 3-4)
Scotsman commented that their vendors provide ECM motors at 200-
300% over the cost of baseline motors and high-efficiency compressors
at up to 30% over the cost of baseline compressors. Scotsman added that
they have not successfully proven the performance and reliability of
such components in different applications. (Scotsman, No. 85 at p. 2)
Joint Commenters urged DOE to determine whether fan, pump, and
auger motors use ``off-the-shelf'' or custom motors if the former, this
would suggest that permanent magnet motor availability should not be a
concern. (Joint Commenters, No. 87 at p. 2-3)
In response to these comments DOE notes that it considers the
purchasing power of manufacturers in its estimation of component cost
pricing. DOE has significantly revised its component cost estimates for
the engineering analysis for the NODA and ultimately final rule phase
based on additional information obtained in discussions with
manufacturers as well as in stakeholder comments. DOE used the detailed
feedback to update its cost estimates for all ice maker components.
b. Energy Consumption Model
As part of the preliminary analysis, DOE worked with the developer
of the FREEZE energy consumption model to adapt the model to updated
correlations for refrigerant heat exchanger performance correlations
and operation in a Windows computer environment. Analysis of ice maker
performance during the preliminary analysis was primarily based on the
model. During the course of the rulemaking, DOE has received numerous
comments describing some of the shortcomings of the model. In response,
DOE has modified its energy use analysis to rely less on the FREEZE
model and more on direct calculation of energy use and energy
reductions, based on test data and on assumptions about the efficiency
of components such as motors. DOE requested that stakeholders provide
information and data to guide the analysis, and also requested comments
on the component efficiency assumptions. DOE received additional
information through comments and confidential information exchange with
DOE's contractor that helped guide adjustments to the analysis.
After the NOPR and NODA publications, stakeholders continued to
express concerns about the FREEZE model. AHRI questioned the accuracy
of the FREEZE model. (AHRI, No. 93 at p. 5-6, 16) Scotsman noted that
the FREEZE simulation program may not be able to model performance of
automatic commercial ice makers upon revision of the EPA SNAP
initiative, which may result in use of different refrigerants than are
currently used in ice makers. (Scotsman, No. 125 at p. 2)
Ice-O-Matic commented that the analysis is based on faulty
assumptions from unrelated rulemakings such as commercial
refrigeration, and that the cycles of ice machines do not resemble the
cycles of commercial refrigeration products. (Ice-O-Matic, Public
Meeting Transcript, No. 70 at p. 32) Scotsman and Manitowoc stated that
the energy model may yield unrealistic efficiency gains for some of the
design options. (Manitowoc, Public Meeting Transcript, No. 70 at p.
154-156; Scotsman, No. 125 at p. 2). Specifically, Manitowoc noted that
the energy use model significantly over-predicts the efficiency gains
associated with design options, due to its inability to account for the
harvest portion of the icemaking cycle. Manitowoc added that many
design options that reduce freeze-cycle energy use increase harvest-
cycle energy use. (Manitowoc, No. 92 at p. 1; Manitowoc, No. 126 at p.
1)
Ice-O-Matic noted that that the FREEZE model was designed for full-
size ice cubes and does not work for half-size ice cube machines. (Ice-
O-Matic, No. 121 at p. 2) Full-size cubes of the ice maker models
primarily considered in the analysis generally are cubes with
dimensions \7/8\ x \7/8\ x \7/8\ inches. Half-size cubes have
dimensions \7/8\ x \7/8\ x \3/8\ inches.
Howe and Hoshizaki both stated that DOE should test its component
design options in actual units in order to
[[Page 4692]]
validate the FREEZE model. (Howe, No. 88 at p. 2; Hoshizaki, No. 86 at
p. 6) AHRI also expressed its concern that DOE has not conducted
thorough testing to validate the efficiency gains associated with
design options and requested that DOE prove the claims made in the
engineering analysis. (AHRI, Public Meeting Transcript, No. 70 at p.
20-21)
DOE used the FREEZE energy model as a basis to estimate energy
savings potential associated with design options in the early stages of
the analysis when DOE had limited information. As more information was
made available to DOE through public comments as well as non-disclosure
agreements with manufacturers, DOE modified or replaced the results
garnered from the FREEZE energy model to better reflect the new data
collected.
In response to Scotsman's comment regarding the FREEZE model's
ability to model the performance of automatic commercial ice makers
which use alternative refrigerants, DOE notes that, as described in
section IV.A.4, it has not conducted analysis on the use of alternative
refrigerants in this rule.
In response to comments regarding the FREEZE model's ability to
model the harvest cycle, DOE notes that while the FREEZE model does not
simulate the harvest period analytically, the harvest energy is an
input for the program that DOE adjusted consistent with test data. In
short, the model's ability to accurately calculate the energy use
associated with harvest is limited only by the availability of data
showing the trends of harvest cycle energy use as different design
options are considered. DOE requested information regarding this aspect
of ice maker performance, received some information through comments
and information exchange with manufacturers, and modified the energy
use calculations accordingly.
DOE notes that the harvest cycle energy use issue associated with
the calculation of energy use for batch ice makers does not apply to
continuous ice makers, which do not have a harvest cycle. DOE concludes
that the inability to measure harvest cycle energy use cannot be a
reason to question the energy use calculations made for continuous ice
makers. DOE notes that stakeholders have not identified similar aspects
of continuous ice maker operation that could potentially be cited as
reasons for inaccuracies in the energy use calculations associated with
these ice makers.
In response to Ice-O-matic's comment regarding the FREEZE model's
ability to model half cube ice machines, DOE notes that the FREEZE
model is capable of modeling such units. However, as indicated in
section IV.D.1 DOE has chosen to base the analysis on full-cube ice
machines which, as explained in section IV.D.1, may have an efficiency
disadvantage as compared to half- dice machines. Hence, focus on full-
cube ice makers makes the analysis more conservative.
Expected Savings for Specific Design Options
Several commenters questioned the energy model's assumptions
regarding the relationship between compressor EER improvement and ice
maker efficiency improvement. AHRI stated that the assumed relationship
should be verified with laboratory tests. (AHRI, No. 93 at p. 15)
Manitowoc and Hoshizaki each stated that they tested a compressor
with 12% higher EER compared to baseline and that it yielded a 3%
efficiency improvement. (Manitowoc, Public Meeting Transcript, No. 70
at p. 138-142; Hoshizaki, Public Meeting Transcript, No. 70 at p. 152)
Ice-O-Matic commented that they tested a compressor with 10% higher EER
and that it yielded only a 2% improvement in efficiency. Ice-O-Matic
noted that this is due to the unique circumstances of the harvest
cycle, which removes a lot of the improvements that are typically seen
with compressor efficiency gains in other refrigeration equipment.
(Ice-O-Matic, Public Meeting Transcript, No. 70 at p. 148-149) Follett
noted that they observed a 9% efficiency gain with a compressor that
was 5% more efficient and an ECM fan in an IMH-A-Large-C ice maker.
Follett indicated that these design options would increase cost $60, a
cost for which the DOE NOPR analysis predicted 20% improvement.
(Follet, No. 84 at p. 8)
AHRI stated that the FREEZE energy model results during the June
19th public meeting did not support the findings DOE published in the
NOPR when swapping an upgraded compressor. Rather the model simulation
predicted that the unit with the upgraded compressor would produce more
ice and consume more energy. AHRI stated that they submitted actual
test data for this unit which showed modest efficiency savings for
upgrading the compressor. AHRI noted that this finding is contradictory
to the significant energy savings DOE claimed would be possible in the
NOPR. (AHRI, No. 128 at p. 6-7) DOE responds that accurate modeling
with any analysis requires careful validation of the input data and
that no conclusions can be drawn regarding the results that emerged
during the meeting because there was no time to ensure consistency of
the input and to review the output to understand whether there was a
valid reason for any unexpected results. One could argue, contrary to
the AHRI position, that the results showed that the FREEZE model
predicts higher energy use than would actually be consumed--DOE
realizes that such a conclusion would be meaningless. The only real
conclusion is that the program is not easy to operate and requires
careful review of both input and output in order to ensure that results
are meaningful.
To address the stakeholder concerns that the FREEZE model cannot
adequately model the effects of increased compressor efficiency on ACIM
energy consumption, DOE modified the outputs of the energy model based
on data received in the comments as well as from manufacturers under
non-disclosure agreements. DOE also performed testing on several ice-
making units and used the test data to further inform the relationship
between increased compressor efficiency and ACIM efficiency.
Operating Conditions
NAFEM, Emerson, Manitowoc, Scotsman commented that DOE's
engineering analysis is flawed because it only examines compressor
ratings at AHRI conditions, rather than over the wide range of
operating conditions experienced by ACIMs in the field. (NAFEM, No. 82
at p. 10, Emerson, Public Meeting Transcript, No. 70 at p. 144;
Manitowoc, Public Meeting Transcript, No. 70 at p. 144-146; Scotsman,
No. 85 at p. 2) Emerson noted that the AHRI rating point for
compressors is not typically where an ice machine operates which may
contribute to the issues with DOE's modeling. (Emerson, Public Meeting
Transcript, No. 70 at p. 144) Manitowoc stated that they typically use
a 10-105 condition for compressors, whereas the cost curves used a 15/
95 condition,\29\ which does not match operating conditions that occur
in ice machines. Manitowoc also noted that the
[[Page 4693]]
compressor maps cannot model what happens during the harvest event or
the pre-chill time and that the coefficient models do not include these
operating regions. (Manitowoc, Public Meeting Transcript, No. 70 at p.
144-146) Danfloss also stated that compressor maps are not useful in
developing assumptions about ice maker compressor performance.
(Danfoss, Public Meeting Transcript, No. 70 at p. 152-153)
---------------------------------------------------------------------------
\29\ Compressor performance depends on suction (inlet) and
discharge (outlet) pressures. These pressures are often represented
as the saturated refrigerant temperatures that correspond to the
pressures. For the 15/95 conditions, the saturated evaporator
temperature is 15[emsp14][deg]F and the saturated condensing
temperature is 95[emsp14][deg]F (to be technically correct, these
are represented as dew point temperatures for the refrigerant in
question, R-404A--because there is a range of temperatures at a
given pressure over which the refrigerant can coexist in equilibrium
in both liquid and vapor phases, the temperature at the high end of
this range often used).
---------------------------------------------------------------------------
AHRI noted that DOE did not take operation changes into account,
such as different batch times or energy use, when upgrading to a more
efficient compressor. (AHRI, No. 128 at p. 2)
In response to the comment that compressors operate under a wide
range of conditions in the field, DOE requested information that could
be used to guide the analysis with respect in regards to what
compressors are not suitable for use in ice makers, and/or what other
guidelines could be used to avoid consideration of ice maker designs
that are not viable in the field. DOE did not receive from stakeholders
specific guidelines that could be used to limit the degree to which a
design option might be applied for a given ice maker model in its
analysis. In response to Emerson's comment about compressor rating
conditions not being the typical operating conditions during ice maker
testing, DOE notes that the calculation of compressor performance
during the test was done at more typical compressor operating
conditions during ice maker testing, based on the full set of
performance data for the compressor--not at the compressor rating
conditions. In response to the comment regarding the 15/95 conditions
associated with the cost curves, the performance calculations for the
compressors had nothing to do with the 15/95 conditions--the 15/95
conditions were simply an intermediate step in assigning a
representative cost for a given compressor. This assignment of cost
involved converting the rated AHRI 20/120 capacity for the compressor
into a 15/95 condition by multiplying the capacity by 1.29. DOE then
used this result as described in Chapter 5 of the TSD to determine an
initial nominal cost using the relationship described in the TSD. DOE
further increased the cost based on feedback obtained about compressor
costs from manufacturers throughout the rulemaking.
DOE received data showing the trends in ice maker energy use
reduction with improved compressor EER, including data received as part
of the AHRI NOPR comment, as well as additional data received by DOE's
contractor under non-disclosure agreement. The data showed that for
batch ice makers, the ice maker energy use reduction is a fraction of
the expected energy use reduction when considering just the compressor
EER improvement. DOE applied this reduction in efficiency improvement
to its NODA and final rule analyses.
Analysis Calibration
DOE calibrated the engineering analysis by comparing the energy use
predictions associated with given sets of design options with energy
usage and design data collected from existing ice maker models. DOE
revisited these calibrations in the final rule phase. In general, DOE's
analysis for a given ice maker class is based on an existing ice maker
model with an efficiency level at or near baseline. Hence, the analysis
is calibrated to this particular ice maker model at its efficiency
level, which is based on either its rating or a combination of its
rating and the results of DOE testing. The analysis considers the
energy use impact of adding design options to improve efficiency. In
order to represent the baseline, the analysis may consider removing a
design option (or more than one if necessary) to allow representation
of a design that is at the baseline efficiency level.
DOE also calibrated its analysis using units at maximum available
efficiency levels (or in some cases, efficiency levels less than the
maximum available), specifically equipment without proprietary
technologies, such as low-thermal-mass or tube-type evaporators for
batch ice makers. DOE chose design options to reach the maximum
available efficiency levels of existing equipment. Importantly design
options involving electronically commutate motors and drain water heat
exchangers were excluded from calibration, as these were not considered
to be commonly used in current ice makers. In some cases, the set of
design options chosen to represent the maximum efficiency level matched
the designs of the maximum available efficiency level equipment. In
other cases, the designs did not match exactly, and the design of the
DOE analysis may have had more improvement in one component, while the
maximum available ice maker had more improvement in another component.
In order to ensure that DOE was not underestimating the costs
associated with the overall design improvements, DOE estimated the cost
differential between changing the major components of the analyzed max
efficiency unit to match those of the maximum available equipment.
Major components considered in this estimate were the compressor,
evaporator, condenser, and condenser fan. Table IV.25 shows this
calibration, listing: The maximum efficiency reached by each directly
analyzed equipment class, without considering ECM or drain water heat
exchanger (DWHX) design options; the efficiency of the maximum
available unit; and the cost difference associated with modifying the
major components of to match those in the maximum available. A negative
cost differential indicates that the DOE analysis predicted a higher
cost at that efficiency level compared with the maximum available unit.
The computed cost differentials are zero or negative in all but one
case, showing that the DOE analysis does not underestimate the cost of
reaching these higher efficiency levels. For the one case in which the
differential is positive, $4 for the IMH-A-Small-B 22-Inch ice maker,
the maximum available efficiency level is 5% higher than the level
predicted by DOE's energy use analysis for a comparable set of design
options. The calibration is presented in more detail in Chapter 5 of
the TSD.
Table IV.25--Maximum Available Calibration
----------------------------------------------------------------------------------------------------------------
DOE Analysis Maximum Cost
maximum available differential
Representative efficiency efficiency moving from
Equipment class capacity (lb level (% level (% analyzed to
ice/24 hours) below below maximum
baseline) baseline) available ($)
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B................................... 300 19.2 19.2 -29
IMH-W-Small-B (22-inch wide).................... 300 16.9 16.9 -34
IMH-A-Small-B................................... 300 19.3 19.3 -27
IMH-A-Small-B (22-inch wide).................... 300 11.6 16.6 +4
[[Page 4694]]
IMH-A-Large-B-Medium............................ 800 16.1 16.1 -74
IMH-A-Large-B (22-inch wide).................... 590 5.5 5.5 -13
IMH-A-Large-B-Large............................. 1500 6.2 6.0 -130
IMH-W-Med-B..................................... 850 10.4 14.3 -240
IMH-W-Large-B-2................................. 2600 2.5 2.5 0
RCU-NRC-Large-B-Med............................. 1500 15.7 15.7 -62
RCU-NRC-Large-B-Large........................... 2400 14.9 14.9 -329
SCU-A-Small-B................................... 110 26.6 24.9 -61
SCU-A-Large-B................................... 200 23.5 26.4 -28
SCU-W-Large-B................................... 300 27.6 27.6 0
IMH-A-Small-C................................... 310 19.8 28.0 -30
IMH-A-Large-C................................... 820 17.0 35.7 -11
SCU-A-Small-C................................... 220 21.8 30.1 -62
RCU-NRC-Small-C................................. 610 17.9 18.4 -40
----------------------------------------------------------------------------------------------------------------
c. Revision of NOPR and NODA Engineering Analysis
DOE developed the final engineering analysis by updating the NOPR
and NODA analyses. This included making adjustments to the
manufacturing cost model as described in section IV.D.4.a. It also
included adjustments to energy modeling as described in section IV.D.4.
DOE made several changes to the engineering analysis throughout the
course of this rulemaking. Specifically, in response to the concerns
raised by stakeholders, DOE adjusted its analysis to rely more on test
data based on input received in manufacturers' public and confidential
comments than on theoretically analysis. These changes included:
Based on new data, DOE made changes to the energy use
reductions associated with individual design options;
Based on new cost data, DOE made changes to the costs
associated with individual design options. Design options were changed
as a result of new data obtained through non-disclosure agreements with
DOE's engineering contractor and comments made during the NOPR comment
period developing an approach based on test data to determine the
condensing temperature reductions associated with use of larger water-
cooled condensers;
Based on comments made during the NOPR period, DOE added
additional cost-efficiency curves for 22-inch width units in the IMH-A-
Small-B, IMH-A-Large-B, and IMH-W-Small-B equipment classes, and an
additional cost-efficiency curve for the RCU-Small-C equipment class.
DOE calibrated the results of its calculations with maximum
available ice makers that are available in the market and which do not
incorporate proprietary technologies. This calibration at the maximum
available levels shows that the costs DOE assigned to the maximum
available level is generally higher than suggested by the compared
maximum available equipment.
DOE believes that these changes help ensure that analysis
accurately reflect technology behavior in the market. Further details
on the analyses are available in chapter 5 of the final rule TSD.
E. Markups Analysis
DOE applies multipliers called ``markups'' to the manufacturer
selling price (MSP) to calculate the customer purchase price of the
analyzed equipment. These markups are in addition to the manufacturer
markup (discussed in section IV.J.2.b) and are intended to reflect the
cost and profit margins associated with the distribution and sales of
the equipment between the manufacturer and customer. DOE identified
three major distribution channels for automatic commercial ice makers,
and markup values were calculated for each distribution channel based
on industry financial data. Table IV.26 shows the three distribution
channels and the percentage of the shipments each is assumed to
reflect. The overall markup values were then calculated by weighted-
averaging the individual markups with market share values of the
distribution channels. See chapter 6 of the TSD for more details on
DOE's methodology for markups analysis.
Table IV.26--Distribution Channel Market Shares
------------------------------------------------------------------------
National account Wholesaler channel: Contractor channel:
channel: Manufacturer Manufacturer to Contractor purchase
direct to customer (1- distributor to customer from distributor for
party) (2-party) installation (3-party)
------------------------------------------------------------------------
0% 38% 62%
------------------------------------------------------------------------
In general, DOE has found that markup values vary over a wide range
based on general economic outlook, manufacturer brand value, inventory
levels, manufacturer rebates to distributors based on sales volume,
newer versions of the same equipment model introduced into the market
by the manufacturers, and availability of cheaper or more
technologically advanced alternatives. Based on market data, DOE
divided distributor costs into
[[Page 4695]]
(1) direct cost of equipment sales; (2) labor expenses; (3) occupancy
expenses; (4) other operating expenses (such as depreciation,
advertising, and insurance); and (5) profit. DOE assumed that, for
higher efficiency equipment only, the ``other operating costs'' and
``profit'' scale with MSP, while the remaining costs stay constant
irrespective of equipment efficiency level. Thus, DOE applied a
baseline markup through which all estimated distribution costs are
collected as part of the total baseline equipment cost, and the
baseline markups were applied as multipliers only to the baseline MSP.
Incremental markups were applied as multipliers only to the MSP
increments (of higher efficiency equipment compared to baseline) and
not to the entire MSP. Taken together the two markups are consistent
with economic behavior in a competitive market--the participants are
only able to recover costs and a reasonable profit level.
DOE received a number of comments regarding markups after the
publication of the NOPR.
In written comments, Manitowoc, Hoshizaki, NAFEM, Follett and AHRI
commented that baseline and incremental markups should be equal, set at
the level of the baseline markups. (Manitowoc, No. 92 at p. 2;
Hoshizaki, No. 86 at p. 3; NAFEM, No. 82 at p. 5; Follett, No. 84 at p.
6; and AHRI, No. 93 at p. 6-7)
Some stakeholders at the NOPR public meeting commented that DOE
should not use incremental markups for incremental equipment costs
arising from the imposition of new standards and that DOE should
instead use one set of markups, that corresponds to the baseline
markups. Danfoss commented that wholesalers did not ask which part of
prices were baseline and which were incremental. (Danfoss, Public
Meeting Transcript, No. 70 at p. 197-198) Manitowoc stated that if they
change list prices, their channel partners simply add a markup, and
Manitowoc was not sure they would adopt another approach because a
regulatory change drove up costs. (Manitowoc, Public Meeting
Transcript, No. 70 at p. 192-193)
Danfoss suggested DOE go back and review the results of earlier
rulemakings and identify how markups worked in those equipment markets.
Doing so could add some credibility to the DOE markups methodology,
maybe not in time for the ACIM rulemaking but in time for later
rulemakings. (Danfoss, Public Meeting Transcript, No. 70 at p. 195)
AHRI agreed that DOE should go back and try to verify the numbers at
some point, maybe not for this rulemaking but for the next one. (AHRI,
Public Meeting Transcript, No. 70 at p. 199-200) NAFEM and Manitowoc
also suggested validation studies. (NAFEM, Public Meeting Transcript,
No. 70 at p. 198; Manitowoc, Public Meeting Transcript, No. 70 at p.
190)
ASAP stated that DOE implemented markups where every dollar spent
got the same markup in rulemakings before the year 2000. ASAP argued
that the real world does not work that way because businesses cover
fixed costs in a certain fashion, and variable costs in a certain
fashion. ASAP has done some work examining the question of how good
DOE's methods are at predicting prices. ASAP found that DOE's predicted
prices tend to be higher than they should be, based on retrospective
analysis. ASAP welcomes more retrospective analysis but notes that such
analysis won't help this docket. (ASAP, Public Meeting Transcript, No.
70 at p. 195-197)
Scotsman provided suggestions for price estimation services, and
commented that the cumulative impact on the supply chain of training,
store design modifications, maintenance, costs associated with passing
along manufacturer adjusted pricing, and retrofit of existing locations
would add significantly to the costs of the standards. (Scotsman, No.
95 at page 5)
DOE acknowledges that a detailed review of results following
compliance with prior rulemakings could provide information on
wholesaler and contractor pricing practices, and agrees that such
results would not be timely for this rulemaking. In the absence of such
information, DOE has concluded that its approach, which is consistent
with expected business behavior in competitive markets, is reasonable
to apply. If the cost of goods sold increases due to efficiency
standards, DOE continues to assume that markups would decline slightly,
leaving profit unchanged, and, thus, it uses lower markups on the
incremental costs of higher-efficiency products. This approach is
consistent with behavior in competitive markets wherein market
participants are expected to be able to recover costs and reasonable
levels of profit. If the markup remains constant while the cost of
goods sold increases, as Manitowoc, Hoshizaki, NAFEM, Follett, and AHRI
suggest, the wholesalers' profits would also increase. While this might
happen in the short run, DOE believes that the wholesale market is
sufficiently competitive that there would be pressure on margins. DOE
recognizes that attempting to capture the market response to changing
cost conditions is difficult. However, DOE's approach is consistent
with the mainstream understanding of firm behavior in a competitive
market.
With respect to Manitowoc and Danfoss comments related to
differential pricing based on efficiency improvements, DOE's approach
for wholesaler markups does not imply that wholesalers differentiate
markups based on the technologies inherently present in the equipment.
Rather, it assumes that the average markup declines as the wholesalers'
cost of goods sold increases due to the higher cost of more-efficient
equipment for the reasons explained in the previous paragraph.
With respect to Scotsman's comments, DOE reviewed the suggested
price quote services and, while appreciative of the information, found
them to not provide the type of information needed for estimating
markups on a national or state average basis. As for the costs
mentioned, DOE believes costs such as passing along the manufacturer
pricing and personnel training are already embodied in markups as such
costs would be included in the data used to estimate markups and no
evidence has been entered into the record to demonstrate that the costs
caused by the proposed standards would be extraordinary. Other costs
such as building renovation and retrofit costs were included in
installation costs, as appropriate.
F. Energy Use Analysis
DOE estimated energy usage for use in the LCC and NIA models based
on the kWh/100 lb ice and gal/100 lb ice values developed in the
engineering analysis in combination with other assumptions. For the
NOPR, DOE assumed that ice makers on average are used to produce one-
half of the ice the machines could produce (i.e., a 50 percent capacity
factor). DOE also assumed that when not making ice, on average ice
makers would draw 5 watts of power. DOE modeled condenser water usage
as ``open-loop'' installations, or installations where water is used in
the condenser one time (single pass) and released into the wastewater
system.
Hoshizaki asked about the basis for the 50 percent usage factor.
(Hoshizaki, Public Meeting Transcript, No. 70 at p. 204) NEEA referred
to the usage factor as a best estimate, and noted that the 50 percent
factor had not been improved upon in response to earlier rulemaking
stages. (NEEA, Public Meeting Transcript, No. 70 at p. 204-205)
With its written comments, AHRI supplied monitored results
collected by two manufacturers and recommended that DOE revise the
utilization factor to 38%, based on the average of the data collected
from stores, cafeterias, and
[[Page 4696]]
restaurants in a variety of states. (AHRI, No. 93 at p. 2-3) Follett
commented that its data shows that ice makers run an average of 38% of
the time and that DOE should modify its analysis accordingly. (Follett,
No. 84 at p. 3) Manitowoc commented that a more accurate average duty
cycle for ACIMs is 40% based on data it had collected. (Manitowoc, No.
92 at p. 3)
NEEA recommended that DOE adjust the energy use on a weighted sales
average to reflect a higher duty cycle for ice makers that are
replacements as compared to new units, where ice demand may not be
accurately known. (NEEA, No. 91 at p. 2)
Based on the monitored results submitted by AHRI and similar
monitored results found in a report posted online,\30\ DOE utilized a
42 percent capacity factor to estimate energy usage for the LCC and NIA
models. With respect to NEEA's comment, given that DOE has no
information on new versus replacement units and that the sample of
monitored results does not include all relevant business types, DOE
used the factor based on monitored results for new and replacement
shipments for all business types.
---------------------------------------------------------------------------
\30\ Karas, A. and D. Fisher. A Field Study to Characterize
Water and Energy Use of Commercial Ice-Cube Machines and Quantify
Saving Potential. December 2007. Fisher-Nickel, Inc. San Ramon, CA.
---------------------------------------------------------------------------
G. Life-Cycle Cost and Payback Period Analysis
In response to the requirements of EPCA in (42 U.S.C.
6295(o)(2)(B)(i) and 6313(d)(4)), DOE conducts a LCC and PBP analysis
to evaluate the economic impacts of potential amended energy
conservation standards on individual commercial customers--that is,
buyers of the equipment. This section describes the analyses and the
spreadsheet model DOE used. TSD chapter 8 details the model and all the
inputs to the LCC and PBP analyses.
LCC is defined as the total customer cost over the lifetime of the
equipment, and consists of installed cost (purchase and installation
costs) and operating costs (maintenance, repair, water,\31\ and energy
costs). DOE discounts future operating costs to the time of purchase
and sums them over the expected lifetime of the unit of equipment. PBP
is defined as the estimated amount of time it takes customers to
recover the higher installed costs of more-efficient equipment through
savings in operating costs. DOE calculates the PBP by dividing the
increase in installed costs by the savings in annual operating costs.
DOE measures the changes in LCC and in PBP associated with a given
energy and water use standard level relative to a base-case forecast of
equipment energy and water use (or the ``baseline energy and water
use''). The base-case forecast reflects the market in the absence of
new or amended energy conservation standards.
---------------------------------------------------------------------------
\31\ Water costs are the total of water and wastewater costs.
Wastewater utilities tend to not meter customer wastewater flows,
and base billings on water commodity billings. For this reason,
water usage is used as the basis for both water and wastewater
costs, and the two are aggregated in the LCC and PBP analysis.
---------------------------------------------------------------------------
The installed cost of equipment to a customer is the sum of the
equipment purchase price and installation costs. The purchase price
includes MPC, to which a manufacturer markup (which is assumed to
include at least a first level of outbound freight cost) is applied to
obtain the MSP. This value is calculated as part of the engineering
analysis (chapter 5 of the TSD). DOE then applies additional markups to
the equipment to account for the costs associated with the distribution
channels for the particular type of equipment (chapter 6 of the TSD).
Installation costs are varied by state depending on the prevailing
labor rates.
Operating costs for automatic commercial ice makers are the sum of
maintenance costs, repair costs, water, and energy costs. These costs
are incurred over the life of the equipment and therefore are
discounted to the base year (2018, which is the proposed effective date
of the amended standards that will be established as part of this
rulemaking). The sum of the installed cost and the operating cost,
discounted to reflect the present value, is termed the life-cycle cost
or LCC.
Generally, customers incur higher installed costs when they
purchase higher-efficiency equipment, and these cost increments will be
partially or wholly offset by savings in the operating costs over the
lifetime of the equipment. Usually, the savings in operating costs are
due to savings in energy costs because higher-efficiency equipment uses
less energy over the lifetime of the equipment. Often, the LCC of
higher-efficiency equipment is lower compared to lower-efficiency
equipment.
The PBP of higher-efficiency equipment is obtained by dividing the
increase in the installed cost by the decrease in annual operating
cost. For this calculation, DOE uses the first-year operating cost
decreases as the estimate of the decrease in operating cost, noting
that some of the repair and maintenance costs used in the analysis are
annualized estimates of costs. DOE calculates a PBP for each efficiency
level of each equipment class. In addition to the energy costs
(calculated using the electricity price forecast for the first year),
the first-year operating costs also include annualized maintenance and
repair costs.
Apart from MSP, installation costs, and maintenance and repair
costs, other important inputs for the LCC analysis are markups and
sales tax, equipment energy consumption, electricity prices and future
price trends, expected equipment lifetime, and discount rates.
As part of the engineering analysis, design option levels were
ordered based on increasing efficiency (decreased energy and water
consumption) and increasing MSP values. DOE developed two to seven
energy use levels for each equipment class, henceforth referred to as
``efficiency levels,'' through the analysis of engineering design
options. For all equipment classes, efficiency levels were set at
specific intervals--e.g., 10 percent improvement over base energy
usage, 15 percent improvement, 20 percent improvement. The max-tech
efficiency level is the only exception. At the max-tech level, the
efficiency improvement matched the specific levels identified in the
engineering analysis.
The base efficiency level (level 1) in each equipment class is the
least efficient and the least expensive equipment in that class. The
higher efficiency levels (level 2 and higher) exhibit progressive
increases in efficiency and cost with the highest efficiency level
corresponding to the max-tech level. LCC savings and PBP are calculated
for each selected efficiency level of each equipment class.
Many inputs for the LCC analysis are estimated from the best
available data in the market, and in some cases the inputs are
generally accepted values within the industry. In general, each input
value has a range of values associated with it. While single
representative values for each input may yield an output that is the
most probable value for that output, such an analysis does not give the
general range of values that can be attributed to a particular output
value. Therefore, DOE carried out the LCC analysis in the form of Monte
Carlo simulations \32\ in which certain inputs were expressed as a
range of values and probability distributions that account
[[Page 4697]]
for the ranges of values that may be typically associated with the
respective input values. The results or outputs of the LCC analysis are
presented in the form of mean LCC savings, percentages of customers
experiencing net savings, net cost and no impact in LCC, and median
PBP. For each equipment class, 10,000 Monte Carlo simulations were
carried out. The simulations were conducted using Microsoft Excel and
Crystal Ball, a commercially available Excel add-in used to carry out
Monte Carlo simulations.
---------------------------------------------------------------------------
\32\ Monte Carlo simulation is, generally, a computerized
mathematical technique that allows for computation of the outputs
from a mathematical model based on multiple simulations using
different input values. The input values are varied based on the
uncertainties inherent to those inputs. The combination of the input
values of different inputs is carried out in a random fashion to
simulate the different probable input combinations. The outputs of
the Monte Carlo simulations reflect the various probable outputs
that are possible due to the uncertainties in the inputs.
---------------------------------------------------------------------------
LCC savings and PBP are calculated by comparing the installed costs
and LCC values of standards-case scenarios against those of base-case
scenarios. The base-case scenario is the scenario in which equipment is
assumed to be purchased by customers in the absence of the proposed
energy conservation standards. Standards-case scenarios are scenarios
in which equipment is assumed to be purchased by customers after the
amended energy conservation standards, determined as part of the
current rulemaking, go into effect. The number of standards-case
scenarios for an equipment class is equal to one less than the total
number of efficiency levels in that equipment class because each
efficiency level above efficiency level 1 represents a potential
amended standard. Usually, the equipment available in the market will
have a distribution of efficiencies. Therefore, for both base-case and
standards-case scenarios, in the LCC analysis, DOE assumed a
distribution of efficiencies in the market, and the distribution was
assumed to be spread across all efficiency levels in the LCC analysis
(see TSD chapter 10).
Recognizing that different types of businesses and industries that
use automatic commercial ice makers face different energy prices and
apply different discount rates to purchase decisions, DOE analyzed
variability and uncertainty in the LCC and PBP results by performing
the LCC and PBP calculations for seven types of businesses: (1) Health
care; (2) lodging; (3) foodservice; (4) retail; (5) education; (6) food
sales; and (7) offices. Different types of businesses face different
energy prices and also exhibit differing discount rates that they apply
to purchase decisions.
Expected equipment lifetime is another input for which it is
inappropriate to use a single value for each equipment class.
Therefore, DOE assumed a distribution of equipment lifetimes that are
defined by Weibull survival functions.\33\
---------------------------------------------------------------------------
\33\ A Weibull survival function is a continuous probability
distribution function that is commonly used to approximate the
distribution of equipment lifetimes.
---------------------------------------------------------------------------
Equipment lifetime is a key input for the LCC and PBP analysis. For
automatic commercial ice maker equipment, there is a general consensus
among industry stakeholders that the typical equipment lifetime is
approximately 7 to 10 years with an average of 8.5 years. There was no
data or comment to suggest that lifetimes are unique to each equipment
class. Therefore, DOE assumed a distribution of equipment lifetimes
that is defined by Weibull survival functions, with an average value of
8.5 years.
Using monitored data on the percentage of potential ice-making
capacity that is actually used in real world installations (referred
herein as utilization factor, but also referred to as duty cycle), the
electricity and water usage of ice makers were also varied in the LCC
analysis.
Another factor influencing the LCC analysis is the physical
location in which the automatic commercial ice maker is installed.
Location is captured by using state-level inputs, including
installation costs, water and energy prices, and sales tax (plus the
associated distribution chain markups). At the national level, the
spreadsheets explicitly modeled variability in the model inputs for
water price, electricity price, and markups using probability
distributions based on the relative populations in all states.
Detailed descriptions of the methodology used for the LCC analysis,
along with a discussion of inputs and results, are presented in chapter
8 and appendices 8A and 8B of the TSD.
1. Equipment Cost
To calculate customer equipment costs, DOE multiplied the MSPs
developed in the engineering analysis by the distribution channel
markups, described in section IV.E. DOE applied baseline markups to
baseline MSPs and incremental markups to the MSP increments associated
with higher efficiency levels.
In the NOPR analysis, DOE developed a projection of price trends
for automatic commercial ice maker equipment, indicating that based on
historical price trends the MSP would be projected to decline by 0.4
percent from the 2012 estimation of MSP values through the 2018 assumed
start date of new or amended standards. The NOPR analysis also
indicated an approximately 1.7 percent decline from the MSP values
estimated in 2012 to the end of the 30-year NIA analysis period used in
the NOPR.
AHRI questioned where the price trend data came from and asked how
confident DOE was of the numbers. (AHRI, Public Meeting Transcript, No.
70 at p. 216) In written comments, AHRI expressed concern with the
experiential learning analysis and use of a producer price index and
urged DOE to assume the MSP remain constant. (AHRI, No. 93 at p. 16-17)
PG&E and SDG&E expressed their support of DOE's use of experiential
price learning in life-cycle cost analysis. (PG&E and SDG&E, No. 89 at
p. 4)
DOE acknowledges the PG&E and SDG&G comment. In response to the
AHRI comments that the data do not support the price trends, DOE agrees
that it would be better to have data very specific to automatic
commercial ice maker price trends. However, such is not available. The
PPI used in the analysis of price trends embodies the price trends of
automatic commercial ice makers as well as related technologies,
including those used as inputs to the manufacturing process. DOE would
also note that a sensitivity analysis was performed with price trends
held constant, and doing such would not have impacted the selection of
efficiency levels for TSLs. (See appendix 10B of the final rule TSD.)
Because DOE believes there is evidence that price learning exists, DOE
continued to use price learning for the final rule.
As is customary between phases of a rulemaking, DOE re-examined the
data available and updated the price trend analysis. DOE continued to
use a subset of the air-conditioning, refrigeration, and forced air
heating equipment Producer Price Index (PPI) that includes only
commercial refrigeration and related equipment, and excludes unrelated
equipment. Using this PPI for the automatic commercial ice maker price
trends analysis yields a price decline of roughly 2.4 percent over the
period of 2013 (the year for which MSP was estimated) through 2047. For
the LCC model, between 2013 and 2018, the price decline is 0.5 percent.
2. Installation, Maintenance, and Repair Costs
a. Installation Costs
Installation cost includes labor, overhead, and any miscellaneous
materials and parts needed to install the equipment. Most automatic
commercial ice makers are installed in fairly standard configurations.
For the NOPR,
[[Page 4698]]
DOE assumed that the installation costs vary from one equipment class
to another, but not by efficiency level within an equipment class. For
the NOPR, DOE tentatively concluded that the engineering design options
did not impact the installation cost within an equipment class. DOE
therefore assumed that the installation cost for automatic commercial
ice makers did not vary among efficiency levels within an equipment
class. Costs that do not vary with efficiency levels do not impact the
LCC, PBP, or NIA results.
During the public meeting manufacturers commented that not all
customers can accommodate increased unit sizes, and that DOE must
consider additional costs incurred from modifying facilities to
accommodate ice makers with potential changes including plumbing and/or
electrical work, relocating existing equipment, and/or building
renovations. (Scotsman, Public Meeting Transcript, No. 70 at p. 126-
127; Manitowoc, Public Meeting Transcript, No. 70 at p. 133 and p. 209;
Ice-O-Matic, Public Meeting Transcript, No. 70 at p. 208 and p. 210)
In written comments, AHRI stated it was incorrect to assume
installation cost would not increase with the efficiency improvement.
(AHRI, No. 93 at p. 4) AHRI and Follett stated that larger ice makers
will require installation space modification and would result in higher
installation costs. (AHRI, No. 93 at p. 7-8; Follett, No. 84 at p. 6)
Hoshizaki stated that the current installation cost range
considerations may be correct for ice makers without size increases but
agreed with AHRI and Follett that the installation cost would increase
if the cabinet size went up, and that drain water heat exchangers would
further increase installation costs. (Hoshizaki, No. 86 at p. 3-4)
Manitowoc provided written comments, adding that remote condenser and
remote condenser with compressor units that have larger condenser coils
will require larger roof curbs or stronger mounting, depending on
whether footprint or height is affected. (Manitowoc, No. 92 at p. 3)
Scotsman stated in response to the NOPR and to the NODA that customers
with space constraints could incur costs including but not limited to
building renovation, water and wastewater service relocation, and
electric service and countertop renovations. (Scotsman, No. 85 at p.
5b-6b; No. 125 at p. 2) Scotsman also stated that any efficiency
improvement greater than 5 percent would cause cabinet size increases.
(Scotsman, No. 125 at p. 2) Policy Analyst stated that DOE should
assess whether commercial ice maker installation costs are affected by
its proposed standards. (Policy Analyst, No. 75, p. 10)
Joint Commenters commented that DOE appropriately considered design
options that increased package sizes, noting the options consumers have
for purchases and noting the opportunity consumers might have to select
smaller units given the low utilization factors used in the analysis.
(Joint Commenters, No. 87, p. 3) NEEA similarly stated that DOE
appropriately considered all the factors related to chassis size
increase (NEEA, No. 91, pp. 1-2) PG&E and SDG&E, and CA IOU noted that
it is unclear that insufficient space exists to increase chassis sizes
in all situations. (PG&E and SDG&E, No. 89, p. 3, and CA IOU, No. 129,
p. 4)
As suggested by Policy Analyst and manufacturers, DOE investigated
further the question of installation costs varying by efficiency
levels. In particular, DOE investigated the issue around increased
cabinet sizes for ice makers and modified the installation cost
calculation methodology to reflect increased installation costs for
equipment classes that are size constrained. In response to stakeholder
comments and data supplied by stakeholders, DOE revised the analysis
for three equipment classes with significant shipment volumes of 22-
inch-wide units and where height increases in the cabinets were
considered in DOE's engineering analysis. In the engineering analysis
for the final rule, DOE examined design options and efficiency level
improvements for 22-inch units for three equipment classes under a
scenario where no increase in equipment size was considered, resulting
in two separate cost-efficiency curves (space constrained and non-space
constrained) for each of these three classes (IMH-A-Small-B, IMH-A-
Large-B, and IMH-W-Small-B). Each of these equipment classes is
designed for mounting on bins, ice dispensers, or fountain dispensers,
and in the case of dispensers, generally the combination is mounted on
a counter or table. For the LCC/PBP analysis and the NIA, DOE
integrated the two curves for these equipment classes. To do so, at the
efficiency level where the 22-inch engineering cost curves end, DOE
researched the additional installation costs customers would incur in
order to raise ceilings or move walls to make it possible for the
customers to install the larger, non-22-inch units. As PG&E, SDG&E and
CA IOU stated, not all installations lack sufficient space to
accommodate increased chassis sizes. Based on the research performed
for the final rule, DOE identified percentages of customers of the non-
space constrained equipment who also face size constraints, and
estimated additional installation costs imposed by the need to raise
ceilings or address other height constraints to facilitate cabinet size
increases. Chapter 8 of the final rule TSD describes the process for
including building renovation costs in the ACIM installation costs, and
the inputs used in the analysis.
In response to Hoshizaki and Manitowoc comments, DOE researched
DWHX installation costs, and the cost to install larger remote
condensers. In both cases, DOE identified incremental installation
costs for these design options and added such to the installation costs
at the efficiency levels that include these options.
In response to Scotsman and Ice-O-Matic comments that the design
options might cause customers to need to increase the size of
electrical or water services, the specific technologies underlying the
design options studied by DOE would not require increased electrical or
water services. In performing the engineering analyses, DOE analyzed
design options for each equipment class at the same voltage levels as
existing typical units. As such, there is no reason to believe that
meeting the energy conservation standard for any specific equipment
class would require an increased electrical service. Similarly, there
is reason to believe meeting the energy conservation standard would
require greater water service, because no design options were analyzed
which would increase water usage. Water or wastewater services
relocations or countertop renovations would be required if customers
move ice makers, but DOE's belief is that moving ice makers would not
be a requirement imposed by the small cabinet size increases envisioned
in this rulemaking.
Additional information regarding the estimation of installation
costs is presented in TSD chapter 8.
b. Repair and Maintenance Costs
The repair cost is the average annual cost to the customer for
replacing or repairing components in the automatic commercial ice maker
that have failed. For the NOPR, DOE approximated repair costs based on
an assessment of the components likely to fail within the lifetime of
an automatic commercial ice maker in combination with the estimated
cost of these components developed in the engineering analysis. Under
this methodology, repair and replacement costs are based on the
original equipment costs, so the more expensive the components are, the
[[Page 4699]]
greater the expected repair or replacement cost. For design options
modeled in the engineering analysis, DOE estimated repair costs, and if
they were different than the baseline cost, the repair costs were
either increased or decreased accordingly.
Maintenance costs are associated with maintaining the proper
operation of the equipment. The maintenance cost does not include the
costs associated with the replacement or repair of components that have
failed, which are included as repair costs. In the NOPR analyses, DOE
estimated material and labor costs for preventative maintenance based
on RS Means cost estimation data and on telephone conservations with
contractors. DOE assumed maintenance cost would remain constant for all
efficiency levels within an equipment class.
AHRI commented that it is incorrect to assume that changes in
maintenance and repair will be negligible for more efficient equipment,
and that DOE should contact parts distributors to find the price
difference between permanent split-capacitor (PSC) and ECM motors and
between 2-stage and 1-stage compressors. AHRI noted that dealers
usually double their costs when invoicing equipment owners. (AHRI, No.
93 at p. 4) Similarly, Scotsman commented that the supply-chain cost
impact of the standards would be nearly equal in percentage to the
manufactured product cost increase. (Scotsman, No. 85 at p. 5b)
Scotsman commented that the expedited product development timeline
would affect manufacturers by impeding the traditional product
development process, resulting in a higher product failure rate,
additional training burden, and increased repair costs and that this
cost should be included in the analysis (Scotsman, Public Meeting
Transcript, No. 70 at p. 212, p. 218, p. 219-220).
In the final rule analysis released for the NODA, DOE added a
``repair labor cost'' to the original repair cost, reflective of the
cost of replacing individual components. DOE's research did not
identify studies or data indicating that the failure rates, and in turn
maintenance and repair costs, of energy-efficient equipment is
significantly higher than traditional equipment. In response to AHRI's
comments about contacting distributors about motors and compressors,
DOE did collect labor information directly from service companies upon
which to base the estimated labor hours. In response to AHRI's note
about the doubling of costs, the total repair chain markup underlying
DOE's estimated repair costs is 250 percent of direct equipment costs.
In response to AHRI's comment about compressors, DOE did not
include 2-stage compressors in the engineering analysis, and so the
comment does not apply.
In response to the Scotsman comment about warranty costs, DOE has
no information indicating whether or how much failure rates will change
as a result of standards implementation. To the extent that training
and warranty costs are born by manufacturers and identified in the data
collection efforts, such costs are included in the manufacturer impact
analysis.
3. Annual Energy and Water Consumption
Chapter 7 of the final rule TSD details DOE's analysis of annual
energy and water usage at various efficiency levels of automatic
commercial ice makers. Annual energy and water consumption inputs by
automatic commercial ice maker equipment class are based on the
engineering analysis estimates of kilowatt-hours of electricity per 100
lb ice and gallons of water per 100 lb ice, translated to annual
kilowatt-hours and gallons in the energy and water use analysis
(chapter 7 of the final rule TSD). The development of energy and water
usage inputs is discussed in section IV.F along with public input and
DOE's response to the public input.
4. Energy Prices
DOE calculated average commercial electricity prices using the EIA
Form EIA-826 data obtained online from the ``Database: Sales
(consumption), revenue, prices & customers'' Web page.\34\ The EIA data
are the average commercial sector retail prices calculated as total
revenues from commercial sales divided by total commercial energy sales
in kilowatt-hours, by state and for the nation. DOE received no
recommendations or suggestions regarding this set of assumptions at the
April 2014 NOPR public meeting or in written comments.
---------------------------------------------------------------------------
\34\ U.S. Energy Information Administration. Sales and revenue
data by state, monthly back to 1990 (Form EIA-826). (Last accessed
May 19, 2014). www.eia.gov/electricity/data.cfm#sales.
---------------------------------------------------------------------------
5. Energy Price Projections
To estimate energy prices in future years for the NOPR and for the
final rule, DOE multiplied the average state-level energy prices
described in the previous paragraph by the forecast of annual average
commercial energy price indices developed in the Reference Case from
AEO2014.\35\ AEO2014 forecasted prices through 2040. To estimate the
price trends after 2040, DOE assumed the same average annual rate of
change in prices as exhibited by the forecast over the 2031 to 2040
period. DOE received no recommendations or suggestions regarding this
set of assumptions at the April 2014 public meeting or in written
comments.
---------------------------------------------------------------------------
\35\ The spreadsheet tool that DOE used to conduct the LCC and
PBP analyses allows users 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.
---------------------------------------------------------------------------
6. Water Prices
To estimate water prices in future years for the NOPR, DOE used
price data from the 2008,\36\ 2010,\37\ and 2012 American Water Works
Association (AWWA) Water and Wastewater Surveys.\38\ The AWWA 2012
survey was the primary data set. No data exists to disaggregate water
prices for individual business types, so DOE varied prices by state
only and not by business type within a state. For each state, DOE
combined all individual utility observations within the state to
develop one value for each state for water and wastewater service.
Since water and wastewater billings are frequently tied to the same
metered commodity values, DOE combined the prices for water and
wastewater into one total dollars per 1,000 gallons figure. DOE used
the Consumer Price Index (CPI) data for water-related consumption
(1973-2012) \39\ in developing a real growth rate for water and
wastewater price forecasts.
---------------------------------------------------------------------------
\36\ American Water Works Association. 2008 Water and Wastewater
Rate Survey. 2009. Denver, CO. Report No. 54004.
\37\ American Water Works Association. 2010 Water and Wastewater
Rate Survey. 2011. Denver, CO. Report No. 54006.
\38\ American Water Works Association. 2012 Water and Wastewater
Rate Survey. 2013. Denver, CO. Report No. 54008.
\39\ The Bureau of Labor Statistics defines CPI as a measure of
the average change over time in the prices paid by urban consumers
for a market basket of consumer goods and services. For more
information see www.bls.gov/cpi/home.htm.
---------------------------------------------------------------------------
In written comments, the Alliance stated that DOE looked only at
energy savings for air-cooled and water-cooled ACIM equipment, and that
DOE should include water and wastewater cost in the LCC analysis. The
Alliance notes that when such costs are included, air-cooled equipment
is more cost-effective than water-cooled equipment. (Alliance, No. 73
at p. 3) The Alliance further recommended that DOE should reflect the
rising costs water and wastewater cost in its life cycle analysis.
(Alliance, No. 73 at p. 3) The Alliance also
[[Page 4700]]
commented that DOE did not take into account the embedded energy needed
to pump, tread and distribute water and to collect and treat
wastewater, noting that the end user does not pay this cost and that it
is paid by the water and wastewater user. (Alliance, No. 73 at p. 3,
18-19)
DOE includes water and wastewater cost in the LCC analysis and
notes that real electric prices (2013$) escalate at roughly 0.4 percent
between 2013 and 2047, while real water and wastewater prices escalate
at roughly 2.0 percent over the same time period. DOE disagrees with
the Alliance's comment that the end user of ice does not pay for the
cost of energy embedded in the water used to make ice. This statement
implies that the hotels, restaurants and other entities that use
automatic commercial ice makers and pay the water and wastewater bills
charge prices that do not fully recover all of their costs of doing
business. DOE would agree that the end user of ice does not perceive
the cost of the ice or any of the factors of production that went into
the provision of the ice or the beverage served with the ice. However,
DOE included water and wastewater costs in the LCC analyses, thereby
capturing the cost of embedded energy in the analysis.
In response to the Alliance's comparison of equipment types, DOE's
final rule and final rule TSD present LCC results for all equipment
classes. As discussed in section II.A of this preamble, DOE's
rulemaking authority required DOE to promulgate standards that do not
eliminate features or reduce customer utility. Because the existing
standards established by Congress made water-cooled equipment separate
equipment classes differentiated by the use of water in the condenser,
DOE considers the use of water in the condenser to be a feature. For
these reasons, DOE has no reason to make determinations that one
equipment type is more cost-effective than another type.
For the final rule, DOE updated the calculation of State-level
water prices with the inclusion of 2013 consumer price index values.
7. Discount Rates
The discount rate is the rate at which future expenditures are
discounted to establish their present value. DOE determined the
discount rate by estimating the cost of capital for purchasers of
automatic commercial ice makers. Most purchasers use both debt and
equity capital to fund investments. Therefore, for most purchasers, the
discount rate is the weighted average cost of debt and equity
financing, or the weighted average cost of capital (WACC), less the
expected inflation.
DOE received no comments at the April 2014 public meeting or in
written form related to discount rates.
To estimate the WACC of automatic commercial ice maker purchasers
for the final rule, DOE used a sample of over 1,400 companies grouped
to be representative of operators of each of the commercial business
types (health care, lodging, foodservice, retail, education, food
sales, and offices) drawn from a database of 7,765 U.S. companies
presented on the Damodaran Online Web site.\40\ This database includes
most of the publicly traded companies in the United States. The WACC
approach for determining discount rates accounts for the current tax
status of individual firms on an overall corporate basis. DOE did not
evaluate the marginal effects of increased costs and the increased
depreciation due to more expensive equipment, on the overall tax
status.
---------------------------------------------------------------------------
\40\ Damodaran financial data is available at https://
pages.stern.nyu.edu/~adamodar/ (Last accessed June 6, 2014).
---------------------------------------------------------------------------
DOE used the final sample of companies to represent purchasers of
automatic commercial ice makers. DOE combined company-specific
information from the Damodaran Online Web site, long-term returns on
the Standard & Poor's 500 stock market index from the Damodaran Online
Web site, nominal long-term Federal government bond rates, and long-
term inflation to estimate a WACC for each firm in the sample.
For most educational buildings and a portion of the office
buildings and cafeterias occupied and/or operated by public schools,
universities, and state and local government agencies, DOE estimated
the cost of capital based on a 40-year geometric mean of an index of
long-term (>20 years) tax-exempt municipal bonds.\41\ \42\ Federal
office space was assumed to use the Federal bond rate, derived as the
40-year geometric average of long-term (>10 years) U.S. government
securities.\43\
---------------------------------------------------------------------------
\41\ Federal Reserve Bank of St. Louis, State and Local Bonds--
Bond Buyer Go 20-Bond Municipal Bond Index. (Last accessed April 6,
2012). Annual 1974-2011 data were available at https://research.stlouisfed.org/fred2/series/MSLB20/downloaddata?cid=32995.
\42\ Rates for 2012 and 2013 calculated from monthly data. Data
source: U.S. Federal Reserve (Last accessed July 10, 2014.)
Available at https://www.federalreserve.gov/releases/h15/data.htm.
\43\ Rate calculated with 1974-2013 data. Data source: U.S.
Federal Reserve (Last accessed July 10, 2014.) Available at https://www.federalreserve.gov/releases/h15/data.htm.
---------------------------------------------------------------------------
DOE recognizes that within the business types purchasing automatic
commercial ice makers there will be small businesses with limited
access to capital markets. Such businesses tend to be viewed as higher
risk by lenders and face higher capital costs as a result. To account
for this, DOE included an additional risk premium for small businesses.
The premium, 1.9 percent, was developed from information found on the
Small Business Administration Web site.\44\
---------------------------------------------------------------------------
\44\ Small Business Administration data on loans between $10,000
and $99,000 compared to AAA Corporate Rates. (Last accessed on June
10, 2013.) Available at https://www.sba.gov/advocacy/7540/6282.
---------------------------------------------------------------------------
Chapter 8 of the final rule TSD provides more information on the
derivation of discount rates. The average discount rate by business
type is shown on Table IV.27.
Table IV.27--Average Discount Rate by Business Type
------------------------------------------------------------------------
Average
Business type discount rate
(real) (%)
------------------------------------------------------------------------
Health Care............................................. 3.4
Lodging................................................. 7.9
Foodservice............................................. 7.1
Retail.................................................. 5.8
Education............................................... 4.0
Food Sales.............................................. 6.9
Office.................................................. 6.2
------------------------------------------------------------------------
8. Lifetime
DOE defines lifetime as the age at which typical automatic
commercial ice maker equipment is retired from service. DOE estimated
equipment lifetime based on its discussion with industry experts and
concluded a typical lifetime of 8.5 years. For the NOPR analyses, DOE
elected to use an 8.5-year average life for all equipment classes.
DOE received written comments on the typical lifetime. Scotsman
stated continuous units might have a shorter typical lifetime than
batch type units but did not provide estimates of the difference.
(Scotsman, No. 85 at p. 5b) Hoshizaki commented that 8.5 years is a
good average lifetime assumption. (Hoshizaki, No. 86 at p. 3) AHRI
commented that the average lifespan of continuous type ice makers is 7
years based on warranty data. (AHRI, No. 93 at p. 7) NAFEM commented
that DOE did not use adequate data to justify its assumed lifetime of
8.5 years and that DOE should study the difference in lifetimes between
batch type and continuous type ice makers. (NAFEM, No. 82 at p. 4)
AHRI and NAFEM both commented that the proposed rule will increase
the size and the cost of automatic commercial ice makers, and both
pointed to the example of air
[[Page 4701]]
conditioners, where efficiency standards led to larger and more
expensive units. The two stakeholders went on to state that annual air
conditioner industry sales dropped about 18% while repair parts sales
sharply increased. (NAFEM, No. 82 at p. 6 and p. 10; AHRI, No. 93 at p.
8) Follett commented that the proposed rule is so stringent that it
would create significant hardship for manufacturers and could require
compromises to reliability and serviceability, adding that the rule
could incent end-users to repair rather than replace their machines.
(Follett, No. 84, at p. 1)
With respect to NAFEM's comment about the adequacy of data, in the
framework and preliminary analysis phases of this rulemaking, DOE
surveyed the available literature and found a range of estimates of 7
to 10 years, with 8.5 being the average. Literature cited on Table
IV.28 suggested lifetimes of up to 20 years or more for automatic
commercial ice makers, and this range was supported by discussion with
experts.
Table IV.28--Estimates for Automatic Commercial Ice Maker Lifetimes
------------------------------------------------------------------------
Life Reference
------------------------------------------------------------------------
7 to 10 years.................... Arthur D. Little, 1996.\45\
8.5 years........................ California Energy Commission,
2004.\46\
8.5 years........................ Fernstrom, G., 2004.\47\
8.5 years........................ Koeller J., and H. Hoffman, 2008.\48\
7 to 10 years.................... Navigant Consulting, Inc. 2009.\49\
------------------------------------------------------------------------
With regard to the Scotsman's suggestion that continuous type ice
makers might have shorter life spans, DOE found the comment lacking
sufficient specific information to act on the comment. With respect to
the AHRI comment that continuous equipment has a 7-year life, DOE notes
that the phrase ``based on warranty data'' provided no information that
DOE could analyze to determine whether to revise the assumed equipment
lifetime. In addition, warranty claims do not necessarily correlate
with product lifetime. For this reason, DOE decided based on the
previous, generally high level of agreement with the 8.5-year lifetime
to retain that lifetime as the basic assumption, and to use the 7-year
continuous product life for sensitivity analyses.
---------------------------------------------------------------------------
\45\ Arthur D. Little, Inc. Energy Savings for Commercial
Refrigeration. Final Report. June, 1996. Submitted to the U.S.
Department of Energy's Energy Efficiency and Renewable Energy
Building Technologies Program. Washington, DC.
\46\ California Energy Commission. Update of Appliance
Efficiency Regulations. 2004. Sacramento, CA.
\47\ Fernstrom, G. B. Analysis of Standards Options For
Commercial Packaged Refrigerators, Freezers, Refrigerator-Freezers
and Ice Makers: Codes and Standards Enhancement Initiative For
PY2004: Title 20 Standards Development. 2004. Prepared by the
American Council for an Energy-Efficient Economy for Pacific Gas &
Electric Company, San Francisco, CA.
\48\ Koeller J., and H. Hoffman. A report on Potential Best
Management Practices. 2008. Prepared by Koeller and Company for the
California Urban Water Conservation Council, Sacramento, CA.
\49\ Navigant Consulting, Inc. Energy Savings Potential and R&D
Opportunities for Commercial Refrigeration. Final Report. 2009.
Submitted to the U.S. Department of Energy's Energy Efficiency and
Renewable Energy Building Technologies Program, Washington, DC.
---------------------------------------------------------------------------
With respect to the AHRI, NAFEM, and Follett comments about
refurbishment, DOE acknowledges that the increased size and prices of
automatic commercial ice makers arising from new and amended standards
could lead to equipment refurbishing or the purchase of used equipment.
DOE lacks sufficient information to explicitly model the extent of such
refurbishment but believes that it would not be significant enough to
change the rankings of TSLs. When DOE performed additional and recent
research on repair costs before issuance of the NODA, contractors
provided estimates of the hours to replace failed components such as
compressors, but some also stated that they recommended replacing the
ice maker instead of repairing it. In some cases the contractor
recommendations were based on relative repair or replacement costs and
warranties while in other cases they were based on the time it would
take to get the required, specific ice maker components. DOE also notes
that, given the engineering cost curves prepared for the final rule,
when the baseline efficiency distribution of current shipments is taken
into account, the average total cost increase faced by customers at TSL
3 is less than 3 percent. For these reasons, DOE believes that the
degree of refurbishing would not be significant enough to change the
rankings of the TSLs considered in this rule.
9. Compliance Date of Standards
EPCA prescribes that DOE must review and determine whether to amend
performance-based standards for cube type automatic commercial ice
makers by January 1, 2015. (42 U.S.C. 6313(d)(3)(A)) In addition, EPCA
requires that the amended standards established in this rulemaking must
apply to equipment that is manufactured on or after 3 years after the
final rule is published in the Federal Register 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. 6313(d)(3)(C)) For the NOPR analyses, based on the January
1, 2015 statutory deadline and giving manufacturers 3 years to meet the
new and amended standards, DOE assumed that the most likely compliance
date for the standards set by this rulemaking would be January 1, 2018.
As discussed in section IV.A.2, DOE received comments about the
compliance date, including requests to provide manufacturers 5 years to
meet the new and amended standards. As stated in section IV.A.2, DOE
believes that the modifications it made in the final rule analysis,
relative to the NOPR, will reduce the burden on manufacturers to meet
requirements established by this rule. Therefore, DOE has determined
that the 3-year period is adequate and is not extending the compliance
date for ACIMs. For the final rule, a compliance date of January 1,
2018 was used for the LCC and PBP analysis.
10. Base-Case and Standards-Case Efficiency Distributions
To estimate the share of affected customers who would likely be
impacted by a standard at a particular efficiency level, DOE's LCC
analysis considers the projected distribution of efficiencies of
equipment that customers purchase under the base case (that is, the
case without new energy efficiency standards). DOE refers to this
distribution of equipment efficiencies as a base-case efficiency
distribution.
For the NOPR, DOE estimated market shares of each efficiency level
within each equipment class based on an analysis of the automatic
commercial ice makers available for purchase by customers. DOE analyzed
all models available as of November 2012, calculated the percentage
difference between the baseline energy usage embodied in the ice maker
rulemaking analyses, and organized the available units by the
efficiency levels. DOE then calculated the percentage of available
models falling within each efficiency level bin. This efficiency
distribution was used in the LCC and other downstream analyses as the
baseline efficiency distribution.
At the NOPR public meeting ASAP noted that the efficiency
distribution used by DOE showed manufacturers can manufacture machines
meeting the efficiency levels proposed in the NOPR.
[[Page 4702]]
(ASAP, Public Meeting Transcript, No. 70 at p. 256-257) Ice-O-Matic and
Manitowoc stated that the distribution showed available equipment, but
the equipment at the higher efficiencies might have small shipments
relative to other efficiency levels. (Ice-O-Matic, Public Meeting
Transcript, No. 70 at p. 260; Manitowoc, Public Meeting Transcript, No.
70 at p. 261-263) Hoshizaki commented that DOE's shipments analysis
would be more accurate if DOE requested actual shipment data under NDA
from manufacturers each year. (Hoshizaki, No. 86 at p. 4) At the public
meeting, manufacturers and AHRI agreed to compile shipments information
by efficiency level.
In written comments, AHRI supplied such information for batch type
equipment. AHRI also stated that DOE should not use available models in
the AHRI database to estimate shipment-weighted market shares by
efficiency levels for batch type units, because by doing so, DOE
overestimates potential energy savings by 11.3% or more. (AHRI, No. 93
at p. 8-9)
For the final rule, DOE used the efficiency distribution for batch
type equipment provided by AHRI. While DOE did not analyze AHRI's
statement of the overestimate of savings, DOE does consider the
shipment-based distribution superior to the available-unit-based
distribution. Lacking a similar shipment-based distribution for
continuous equipment classes, DOE used an available-unit-based
distribution for continuous equipment classes for the final rule.
11. Inputs to Payback Period Analysis
Payback period is the amount of time it takes the customer to
recover the higher purchase cost of more energy-efficient equipment as
a result of lower operating costs. Numerically, the PBP is the ratio of
the increase in purchase cost to the decrease in annual operating
expenditures. This type of calculation is known as a ``simple'' PBP
because it does not take into account changes in operating cost over
time (i.e., as a result of changing cost of electricity) or the time
value of money; that is, the calculation is done at an effective
discount rate of zero percent. PBPs are expressed in years. PBPs
greater than the life of the equipment mean that the increased total
installed cost of the more-efficient equipment is not recovered in
reduced operating costs over the life of the equipment, given the
conditions specified within the analysis, such as electricity prices.
The inputs to the PBP calculation are the total installed cost to
the customer 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.
In written comments, Earthjustice stated that DOE inappropriately
used a 3-year payback period as an upper limit for an acceptable
customer impact without providing a justification for such, and that
DOE should revise its approach for using payback period. (Earthjustice,
No. 81, pp. 1-2) DOE acknowledges the comment and notes that, for the
NOPR, DOE intended the use of the payback period as an illustration of
the relatively significant differences between the impacts of TSLs.
12. Rebuttable Presumption Payback Period
EPCA (42 U.S.C. 6295(o)(2)(B)(iii) and 6313(d)(4)) established a
rebuttable presumption that new or amended standards are 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 that the consumer will receive during the first year as a
result of the standard, as calculated under the applicable test
procedure.
While DOE examined the rebuttable presumption criterion, it
considered whether the standard levels considered are economically
justified through a more detailed analysis of the economic impacts of
these levels pursuant to 42 U.S.C. 6295(o)(2)(B)(iii) and 6313(d)(4).
The results of this analysis served as the basis for DOE to evaluate
the economic justification for a potential standard level definitively
(thereby supporting or rebutting the results of any preliminary
determination of economic justification).
H. National Impact Analysis--National Energy Savings and Net Present
Value
The NIA assesses the NES and the NPV of total customer costs and
savings that would be expected as a result of the amended energy
conservation standards. The NES and NPV are analyzed at specific
efficiency levels (i.e., TSL) for each equipment class of automatic
commercial ice makers. 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 LCC analysis. For
the NOPR analysis, DOE forecasted the energy savings, operating cost
savings, equipment costs, and NPV of customer benefits for equipment
sold from 2018 through 2047--the year in which the last standards-
compliant equipment is shipped during the 30-year analysis.
DOE evaluates the impacts of the new and amended standards by
comparing base-case projections with standards-case projections. The
base-case projections characterize energy use and customer costs for
each equipment class in the absence of any new or amended energy
conservation standards. DOE compares these base-case projections with
projections characterizing the market for each equipment class if DOE
adopted the amended standards at each TSL. For the standards cases, DOE
assumed a ``roll-up'' scenario in which equipment at efficiency levels
that do not meet the standard level under consideration would ``roll
up'' to the efficiency level that just meets the proposed standard
level, and equipment already being purchased at efficiency levels at or
above the proposed standard level would remain unaffected.
DOE uses a Microsoft Excel spreadsheet model to calculate the
energy savings and the national customer costs and savings from each
TSL. Final rule TSD chapter 10 and appendix 10A explain the models and
how to use them, and interested parties can review DOE's analyses by
interacting with these spreadsheets. The models and documentation are
available at: https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/29.
The NIA spreadsheet model uses average values as inputs (rather
than 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 AEO2014 Reference
Case. In addition, DOE analyzed scenarios that used inputs from the
AEO2014 Low Economic Growth and High Economic Growth Cases. These cases
have lower and higher energy price trends, respectively, compared to
the Reference Case. NIA results based on these cases are presented in
chapter 10 of the final rule TSD.
A detailed description of the procedure to calculate NES and NPV
and inputs for this analysis are provided in chapter 10 of the final
rule TSD.
1. Shipments
Comments related to the shipment analysis received at the April
2014 public meeting were all questions for clarification. The following
description of the shipments projection presents the shipments analysis
for the final rule. The process described in this section
[[Page 4703]]
was documented and released for comments in the NODA.
DOE obtained data from AHRI, ENERGY STAR, and U.S. Census Bureau's
Current Industrial Reports (CIR) to estimate historical shipments for
automatic commercial ice makers. AHRI provided DOE with automatic
commercial ice maker shipment data for 2010 describing the distribution
of shipments by equipment class and by harvest capacity. AHRI data
provided to DOE also included an 11-year history of total shipments
from 2000 to 2010. DOE also collected total automatic commercial ice
maker shipment data for the period of 1973 to 2009 from the CIR.
Additionally, DOE collected 2008-2012 data on ACIM shipments under the
ENERGY STAR program. The ENERGY STAR data consisted of numbers of units
meeting ENERGY STAR efficiency levels and the percent of the total
market represented, from which the total market could be estimated.
ENERGY STAR shipments only pertained to air-cooled batch equipment.
In the preliminary analysis phase, DOE relied extensively on the
CIR shipments data for the shipments projection. Subsequent to
receiving comments on the preliminary analysis shipments, DOE relied
more heavily on AHRI data for the NOPR and for the final rule shipments
projections. After the NOPR analyses were completed, analysis of ENERGY
STAR data led DOE to conclude that the AHRI data understates shipments
by approximately 9 percent and that the difference was likely due to a
greater number of manufacturers represented in the ENERGY STAR results.
However, the AHRI data gives significantly greater detail than the
ENERGY STAR data. Therefore, the final rule and the NOPR methodologies
are identical except for an upward adjustment of the historical AHRI
data by 9 percent to correct for the presumed under-reporting of non-
AHRI-members.
To determine the percentage of shipments going to replace existing
stock and the percentage represented by new installations, DOE used the
CIR data to create a series of estimates of total existing stock by
aggregating historical shipments across 8.5-year historical periods.
DOE used the CIR data to estimate a time series of shipments and total
stock for 1994 to 2006--at the time of the analysis, the last year of
data available without significant gaps in the data due to disclosure
limitations. For each year, using shipments, stock, and the 8.5-year
life of the equipment, DOE estimated that, on average, 14 percent of
shipments were for new installations and the remainder for replacement
of existing stock.
DOE then used the historical AHRI shipments to create a 2010 stock
estimate. The 2010 stock and 2010 shipments from AHRI, disaggregated
between new installations and shipments for existing stock replacement,
were combined with projections of new construction activity from
AEO2014 to generate a forecast of shipments for new installations.
Stock and shipments were first disaggregated to individual business
types based on data developed for DOE on commercial ice maker
stocks.\50\ The business types and share of stock represented by each
type are shown in Table IV.29. Using a Weibull distribution assuming
that equipment has an average life of 8.5 years and lasts from 5 to 11
years, DOE developed a 30-year series of replacement ice maker
shipments using the AHRI historical series. Using the estimated 2010
shipments to new installations, and year-to-year changes in new
commercial sector floor space additions from AEO2014, DOE estimated
future shipments for new installations. (For the NOPR, DOE used AEO2013
projections of floor space additions.) The AEO2014 floor space
additions by building type are shown in Table IV.30. The combination of
the replacement and new installation shipments yields total shipments.
The final step was to distribute total sales to equipment classes by
multiplying the total shipments by percentage shares by class. Table
IV.31 shows the percentages represented by all equipment classes, both
the primary classes modeled explicitly in all NOPR analyses as well as
the secondary classes.
---------------------------------------------------------------------------
\50\ Navigant Consulting, Inc. Energy Savings Potential and R&D
Opportunities for Commercial Refrigeration. Final Report, submitted
to the U.S. Department of Energy. September 23, 2009. p. 41.
Table IV.29--Business Types Included in Shipments Analysis
------------------------------------------------------------------------
Building type
Building type as percent of
stock (%)
------------------------------------------------------------------------
Health Care............................................. 9
Lodging................................................. 33
Foodservice............................................. 22
Retail.................................................. 8
Education............................................... 7
Food Sales.............................................. 16
Office.................................................. 4
---------------
Total............................................... 100
------------------------------------------------------------------------
Table IV.30--AEO2014 Forecast of New Building Square Footage
--------------------------------------------------------------------------------------------------------------------------------------------------------
New construction
---------------------------------------------------------------------------------------------------------------
Year million ft\2\
---------------------------------------------------------------------------------------------------------------
Health Care Lodging Foodservice Retail Education Food sales Office
--------------------------------------------------------------------------------------------------------------------------------------------------------
2013.................................... 66 147 31 279 247 21 174
2018.................................... 67 164 51 428 209 36 411
2020.................................... 65 176 47 404 197 33 451
2025.................................... 63 181 48 444 169 34 392
2030.................................... 71 150 55 515 190 39 276
2035.................................... 72 207 57 527 228 40 415
2040.................................... 76 188 56 565 252 40 403
Annual Growth Factor, 2031-2040......... 2.4% 2.5% 2.4% 2.5% 1.7% 2.3% 2.1%
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4704]]
Table IV.31--Percent of Shipped Units of Automatic Commercial Ice Makers
------------------------------------------------------------------------
Percentage of
Equipment class shipments (%)
------------------------------------------------------------------------
IMH-W-Small-B........................................... 4.54
IMH-W-Med-B............................................. 2.90
IMH-W-Large-B........................................... 0.48
IMH-A-Small-B........................................... 27.08
IMH-A-Large-B........................................... 16.14
RCU-Small-B............................................. 5.43
RCU-RC/NC-Large-B....................................... 6.08
SCU-W-Small-B........................................... 0.68
SCU-W-Large-B........................................... 0.22
SCU-A-Small-B........................................... 13.85
SCU-A-Large-B........................................... 6.56
IMH-W-Small-C........................................... 0.68
IMH-W-Large-C........................................... 0.17
IMH-A-Small-C........................................... 3.53
IMH-A-Large-C........................................... 1.07
RCU-Small-C............................................. 0.83
RCU-Large-C............................................. 0.87
SCU-W-Small-C........................................... 0.15
SCU-W-Large-C........................................... 0.00
SCU-A-Small-C........................................... 8.75
SCU-A-Large-C........................................... 0.00
---------------
Total............................................... 100.00
------------------------------------------------------------------------
Source: AHRI, 2010 Shipments data submitted to DOE as part of this
rulemaking.
2. Forecasted Efficiency in the Base Case and Standards Cases
The method for estimating the market share distribution of
efficiency levels is presented in section IV.G.10, and a detailed
description can be found in chapter 10 of the final rule TSD. To
estimate efficiency trends in the standards cases, DOE uses a ``roll-
up'' scenario in its standards rulemakings. Under the ``roll-up''
scenario, DOE assumes that equipment efficiencies in the base case that
do not meet the standard level under consideration would ``roll up'' to
the efficiency level that just meets the proposed standard level, and
equipment already being purchased at efficiencies at or above the
standard level under consideration would be unaffected. Table IV.32
shows the shipment-weighted market shares by efficiency level in the
base-case scenario.
Table IV.32--Shipment-Weighted Market Shares by Efficiency Level, Base Case
--------------------------------------------------------------------------------------------------------------------------------------------------------
Market share by efficiency level Percent
Equipment class --------------------------------------------------------------------------------------------------
Level 1 Level 2 Level 3 Level 3A Level 4 Level 4A Level 5 Level 6 Level 7
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Small-B........................................ 37.1 15.6 44.8 ......... 2.5 0.0 0.0 ......... .........
IMH-W-Med-B.......................................... 55.8 20.0 15.3 ......... 8.9 ......... ......... ......... .........
IMH-W-Large-B
IMH-W-Large-B-1.................................. 87.2 12.8 ......... ......... ......... ......... ......... ......... .........
IMH-W-Large-B-2.................................. 87.2 12.8 ......... ......... ......... ......... ......... ......... .........
IMH-A-Small-B........................................ 23.7 29.5 46.8 0.0 0.0 ......... 0.0 0.0 .........
IMH-A-Large-B
IMH-A-Large-B-1.................................. 34.1 27.8 35.1 0.3 2.7 ......... ......... ......... .........
IMH-A-Large-B-2.................................. 16.8 22.5 60.8 ......... ......... ......... ......... ......... .........
RCU-Large-B
RCU-Large-B-1.................................... 43.9 36.4 18.8 ......... 1.0 ......... ......... ......... .........
RCU-Large-B-2.................................... 43.9 36.4 18.8 ......... 1.0 ......... ......... ......... .........
SCU-W-Large-B........................................ 71.6 0.6 0.0 ......... 22.5 ......... 5.4 0.0 .........
SCU-A-Small-B........................................ 51.8 15.3 12.9 ......... 8.0 ......... 12.0 0.0 0.0
SCU-A-Large-B........................................ 62.6 14.8 21.5 ......... 0.0 ......... 1.1 0.0 .........
IMH-A-Small-C........................................ 30.6 11.1 19.4 ......... 5.6 ......... 19.4 13.9 .........
IMH-A-Large-C........................................ 43.5 21.7 17.4 ......... 8.7 ......... 8.7 ......... .........
RCU-Small-C.......................................... 27.8 27.8 33.3 ......... 5.6 ......... 0.0 5.6 .........
SCU-A-Small-C........................................ 44.1 8.8 14.7 ......... 17.6 ......... 14.7 0.0 .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
3. National Energy Savings
For each year in the forecast period, DOE calculates the NES for
each TSL by multiplying the stock of equipment affected by the energy
conservation standards by the estimated per-unit annual energy savings.
DOE typically considers the impact of a rebound effect, introduced in
the energy use analysis, in its calculation of NES 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. When a rebound effect occurs, it is generally because
the users of the equipment perceive it as less costly to use the
equipment and elect to use it more intensively. In the case of
automatic commercial ice makers, users of the equipment include
restaurant wait staff, hotel guests, cafeteria patrons, or hospital
staff using ice in the treatment of patients. Users of automatic
commercial ice makers tend to have little or no perception of or
personal stake in the cost of the ice and rather are using the ice to
serve a specific need. Given this, DOE believes there is very little or
no potential for a rebound effect. For the NIA, DOE used a rebound
factor of 1, or no effect, for automatic commercial ice makers.
At the NOPR phase, the only comment regarding rebound effect was
from the Policy Analyst. Policy Analyst stated that DOE should evaluate
whether there was a rebound effect caused by the previous standard.
(Policy Analyst, No. 75 at p. 10) As stated above, DOE believes that
the users of ACIM equipment would not perceive the price effects, so
DOE believes rebound effect should not be present for this equipment
and does not believe further analysis is necessary.
Inputs to the calculation of NES are annual unit energy
consumption, shipments, equipment stock, and a site-to-source
conversion factor.
The annual unit energy consumption is the site energy consumed by
an automatic commercial ice maker unit in a given year. Using the
efficiency of units at each efficiency level and the baseline
efficiency distribution, DOE determined annual forecasted shipment-
weighted average equipment efficiencies
[[Page 4705]]
that, in turn, enabled determination of shipment-weighted annual energy
consumption values.
The automatic commercial ice makers stock in a given year is the
total number of automatic commercial ice makers shipped from earlier
years (up to 12 years earlier) that remain in use in that year. The NES
spreadsheet model keeps track of the total units shipped each year. For
purposes of the NES and NPV analyses in the NOPR analysis, DOE assumed
that, based on an 8.5-year average equipment lifetimes, approximately
12 percent of the existing automatic commercial ice makers are retired
and replaced in each year. DOE assumes that, for units shipped in 2047,
any units still remaining at the end of 2055 will be replaced.
DOE uses a multiplicative factor called ``site-to-source conversion
factor'' to convert site energy consumption (at the commercial
building) into primary or source energy consumption (the energy input
at the energy generation station required to convert and deliver the
energy required at the site of consumption). These site-to-source
conversion factors account for the energy used at power plants to
generate electricity and for the 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 amended energy conservation standards.
For this final rule, DOE used conversion factors based on the U.S.
energy sector modeling using the National Energy Modeling System (NEMS)
Building Technologies (NEMS-BT) version that corresponds to AEO2014 and
which provides national energy forecasts through 2040. Within the
results of NEMS-BT model runs performed by DOE, a site-to-source ratio
for commercial refrigeration was developed. The site-to-source ratio
was held constant beyond 2040 through the end of the analysis period
(30 years plus the life of equipment).
DOE has historically presented NES in terms of primary energy
savings. In response to the recommendations of a committee on ``Point-
of-Use and Full-Fuel-Cycle Measurement Approaches to Energy Efficiency
Standards'' appointed by the National Academy of Science, DOE announced
its intention to use full-fuel-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) 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.\51\
---------------------------------------------------------------------------
\51\ Docket ID: EERE-2010-BT-NOA-0028, comment by Kirk
Lundblade.
---------------------------------------------------------------------------
The approach used for this final rule, and the FFC multipliers that
were applied are described in appendix 10D of the final rule TSD. NES
results are presented in both primary and in terms of FFC savings. The
savings by TSL are summarized in terms of FFC savings in section I.C.
4. Net Present Value of Customer Benefit
The inputs for determining the NPV of the total costs and benefits
experienced by customers of the automatic commercial ice makers are (1)
total annual installed cost; (2) total annual savings in operating
costs; and (3) a discount factor. DOE calculated net national customer
savings for each year as the difference in installation and operating
costs between the base-case scenario and standards-case scenarios. DOE
calculated operating cost savings over the life of each piece of
equipment shipped in the forecast period.
DOE multiplied monetary values in future years by the discount
factor to determine the present value of costs and savings. DOE
estimated national impacts with both a 3-percent and a 7-percent real
discount rate as the average real rate of return on private investment
in the U.S. economy. These discount rates are used in accordance with
the Office of Management and Budget (OMB) guidance to Federal agencies
on the development of regulatory analysis (OMB Circular A-4, September
17, 2003), and section E, ``Identifying and Measuring Benefits and
Costs,'' therein. DOE defined the present year as 2013 for the NOPR
analysis. The 7-percent real value is an estimate of the average
before-tax rate of return to private capital in the U.S. economy. DOE
used the 3-percent rate to capture the potential effects of the new and
amended standards on private consumption. This rate represents the
``societal rate of time preference,'' which is the rate at which
society discounts future consumption flows to their present.
DOE received one comment from Ice-O-Matic stating that the 7-
percent discount rate was too high when the current prime rate is 3.25
percent and the current Treasury bill rate is 3.67 percent. (Ice-O-
Matic, No. 120, p. 1; Ice-O-Matic, No. 121, p. 1) Ice-O-Matic also
indicated that the use of 7-percent discount rate inflated the rate of
return experienced by customers. (Ice-O-Matic, No. 120, p. 1)
As Ice-O-Matic noted, the discount rate is high relative to current
interest rates. However, DOE suspects that the comments misinterpreted
the use of the discount rate. In this case, the discount rate is used
to express a given number of future dollars as an equivalent number of
dollars today, whereas the comments seemed to assume the discount rate
was used as an interest rate to express a given number of dollars today
as a future value equivalent. Since the 7-percent discount rate that
DOE used in the NIA is used in accordance with OMB guidelines, DOE will
continue using it in the NIA.
As discussed in section IV.G.1, DOE included a projection of price
trends in the preliminary analysis NIA. For the NOPR, DOE reviewed and
updated the analysis with the result that the projected reference case
downward trend in prices is quite modest. For the NOPR, DOE also
developed high and low case price trend projections, as discussed in
final rule TSD appendix 10B.
I. Customer Subgroup Analysis
In analyzing the potential impact of new or amended standards on
commercial customers, DOE evaluates the impact on identifiable groups
(i.e., subgroups) of customers, such as different types of businesses
that may be disproportionately affected. Small businesses typically
face a higher cost of capital. In general, the lower the cost of
electricity and higher the cost of capital, the more likely it is that
an entity would be disadvantaged by the requirement to purchase higher
efficiency equipment. Based on the data available to DOE, automatic
commercial ice maker ownership in three building types represent over
70 percent of the market: Food sales, foodservice, and hotels. Based on
data from the 2007 U.S. Economic Census and size standards set by the
U.S. Small Business Administration (SBA), DOE determined that a
majority of food sales, foodservice and lodging firms fall under the
definition of small businesses. Chapter
[[Page 4706]]
8 of the TSD presents the electricity price by business type and
discount rates by building types, respectively, while chapter 11
discusses these topics as they specifically relate to small businesses.
Comparing the foodservice, food sales, and lodging categories,
foodservice faces the highest energy price, with food sales and lodging
facing lower and nearly the same energy prices. Lodging faces the
highest cost of capital. Foodservice faces a higher cost of capital
than food sales. Given the cost of capital disparity, lodging was
selected for LCC subgroup analysis. With foodservice facing a higher
cost of capital, it was selected for LCC subgroup analysis because the
higher cost of capital should lead foodservice customers to value first
cost more and future electricity savings less than would be the case
for food sales customers.
Three written comments specifically focused on the customer
subgroups, all three specifically focusing on the food service
industry. U.S. Senator Toomey commented that the proposed rule will
negatively impact employment in the food services industry, which is
dominated by small businesses, and that restaurant owners would already
purchase efficient products if they were going to be able to recoup the
higher prices through savings. (U.S. Senator Toomey, No. 79 at p. 1)
NRA commented that the cost of new standards could be greater for small
businesses, due to increased capital, maintenance, repair, and
installation costs, thus affecting their payback period. (NRA, No. 69
at p. 2-3) NAFEM commented that the proposed rule will affect the food
service industry, which is also dominated by small businesses, because
they will not be able to afford equipment upgrades and will choose to
extend the life of used equipment. (NAFEM, No. 82 at p. 5)
With respect to the issue of negative employment impacts, if the
standard has a positive LCC benefit to the food service customer, such
an impact should not reduce employment. DOE notes that the LCC analysis
looks strictly at the net economic impact of a hypothetical purchase of
equipment and does not look specifically at employment. However, if the
analysis shows a net LCC benefit, the food service customer should be
better off and presumably such result should not negatively impact
employment. DOE agrees with the NRA comment that the cost of new
standards could be greater for small businesses and notes the analysis
of the impacts is precisely the point of the customer subgroup
analysis.
With respect to NAFEM's comment regarding small business's
inability to afford the equipment upgrades, if the results indicate
positive LCC benefits the presumption is that the customer's financial
situation is improved with the more efficient equipment when compared
to less efficient equipment. DOE lacks information with which to
estimate the extent to which customers might choose to extend the life
of equipment, but believes that given the relatively modest average
price increase of the proposed standard (approximately 3 percent) in
combination with the customer energy savings, the proportion of
customers who would choose life extension is small.
DOE estimated the impact on the identified customer subgroups using
the LCC spreadsheet model. The standard LCC and PBP analyses (described
in section IV.F) include various types of businesses that use automatic
commercial ice makers. For the LCC subgroup analysis, it was assumed
that the subgroups analyzed do not have access to national purchasing
accounts or to major capital markets thereby making the discount rates
higher for these subgroups. Details of the data used for LCC subgroup
analysis and results are presented in chapter 11 of the TSD.
J. Manufacturer Impact Analysis
1. Overview
DOE performed an MIA to estimate the impacts of new and amended
energy conservation standards on manufacturers of automatic commercial
ice makers. The MIA has both quantitative and qualitative aspects and
includes analyses of forecasted industry cash flows, the INPV,
investments in research and development (R&D) and manufacturing
capital, and domestic manufacturing employment. Additionally, the MIA
seeks to determine how amended energy conservation standards might
affect manufacturing employment, capacity, and competition, as well as
how standards contribute to overall regulatory burden. Finally, the MIA
serves to identify any disproportionate impacts on manufacturer
subgroups, in particular, small businesses.
The quantitative part of the MIA primarily relies on the Government
Regulatory Impact Model (GRIM), an industry cash flow model with inputs
specific to this rulemaking. The key GRIM inputs include data on the
industry cost structure, unit production costs, product shipments,
manufacturer markups, and investments in R&D and manufacturing capital
required to produce compliant products. A key GRIM output is the INPV,
which is the sum of industry annual cash flows over the analysis
period, discounted using the industry weighted average cost of capital.
Another key output is the impact to domestic manufacturing employment.
The model estimates the impacts of more-stringent energy conservation
standards on a given industry by comparing changes in INPV and domestic
manufacturing employment between a base case and the various TSLs in
the standards case. To capture the uncertainty relating to manufacturer
pricing strategy following amended standards, the GRIM estimates a
range of possible impacts under different markup scenarios.
The qualitative part of the MIA addresses manufacturer
characteristics and market trends. Specifically, the MIA considers such
factors as manufacturing capacity, competition within the industry, the
cumulative impact of other DOE and non-DOE regulations, and impacts on
small business manufacturers. The complete MIA is outlined in chapter
12 of the final rule TSD.
DOE conducted the MIA for this rulemaking in three phases. In Phase
1 of the MIA, DOE prepared a profile of the automatic commercial ice
maker industry. This included a top-down cost analysis of automatic
commercial ice maker manufacturers that DOE used to derive preliminary
financial inputs for the GRIM (e.g., revenues; materials, labor,
overhead, and depreciation expenses; selling, general, and
administrative expenses (SG&A); and R&D expenses). DOE also used public
sources of information to further calibrate its initial
characterization of the automatic commercial ice maker industry,
including company Securities and Exchange Commission (SEC) 10-K
filings,\52\ corporate annual reports, the U.S. Census Bureau's
Economic Census,\53\ and Hoover's reports.\54\
---------------------------------------------------------------------------
\52\ U.S. Securities and Exchange Commission. Annual 10-K
Reports. Various Years. https://sec.gov.
\53\ U.S.Census Bureau, Annual Survey of Manufacturers: General
Statistics: Statistics for Industry Groups and Industries. https://factfinder2.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t.
\54\ Hoovers Inc. Company Profiles. Various Companies. https://www.hoovers.com.
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In Phase 2 of the MIA, DOE prepared a framework industry cash flow
analysis to quantify the impacts of new and amended energy conservation
standards. The GRIM uses several factors to determine a series of
annual cash flows starting with the announcement of the standard and
extending over a 30-year period
[[Page 4707]]
following the effective date of the standard. These factors include
annual expected revenues, costs of sales, SG&A and R&D expenses, taxes,
and capital expenditures. In general, 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 changes in sales
volumes.
In addition, during Phase 2, DOE developed interview guides to
distribute to manufacturers of automatic commercial ice makers in order
to develop other key GRIM inputs, including product and capital
conversion costs, and to gather additional information on the
anticipated effects of energy conservation standards on revenues,
direct employment, capital assets, industry competitiveness, and
subgroup impacts.
In Phase 3 of the MIA, DOE conducted structured, detailed
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. As part of Phase 3, DOE
also evaluated subgroups of manufacturers that may be
disproportionately impacted by amended standards or that may not be
accurately represented by the average cost assumptions used to develop
the industry cash flow analysis. Such manufacturer subgroups may
include small manufacturers, low volume manufacturers, niche players,
and/or manufacturers exhibiting a cost structure that largely differs
from the industry average.
DOE identified one subgroup, small manufacturers, for which average
cost assumptions may not hold. DOE applied the small business size
standards published by the SBA to determine whether a company is
considered a small business. 65 FR 30836 (May 15, 2000), as amended by
65 FR 53533 (Sept. 5, 2000) and 67 FR 52597 (Aug. 13, 2002), as
codified at 13 CFR part 121. The Small Business Administration (SBA)
defines a small business for North American Industry Classification
System (NAICS) 333415, ``Air-Conditioning and Warm Air Heating
Equipment and Commercial and Industrial Refrigeration Equipment
Manufacturing,'' which includes commercial ice maker manufacturing, as
having 750 or fewer employees. The 750-employee threshold includes all
employees in a business's parent company and any other subsidiaries.
Based on this classification, DOE identified seven manufacturers of
automatic commercial ice makers that qualify as small businesses. The
automatic commercial ice maker small manufacturer subgroup is discussed
in chapter 12 of the final rule TSD and in section VI.B.1 of this
rulemaking.
2. Government Regulatory Impact Model
DOE uses the GRIM to quantify the changes in industry cash flows
resulting from new or amended energy conservation standards. The GRIM
uses manufacturer costs, markups, shipments, and industry financial
information to arrive at a series of base-case annual cash flows absent
new or amended standards, beginning in 2015 and continuing through
2047. The GRIM then models changes in costs, investments, shipments,
and manufacturer margins that may result from new or amended energy
conservation standards and compares these results against those in the
base-case forecast of annual cash flows. The primary quantitative
output of the GRIM is the INPV, which DOE calculates by summing the
stream of annual discounted cash flows over the full analysis period.
For manufacturers of automatic commercial ice makers, DOE used a real
discount rate of 9.2 percent, based on the weighted average cost of
capital as derived from industry financials and feedback received
during confidential interviews with manufacturers.
The GRIM calculates cash flows using standard accounting principles
and compares changes in INPV between the base case and each TSL. The
difference in INPV between the base case and a standards case
represents the financial impact of the amended standard on
manufacturers at that particular TSL. As discussed previously, DOE
collected the necessary information to develop key GRIM inputs from a
number of sources, including publicly available data and interviews
with manufacturers (described in the next section). The GRIM results
are shown in section V.B.2.a. Additional details about the GRIM can be
found in chapter 12 of the final rule TSD.
a. Government Regulatory Impact Model Key Inputs
Manufacturer Production Costs
Manufacturing higher efficiency equipment is typically more
expensive than manufacturing baseline equipment due to the use of more
complex, and typically more costly, components. The changes in the MPCs
of the analyzed equipment can affect the revenues, gross margins, and
cash flow of the industry, making production cost data key GRIM inputs
for DOE's analysis.
For each efficiency level of each equipment class that was directly
analyzed, DOE used the MPCs developed in the engineering analysis, as
described in section IV.B and further detailed in chapter 5 of the
final rule TSD. For equipment classes that were indirectly analyzed,
DOE used a composite of MPCs from similar equipment classes, substitute
component costs, and design options to develop an MPC for each
efficiency level. For equipment classes that had multiple units
analyzed, DOE used a weighted average MPC based on the relative
shipments of products at each efficiency level as the input for the
GRIM. Additionally, DOE used information from its reverse engineering
analysis, described in section IV.D.4, to disaggregate the MPCs into
material and labor costs. These cost breakdowns and equipment markups
were validated with manufacturers during manufacturer interviews.
Base-Case Shipments Forecast
The GRIM estimates manufacturer revenues based on total unit
shipment forecasts and the distribution of shipments by efficiency
level. Changes in sales volumes and efficiency mix over time can
significantly affect manufacturer finances. For the base-case analysis,
the GRIM uses the NIA's annual shipment forecasts from 2015, the base
year, to 2047, the end of the analysis period. See chapter 9 of the
final rule TSD for additional details.
Product Conversion Costs, Capital Conversion Costs, and Stranded Assets
New and amended energy conservation standards will cause
manufacturers to incur conversion costs to bring their production
facilities and product designs into compliance. For the MIA, DOE
classified these conversion costs into two major groups: (1) Product
conversion costs and (2) capital conversion costs. Product conversion
costs include investments in research, development, testing, marketing,
and other non-capitalized costs necessary to make product designs
comply with new or amended energy conservation standards. Capital
conversion costs include investments in property, plant, and equipment
necessary to adapt or change existing production facilities such that
new product designs can be fabricated and assembled.
If new or amended energy conservation standards require
[[Page 4708]]
investment in new manufacturing capital, there also exists the
possibility that they will render existing manufacturing capital
obsolete. In the case that this obsolete manufacturing capital is not
fully depreciated at the time new or amended standards go into effect,
this would result in the stranding of these assets, and would
necessitate the write-down of their residual un-depreciated value.
DOE used multiple sources of data to evaluate the level of product
and capital conversion costs and stranded assets manufacturers would
likely face to comply with new or amended energy conservation
standards. DOE used manufacturer interviews to gather data on the level
of investment anticipated at each proposed efficiency level and
validated these assumptions using estimates of capital requirements
derived from the product teardown analysis and engineering model
described in section IV.D.4. These estimates were then aggregated and
scaled using information gained from industry product databases to
derive total industry estimates of product and capital conversion costs
and to protect confidential information.
In general, DOE assumes that all conversion-related investments
occur between the year the final rule is published and the year by
which manufacturers must comply with the new or amended standards. The
investment figures used in the GRIM can be found in section V.B.2.a of
this preamble. For additional information on the estimated product
conversion and capital conversion costs, see chapter 12 of the final
rule TSD.
b. Government Regulatory Impact Model Scenarios
Markup Scenarios
As discussed in section IV.J.2.b MSPs include direct manufacturing
production costs (i.e., labor, material, overhead, and depreciation
estimated in DOE's MPCs) and all non-production costs (i.e., SG&A, R&D,
and interest), along with profit. To calculate the MSPs in the GRIM,
DOE applied manufacturer markups to the MPCs estimated in the
engineering analysis. 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 amended energy
conservation standards: (1) A preservation of gross margin percentage
markup scenario; and (2) a preservation of earnings before interest and
taxes (EBIT) markup scenario. These scenarios lead to different markups
values that, when applied to the 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 with efficiency, this
scenario implies that the absolute dollar markup will increase as well.
Based on publicly available financial information for manufacturers of
automatic commercial ice makers and comments from manufacturer
interviews, DOE assumed the industry average markup on production costs
to be 1.25. Because this markup scenario assumes that manufacturers
would be able to maintain their gross margin percentage as production
costs increase in response to new and amended energy conservation
standards, it represents a lower bound of industry impacts (higher
industry profitability) under new and amended energy conservation
standards.
In the preservation of EBIT markup scenario, manufacturer markups
are calibrated so that EBIT in the year after the compliance date of
the amended energy conservation standard is the same as in the base
case. Under this scenario, as the cost of production goes up,
manufacturers are generally required to reduce the markups on their
minimally compliant products to maintain a cost-competitive offering.
The implicit assumption behind this scenario is that the industry can
only maintain EBIT in absolute dollars after compliance with the
amended standard is required. Therefore, operating margin (as a
percentage) shrinks in the standards cases. This markup scenario
represents an upper bound of industry impacts (lower profitability)
under an amended energy conservation standard.
3. Discussion of Comments
During the NOPR public meeting, interested parties commented on the
assumptions and results of the analyses in the NOPR TSD. In addition,
interested parties submitted written comments on the assumptions and
results of the NOPR TSD and NODA. DOE summarizes the MIA related
comments below:
a. Conversion Costs
At the NOPR Stage, several stakeholders pointed out high capital
costs and intense redesign efforts would be required by the proposed
standards. Hoshizaki commented that many of the design options
suggested in this rulemaking would require manufacturers to modify or
buy new tooling and grow packaging, pallets, and conveyor belts to
accommodate larger machines. Hoshizaki noted that these costs would
compound to over $20 million in the first year. (Hoshizaki, No. 86 at
p. 7-8) Ice-O-Matic commented that DOE should directly consider the
capital expenditures associated with tooling changes as it is a
discrete expense that is not planned from year to year. (Ice-O-Matic,
Public Meeting Transcript, No. 70 at p. 88)
As suggested by Ice-O-Matic, DOE does consider conversion expenses
to be one-time expenditures that are not planned from year-to-year. DOE
models conversion investments, including capital expenditures, as
occurring between the announcement year and standards year. These
investments result in decreases in operating profit, free cash flow,
and INPV. DOE's conversion cost estimates account for all production
line modifications associated with the design options considered in the
engineering analysis including changes in conveyor, equipment, and
tooling. For the final rule, DOE made changes to the considered design
options based on feedback from the industry. DOE believes the changes
in design options will reduce the capital requirements on industry.
Several manufacturers noted that a significant portion of their
product lines would require redesign in order to meet the standard
levels proposed in the NOPR. Specifically, Manitowoc commented that 90%
of its models would require a major redesign to meet the proposed
standards. (Manitowoc, No. 92 at p. 2-3) Similarly, Hoshizaki commented
that about 80% of their continuous type units would not be able to meet
the proposed standards. (Hoshizaki, Public Meeting Transcript, No. 70
at p. 74) Hoshizaki noted in a written comment that over 75% of units
on the market will be unable to meet the proposed standard. (Hoshizaki,
No. 86 at p. 1) Scotsman commented that 97% of their product line would
need to be replaced in order to achieve the proposed efficiency levels.
(Scotsman, No. 85 at p. 2b) Emerson estimated 70% of the batch ice
machines would need some amount of redesign in order to meet the
proposed minimum efficiency levels at the NOPR stage. (Emerson, No. 122
at p. 1) AHRI commented that 99% of the existing batch type market
would be eliminated if the proposed TSL 3 became effective and that the
impact of NOPR TSL 3 would lead to industry consolidation, loss of
jobs, and loss of
[[Page 4709]]
international sales. (AHRI, No. 93 at p. 10-12) NAFEM noted general
concerns about product obsolescence at the NOPR levels. (NAFEM, No. 82
at p. 2)
Between the NOPR and the Final Rule, DOE revised and updated its
analysis based on stakeholders comments received at the NOPR public
meeting, in additional manufacturer interviews, and in written
responses to the NOPR and NODA. These updates included changes in its
approach to calculating the energy use associated with groups of design
options, changes in inputs for calculations of energy use and equipment
manufacturing cost, and consideration of space-constrained
applications. In response to the NOPR and NODA comments, DOE adjusted
the design options it considered to reduce impacts on the industry. A
discussion of these changes can be found in section IV.D.3. After
applying the change to the analyses, the efficiency levels that DOE
determined to be cost-effective changed considerably. These revised
TSLs are presented in section V.A.
When compared to the NOPR levels, DOE believes the revised levels
proposed in section V.A will reduce the burdens on industry. Table
IV.33 below presents the portion of model that DOE estimates would
require redesign at the various final rule TSLs.
Table IV.33--Portion of Industry Models Requiring Redesign at Final Rule TSLs
----------------------------------------------------------------------------------------------------------------
Percent of models failing at each TSL
----------------------------------------------------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 Total
----------------------------------------------------------------------------------------------------------------
Batch..................................................... 27% 39% 51% 66% 84% 100%
Continuous................................................ 29 41 55 55 78 100
-----------------------------------------------------
Total................................................. 28 40 52 63 82 100
----------------------------------------------------------------------------------------------------------------
b. Cumulative Regulatory Burden
NRA and NAFEM both commented that DOE should consider the impacts
of the cumulative regulatory burden of rulemakings, including energy
conservation standards for CRE and walk-in units as well as EPA
rulemakings on refrigerants, and standards imposed nearly
simultaneously on equipment manufacturers. (NRA, No. 69 at pp. 3-4)
(NAFEM, No. 82 at pp. 6-7)
DOE is instructed to consider all Federal, product-specific burdens
that go into effect within 3 years of the compliance date of this final
rule. The list of other standards considered in the cumulative
regulatory burden analysis can be found in section V.B.2.g. DOE has
included the energy conservation standard final rules for walk-in
coolers and freezers final rule and the commercial refrigeration
equipment final rule. DOE has not included the EPA SNAP rulemaking in
this analysis. Because that rulemaking is in the NOPR stage and is not
finalized at this time, any estimation of the impact or effective dates
would be speculative.
c. SNAP and Compliance Date Considerations
AHRI stated that the burden imposed by a potential changes in
refrigerants is significant and will require major redesign just to
maintain current efficiency levels. (AHRI, No. 168 at p. 5) AHRI urged
DOE to extend the compliance period to five years or put a hold on the
ACIM standards rulemaking until the SNAP refrigerants are finalized in
order to avoid another redesign during the compliance period of the
amended ACIM energy conservation standard. (AHRI, No. 70 at p. 16)
Emerson also supported the idea of DOE starting the three-year
compliance period after EPA finalizes a decision on refrigerants,
allowing manufactures of components and equipment to re-design for both
energy efficiency and low-GWP refrigerants in one design cycle.
(Emerson, No. 122 at p.1) Ice-O-Matic proposed either a five year
compliance period for the NODA TSL 3 or that DOE chose a lower standard
level. (Ice-O-Matic, No. 121 at p. 2) Manitowoc stated that commercial
ice makers are not within the current scope of the SNAP NOPR, however
it believes that ice makers could be affected by a subsequent
rulemaking. Furthermore, Manitowoc noted that even if there is no
action on ice makers, the component suppliers to the ice maker industry
(including suppliers of compressors, expansion valves, and heat
exchangers) will be focusing their efforts on supporting the transition
to SNAP refrigerants. Consequently, the commercial ice maker industry
will be affected even if it is not directly covered by EPA rules.
Manitowoc also supported a course of action to reduce the risk of
multiple redesigns due to the refrigerant changes and an amended energy
conservation standard. (Manitowoc, No. 126 at p. 3) NEEA expressed
their support for DOE's current refrigerant-neutral position. (NEEA,
No. 91 at p. 2)
Since the SNAP rulemaking is in the NOPR stage and not finalized at
this time, any estimation of the impact or effectives dates would be
speculative, however in its August 6, 2014 proposal, EPA did not list
ACIM as a product that would be impacted by forthcoming regulations (82
FR 46126). DOE cannot speculate on the outcome of a rulemaking in
progress and can only consider in its rulemakings regulations that are
currently in effect. Therefore, DOE has not included possible outcomes
of a potential EPA SNAP rulemaking.
In response to the request that DOE extend the compliance date
period for automatic commercial ice makers beyond the 3 years specified
by the NOPR, as stated in section IV.A.2, DOE has determined that the 3
year compliance period is adequate and is not extending the compliance
date for ACIMs. In response to AHRI's comment that DOE should put a
hold on the ACIM standards rulemaking until the SNAP refrigerants are
finalized, EPCA prescribes that DOE must issue a final rule
establishing energy conservation standards for automatic commercial ice
makers not later than January 1, 2015 and DOE does not have the
authority to alter this statutory mandate. (42 U.S.C. 6313(d)(3))
d. ENERGY STAR
Manitowoc and Hoshizaki noted that the proposed standard bypasses
the ENERGY STAR level (Manitowoc, Public Meeting Transcript, No. 70 at
p. 74; Hoshizaki, No. 86 at p. 1) Manitowoc expressed concern that, if
efficiency standards were raised to the level proposed in the NOPR,
there would be no more room for an ENERGY STAR category, which would be
disruptive to the industry. (Manitowoc, Public Meeting Transcript, No.
70 at p. 74)
DOE acknowledges the importance of the ENERGY STAR program and of
understanding its interaction with
[[Page 4710]]
energy efficiency standards. However, EPCA requires DOE to establish
energy conservation standards at the maximum level that is
technologically feasible and economically justified. The standard level
considered in this final rule is estimated to reduce cumulative source
energy usage by 8% percent over the baseline, for products purchased in
2018-2047. Comparatively, the max-tech level is estimated to reduce
cumulative source energy usage by 14% percent over the baseline for the
same time period (refer to section V.B.3 for a complete discussion of
energy savings). As such, the standard level continues to leave room
for ENERGY STAR rebate programs, and therefore new ENERGY STAR levels
could be reestablished once compliance with these standards is
required.
e. Request for DOE and EPA Collaboration
Hoshizaki commented that during a previous round of refrigerant
changeovers, it took over five years to make the appropriate changes to
their product line and that it would take even longer this time due to
the highly flammable refrigerant alternatives under consideration that
would require additional redesign work. Hoshizaki requested that DOE
and EPA work together to ensure that manufacturers are not unduly
burdened with standards from both agencies. (Hoshizaki, No. 86 at p. 6-
7)
DOE recognizes that the combined effects of recent or impending
regulations may have serious consequences for some manufacturers,
groups of manufacturers, or an entire industry. As such, DOE conducts
an analysis of the cumulative regulatory burden as part of its
rulemakings pertaining to equipment efficiency. As stated previously,
however, DOE cannot speculate on the outcome of a rulemaking in
progress and can only consider in its rulemakings regulations that are
currently in effect. If a manufacturer believes that its design is
subjected to undue hardship by regulations, the manufacturer may
petition DOE's Office of Hearing and Appeals (OHA) for exception relief
or exemption from the standard pursuant to OHA's authority under
section 504 of the DOE Organization Act (42 U.S.C. 7194), as
implemented at subpart B of 10 CFR part 1003. OHA has the authority to
grant such relief on a case-by-case basis if it determines that a
manufacturer has demonstrated that meeting the standard would cause
hardship, inequity, or unfair distribution of burdens.
f. Compliance With Refrigerant Changes Could Be Difficult
NAFEM commented that municipal and state regulations and codes may
make it difficult to comply with proposed EPA refrigerant regulations
in some localities and could create hardship for manufacturers. (NAFEM,
No. 82 at p. 7)
This comment relates to proposed EPA refrigerant regulations, and
is beyond the scope of this rulemaking. DOE has forwarded the comment
to EPA's Stratospheric Protection Division.
g. Small Manufacturers
NAFEM notes that the proposed rule has a disparate impact on small
businesses because commercial ice makers are largely manufactured by
small businesses. (NAFEM, No. 82 at p. 5) AHRI agreed that this
rulemaking has impacts on small businesses and requested DOE account
for all small ACIM manufacturers. (AHRI, No. 93 at p. 12)
DOE recognizes the potential for this rule to affect small
businesses. As a result, DOE presented a small business manufacturer
sub-group analysis in the NOPR stage and in this final rule notice. DOE
used industry trade association membership directories, public product
databases, individual company Web sites, and other market research
tools to establish a draft list of covered small manufacturers. DOE
presented its draft list of covered small manufacturers to stakeholders
and industry representatives and asked if they were aware of any other
small manufacturers that should be added to the list during
manufacturer interviews and at DOE public meetings. DOE identified
seven small manufacturers at the NOPR stage. Stakeholders did not
provide any information in interviews or comments that identified
additional small manufacturers of automatic commercial ice makers. As
discussed in section VI.B, DOE applied the small business size
standards published by the SBA to determine whether a company is
considered a small manufacturer. The SBA defines a small business for
NAICS 333415 ``Air-Conditioning and Warm Air Heating Equipment and
Commercial and Industrial Refrigeration Equipment Manufacturing'' as
having 750 or fewer employees. The 750-employee threshold includes all
employees in a business's parent company and any other subsidiaries.
Given the lack of additional new information, DOE maintains that there
are seven small business manufacturers of the covered product in the
Final Regulatory Flexibility Analysis, found in section VI.B.
NAFEM did not provide any data supporting the suggestion that the
majority of domestic ice maker sales are from small manufacturers.
Based on a 2008 study by Koeller & Company,\55\ DOE understands that
the ACIM market is dominated by four manufacturers who produce
approximately 90 percent of the automatic commercial ice makers for
sale in the United States. The four major manufacturers with the
largest market share are Manitowoc, Scotsman, Hoshizaki, and Ice-O-
Matic; none of which are consider small business manufacturers. The
remaining 12 large and small manufacturers account for ten percent of
domestic sales. Thus, DOE disagrees with NAFEM's statement that a
majority of sales are from small manufacturers.
---------------------------------------------------------------------------
\55\ Koeller, John, P.E., and Herman Hoffman, P.E. A Report on
Potential Best Management Practices. Rep. The California Urban Water
Conservation Council, n.d. Web. 19 May 2014.
---------------------------------------------------------------------------
h. Large Manufacturers
Scotsman commented that DOE's INPV analysis ignores manufacturers'
current financial stability and noted that the impacts on large
manufacturers could be significantly more severe than the average.
(Scotsman, No. 85 at p.6b)
The MIA does not forecast the financial stability of individual
manufacturers. The MIA is an industry-level analysis. Inherent to this
analysis is that fact that not all industry participants will perform
equally.
i. Negative Impact on Market Growth
Follett and Hoshizaki commented that more stringent standards have
an adverse impact on innovation and development of new products.
Follett commented that DOE's analysis must account for the lost
opportunity to initiate growth projects that would expand the market.
(Follett, No. 84 at p.10) (Hoshizaki, No.86 at p.4) NRA commented that
the cost of R&D would be passed on to end-users, causing them to delay
purchasing new equipment and thus negatively affecting the ice machine
industry. (NRA, No. 69 at p. 4)
The MIA uses the annual shipments forecast from the Shipment's
Analysis as an input in the GRIM. The Shipments Analysis provides the
base case shipments as well as standards case shipments. The analysis
uses data from AHRI, ENERGY STAR, and U.S. Census Bureau's Current
Industrial Reports (CIR) to estimate historical shipments for automatic
commercial ice makers. Future shipments are broken down into
replacement units based on a stock accounting model; new sales based on
[[Page 4711]]
projections of new construction activity from AEO2014. More detail on
this methodology can be found in section IV.H.1. DOE's analysis does
not speculate on additional shipments that are the result of ``growth
projects.'' Manufacturers did not provide estimations of these growth
levels or justification for such growth levels. Thus, DOE was not able
to include such growth factors in its models.
j. Negative Impact on Non-U.S. Sales
Follett added that the additional cost of efficient components
would impact non-U.S. sales. (Follett, No. 84 at p.7) Ice-O-Matic
commented that they can't afford designs that can only be sold in North
America and that they will lose global busines. (Ice-O-Matic, No. 70 at
p.308) Scotsman stated it will be a challenge to meet DOE efficiency
thresholds, the EPA SNAP regulations and EU regulations with common
equipment platforms. Scotsman continued that the regulations will make
it difficult for domestic manufacturers to compete in the global
market, where the customers' primary decision criterion is sales price.
(Scotsman, No.125 at p. 2-3) Scotsman requested DOE's analysis account
for the impact that regulations will have on manufacturers' ability to
compete in a global market against cheaper products not governed by DOE
standards. (Scotsman, No.70 at p.43-44)
The standards in this final rule only cover equipment placed into
commerce in the domestic market, and as such, do not restrict
manufacturers from selling products below the new and amended standards
in foreign markets. DOE notes that manufacturers make products today
that meet the standard set by the 2005 energy conservation standard for
automatic commercial ice makers and are able to compete against
manufacturers with production lines in lower cost countries. In their
comments, manufacturers did not provide any information as to which
product models or which efficiencies are sold into international
markets. If the models sold internationally have efficiencies that
exceed the amended standard, then manufacturers will likely see a
production cost decrease as sales roll-up to the new standard and
production volumes increase. It is also possible that manufacturer
production costs could increase marginally due to small production
runs. However, stakeholders did not provide enough information for DOE
to model the price-sensitivity of the foreign market.
k. Employment
Ice-O-Matic commented that, if the market loses net present value,
companies are not going to accept less profit, and so there's no way
they can employ the same number of people unless they reduce their pay.
(Ice-O-Matic, No. 70 at p.313) In the NOPR public meeting, AHRI,
Scotsman, and Ice-o-matic noted concerns about DOE direct employment
estimates being too low. (No. 70 at p.320-330)
DOE analyzes the potential impacts of the energy conservation
standard on direct production labor in section V.B.2.d. This analysis
estimates the production head count, including production workers up to
the line-supervisor level who are directly involved in fabricating and
assembling a product within an original equipment manufacturer (OEM)
facility. It does not account for sales, engineering, management, and
all other workers who are not directly producing and assembling
product. DOE presents an upper and lower bound for direct employment.
DOE does not assert that employment will remain steady throughout the
analysis period.
In the NOPR, DOE clearly stated the assumptions that contributed to
its estimate of direct production employment. These assumptions
included: Unit sales, labor content per unit sold, average hourly wages
for production workers, and annual hours worked by production workers.
The calculation of production employment is discussed in detail in
chapter 12 of the TSD, section 12.7. In the NOPR and NODA comments, DOE
did not receive any comments on these key production employment
assumptions. However, DOE updated its final rule analysis based on a
revised engineering analysis, shipments analysis, and trial standard
levels.
l. Compliance With 12866 and 13563
NAFEM commented that DOE is in violation of Executive Orders 12866
and 13563. (NAFEM, No. 82 at p.8) DOE has fulfilled the obligations
required by Executive Orders 12866 and 13563. Additional information
can be found in section VI of this preamble.
m. Warranty Claims
Scotsman noted concern that the MIA results had not ``accurately
accounted for warranty increases''. (Scotsman, No.125 at p.3)
Specifically, it noted that an ECM condenser fan motor would cost
significantly more than its current component.
DOE did not explicitly factor in changes in warranty set-asides or
payments. In interviews, DOE requested manufacturers highlight key
concerns related to the rulemaking. Warranty concerns were not cited as
a key issue. In order for DOE to account for changes in warranty costs,
manufacturers would need to provide data on current product failure
rates, causes of failure and related repair costs, expected future
warranty rates, and changes in expected repair costs. Insufficient
information was provided to model a change in warranty reserve and
warranty pay out. Aside from the Scotsman data point on the cost of ECM
fan motors, no other manufacturer supplied hard data related to
warranty expenses. As a result, DOE did not incorporate a change in
warranty rate in its analysis.
n. Impact to Suppliers, Distributors, Dealers, and Contractors
AHRI commented that DOE must perform analyses to assess the impacts
of the final rule on component suppliers, distributors, dealers, and
contractors. Policy Analyst also suggested that DOE assess whether
suppliers are affected by the proposed standard. (Policy Analyst, No.
75 at p. 10) The MIA assesses the impact of amended energy conservation
standards on manufacturers of automatic commercial ice makers. Analysis
of the impacts on distributors, dealers, and contractors as a result of
energy conservation standards on manufacturers of automatic commercial
ice makers falls outside the scope of this analysis.
Impacts on component suppliers might arise if manufacturers
switched to more-efficient components, or if there was a substantial
reduction in sales orders following new or amended standards. In public
comments and in confidential interviews, manufacturers expressed that
given their low production volumes, the automatic commercial ice maker
manufacturing industry has little influence over component suppliers
relative to other commercial refrigeration equipment industries.
(Manitowoc, Preliminary Analysis Public Meeting Transcript, No. 42 at
pp. 14-15). It follows that energy conservation standards for automatic
commercial ice makers would have little impact on component suppliers
given their marginal contribution to overall commercial refrigeration
component demand.
K. Emissions Analysis
In the emissions analysis, DOE estimated the reduction in power
sector emissions of CO2, NOX, SO2, and
Hg from potential energy conservation standards for automatic
commercial ice
[[Page 4712]]
makers. 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), 77 FR 49701 (Aug. 17, 2012)) the FFC analysis
includes impacts on emissions of CH4 and N2O,
both of which are recognized as greenhouse gases (GHGs).
DOE primarily conducted the emissions analysis using emissions
factors for CO2 and most of the other gases derived from
data in the AEO2014. Combustion emissions of CH4 and
N2O were estimated using emissions intensity factors
published by the Environmental Protection Agency (EPA), GHG Emissions
Factors Hub.\56\ DOE developed separate emissions factors for power
sector emissions and upstream emissions. The method that DOE used to
derive emissions factors is described in chapter 13 of the final rule
TSD.
---------------------------------------------------------------------------
\56\ https://www.epa.gov/climateleadership/inventory/ghg-emissions.html.
---------------------------------------------------------------------------
For CH4 and N2O, DOE calculated emissions
reduction in tons and also in terms of units of carbon dioxide
equivalent (CO2eq). Gases are converted to CO2eq
by multiplying the physical units by the gases' global warming
potential (GWP) over a 100-year time horizon. Based on the Fourth
Assessment Report of the Intergovernmental Panel on Climate Change,\57\
DOE used GWP values of 28 for CH4 and 265 for
N2O.
---------------------------------------------------------------------------
\57\ Intergovernmental Panel on Climate Change. Climate Change
2013: The Physical Science Basis. Contribution of Working Group I to
the Fifth Assessment Report of the Intergovernmental Panel on
Climate Change. 2013. Stocker, T.F., D. Qin, G.-K. Plattner, M.
Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M.
Midgley (eds.). Cambridge University Press, Cambridge, United
Kingdom and New York, NY, USA. Chapter 8.
---------------------------------------------------------------------------
EIA prepares the AEO using NEMS. Each annual version of NEMS
incorporates the projected impacts of existing air quality regulations
on emissions. AEO2014 generally represents current legislation and
environmental regulations, including recent government actions, for
which implementing regulations were available as of October 31, 2013.
SO2 emissions from affected electric generating units
(EGUs) are subject to nationwide and regional emissions cap-and-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 U.S. Environmental Protection Agency (EPA) by the U.S.
Court of Appeals for the District of Columbia Circuit but it remained
in effect.\58\ In 2011 EPA issued a replacement for CAIR, the Cross-
State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). On
August 21, 2012, the D.C. Circuit issued a decision to vacate
CSAPR.\59\ The court ordered EPA to continue administering CAIR. The
emissions factors used for this final rule, which are based on AEO2014,
assume that CAIR remains a binding regulation through 2040.\60\
---------------------------------------------------------------------------
\58\ See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008);
North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008).
\59\ See EME Homer City Generation, LP v. EPA, 696 F.3d 7, 38
(D.C. Cir. 2012).
\60\ On April 29, 2014, the U.S. Supreme Court reversed the
judgment of the D.C. Circuit and remanded the case for further
proceedings consistent with the Supreme Court's opinion. The Supreme
Court held in part that EPA's methodology for quantifying emissions
that must be eliminated in certain states due to their impacts in
other downwind states was based on a permissible, workable, and
equitable interpretation of the Clean Air Act provision that
provides statutory authority for CSAPR. See EPA v. EME Homer City
Generation, No 12-1182, slip op. at 32 (U.S. April 29, 2014).
Because DOE is using emissions factors based on AEO2014 for today's
final rule, the analysis assumes that CAIR, not CSAPR, is the
regulation in force. The difference between CAIR and CSAPR is not
relevant for the purpose of DOE's analysis of SO2
emissions.
---------------------------------------------------------------------------
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 2016, however, SO2 emissions will fall as a
result of the Mercury and Air Toxics Standards (MATS) for power plants.
77 FR 9304 (Feb. 16, 2012). 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. AEO2014 assumes that, in order
to continue operating, coal plants must have either flue gas
desulfurization or dry sorbent injection systems installed by 2016.
Both technologies are used to reduce acid gas emissions, and also
reduce SO2 emissions. Under the MATS, emissions will be far
below the cap established by CAIR, 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 2016 and beyond.
CAIR established a cap on NOX emissions in 28 eastern
States and the District of Columbia.\61\ Energy conservation standards
are expected to have little effect on NOX emissions in those
States covered by CAIR 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 this final rule
for these States.
---------------------------------------------------------------------------
\61\ CSAPR also applies to NOX and it would supersede
the regulation of NOX under CAIR. As stated previously,
the current analysis assumes that CAIR, not CSAPR, is the regulation
in force. The difference between CAIR and CSAPR with regard to DOE's
analysis of NOX emissions is slight.
---------------------------------------------------------------------------
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 AEO2014, which
incorporates the MATS.
In response to the NOPR, DOE received one comment specifically
about measuring environmental benefits. Policy Analyst stated that DOE
should commit to measuring environmental benefits and reductions in
energy usage as a result of these standards. (Policy Analyst, No. 75 at
p. 10) DOE has invested a great deal of time and effort in quantifying
the energy reductions and environmental benefits of this rule, as
described in this section and as described in the discussion of the
[[Page 4713]]
NIA (IV.H). Given the dispersed nature of automatic commercial ice
makers on customer premises across the country, actual physical
measurement of the energy savings and environmental benefits would be a
large and costly undertaking which would likely not yield useful
results. However, DOE is committed to working with other governmental
agencies to continue developing tools for quantifying the environmental
benefits of proceedings such as this ACIM rulemaking. The discussion
that follows of the development of the social cost of carbon (SCC) is
the prime example of these efforts.
L. Monetizing Carbon Dioxide and Other Emissions Impacts
As part of the development of the standards in this final rule, DOE
considered the estimated monetary benefits 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 equipment
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 this final rule, DOE is relying on a set of values for the
social cost of carbon (SCC) that was developed by an interagency
process. The basis for these values is summarized below, and a more
detailed description of the methodologies used is provided as an
appendix to chapter 14 of the final rule TSD.
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 CO2. A domestic SCC value is
meant to reflect the value of damages in the United States resulting
from a unit change in CO2 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. 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.
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
CO2 emissions, the analyst faces a number of serious
challenges. A report from the National Research Council \62\ 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.
---------------------------------------------------------------------------
\62\ National Research Council. Hidden Costs of Energy: Unpriced
Consequences of Energy Production and Use. National Academies Press:
Washington, DC (2009).
---------------------------------------------------------------------------
Despite the limits of both quantification and monetization, SCC
estimates can be useful in estimating the social benefits of reducing
CO2 emissions. 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.
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. Development of Social Cost of Carbon Values
In 2009, an interagency process was initiated to offer a
preliminary assessment of how best to quantify the benefits from
reducing CO2 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 peer-reviewed 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
[[Page 4714]]
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 higher-than-expected impacts from temperature
change further out in the tails of the SCC distribution. The values
grow in real terms over time. 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,
although preference is given to consideration of the global benefits of
reducing CO2 emissions. Table IV.34 presents the values in
the 2010 interagency group report,\63\ which is reproduced in appendix
14A of the TSD.
---------------------------------------------------------------------------
\63\ 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. www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.
Table IV.34--Annual SCC Values From 2010 Interagency Report, 2010-2050
[2007 dollars per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate (%)
---------------------------------------------------------------
5 3 2.5 3
Year ---------------------------------------------------------------
95th
Average Average Average percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 4.7 21.4 35.1 64.9
2015............................................ 5.7 23.8 38.4 72.8
2020............................................ 6.8 26.3 41.7 80.7
2025............................................ 8.2 29.6 45.9 90.4
2030............................................ 9.7 32.8 50.0 100.0
2035............................................ 11.2 36.0 54.2 109.7
2040............................................ 12.7 39.2 58.4 119.3
2045............................................ 14.2 42.1 61.7 127.8
2050............................................ 15.7 44.9 65.0 136.2
----------------------------------------------------------------------------------------------------------------
The SCC values used for this rulemaking were generated using the
most recent versions of the three integrated assessment models that
have been published in the peer-reviewed literature.\64\ (See appendix
14-B of the final rule TSD for further information.) Table IV.35 shows
the updated sets of SCC estimates in 5-year increments from 2010 to
2050. The full set of annual SCC estimates between 2010 and 2050 is
reported in appendix 14-B of the final rule 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.
---------------------------------------------------------------------------
\64\ 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; revised November 2013. www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf
Table IV.35--Annual SCC Values From 2013 Interagency Update, 2010-2050
[2007 dollars per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate (%)
---------------------------------------------------------------
5 3 2.5 3
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 11 32 51 89
2015............................................ 11 37 57 109
2020............................................ 12 43 64 128
2025............................................ 14 47 69 143
2030............................................ 16 52 75 159
2035............................................ 19 56 80 175
2040............................................ 21 61 86 191
2045............................................ 24 66 92 206
2050............................................ 26 71 97 220
----------------------------------------------------------------------------------------------------------------
[[Page 4715]]
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 in section IV.L.1.a 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 analytic
challenges that are being 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 2013$ using the Gross Domestic
Product price deflator. For each of the four cases of SCC values, the
values for emissions in 2015 were $12.0, $40.5, $62.4, and $119 per
metric ton of CO2 avoided. 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.
In responding to the NOPR, many commenters questioned why DOE
quantified the emissions. Commenters also questioned the scientific and
economic basis of the SCC values.
Scotsman stated they did not understand the logic of predicting
emissions reductions associated with a product with such a limited
population relative to national average energy consumption. (Scotsman,
No. 95 at page 7) As stated earlier in the SCC discussion, DOE
quantifies emissions reductions as one of the societal impacts of all
standards in accordance with section 1(b) of Executive Order 12866.
A number of stakeholders stated that DOE should not use SCC values
to establish monetary figures for emissions reductions until the SCC
undergoes a more rigorous notice, review, and comment process. (AHRI,
No. 93 at pp. 13-14; The Associations, No. 77 at p. 4) The Cato
Institute commented that SCC should be barred from use until its
deficiencies are rectified. (Cato Institute, No. 74 at p. 1) Similarly,
IER stated that SCC should no longer be used in Federal regulatory
analysis and rulemakings. (IER, No. 83 at p. 2) In contrast, IPI et al.
affirmed that current SCC values are sufficiently robust and accurate
for continued use in regulatory analyses. (IPI, No. 78 at p. 1)
In conducting the interagency process that developed the SCC
values, 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. Key
uncertainties and model differences transparently and consistently
inform the range of SCC estimates. These uncertainties and model
differences are discussed in the interagency working group's reports,
which are reproduced in appendix 14A and 14B of the TSD, as are the
major assumptions. The 2010 SCC values have been used in a number of
Federal rulemakings upon which the public had opportunity to comment.
In November 2013, the OMB announced a new opportunity for public
comment on the TSD underlying the revised SCC estimates. See 78 FR
70586 (Nov. 26, 2013). OMB is currently reviewing comments and
considering whether further revisions to the 2013 SCC estimates are
warranted. DOE stands ready to work with OMB and the other members of
the interagency working group on further review and revision of the SCC
estimates as appropriate.
IER commented that the SCC is inappropriate for use in federal
rulemakings because it is based on subjective modeling decisions rather
than objective observations and because it violates OMB guidelines for
accuracy, reliability, and freedom from bias. (IER, No. 83 at p. 2) The
General Accounting Office (GAO) was asked to review the Interagency
Working Group's (IWG) development of SCC estimates,\65\ and noted that
OMB and EPA participants reported that the IWG documented all major
issues consistent with Federal standards for internal control. The GAO
also found, according to its document review and interviews, that the
IWG's development process followed three principles: (1) It used
consensus-based decision making; (2) it relied on existing academic
literature and models; and (3) it took steps to disclose limitations
and incorporate new information. Further, DOE has sought to ensure that
the data and research used to support its policy decisions--including
the SCC values--are of high scientific and technical quality and
objectivity, as called for by the Secretarial Policy Statement on
Scientific Integrity.\66\ See section VI.L for DOE's evaluation of this
final rule and supporting analyses under the DOE and OMB information
quality guidelines.
---------------------------------------------------------------------------
\65\ www.directives.doe.gov/directives-documents/400-series/0411.2-APolicy.
\66\ www.gao.gov/products/GAO-14-663.
---------------------------------------------------------------------------
The Cato Institute stated that the determination of the SCC is
discordant with the best scientific literature on the equilibrium
climate sensitivity and the fertilization effect of CO2--two
critically important parameters for establishing the net externality of
CO2 emissions. (Cato Institute, No. 74 at pp. 1, 12-15) The
revised estimates that were issued in November 2013 are based on the
best available scientific information on the impacts of climate change.
The issue of equilibrium climate sensitivity is addressed in section
14A.4 of appendix 14A in the TSD. The EPA, in collaboration with other
Federal agencies, continues to investigate potential improvements to
the way in which economic damages associated with changes in
CO2 emissions are quantified.
AHRI commented that the GHG emissions reductions benefits may be
overestimated because the DOE's analysis does not take into
consideration EPA's planned regulation of GHG emissions from power
plants, which would affect the estimated carbon emissions. AHRI
suggested DOE conduct additional research on the impact of EPA's
regulations on SCC values. (AHRI, No. 93 at p. 14) As noted in section
IV.L.1, DOE participates in the IWG process. DOE believes that if
necessary and appropriate the IWG will perform research as suggested by
AHRI, but notes that results from any such research will not be timely
for inclusion in this rulemaking. With respect to AHRI's comment about
accounting for EPA's planned regulations, DOE cannot account for
regulations that are not currently in effect because whether such
regulations will be adopted and their final form are matters of
speculation at this time.
The Cato Institute commented that the IWG appears to violate the
directive in OMB Circular A-4, which states, ``Your analysis should
focus on benefits and costs that accrue to citizens and residents of
the United States. Where you choose to evaluate a regulation that
[[Page 4716]]
is likely to have effects beyond the borders of the United States,
these effects should be reported separately.'' The Cato Institute
stated that instead of focusing on domestic benefits and separately
reporting any international effects, the IWG only reports the global
costs and makes no determination of the domestic costs. (Cato
Institute, No. 74 at pp. 2-3) IER expressed similar concerns about the
IWG's use of a global perspective in reporting SCC estimates. (IER, No.
83 at pp. 16-17) AHRI commented that either domestic or global costs
and benefits should be considered, but not both. (AHRI, No. 93 at p.
14)
Although the relevant analyses address both domestic and global
impacts, the interagency group has determined that it is appropriate to
focus on a global measure of SCC because of the distinctive nature of
the climate change problem, which is highly unusual in at least two
respects. First, it involves a global externality: Emissions of most
greenhouse gases contribute to damages around the world when they are
emitted in the United States. Second, climate change presents a problem
that the United States alone cannot solve. The issue of global versus
domestic measures of the SCC is further discussed in appendix 14A of
the TSD.
AHRI stated that the costs of the proposed rule are calculated over
the course of a 30-year period, while avoided SCC benefit is calculated
over a 300-year period. AHRI further commented that longer-term (i.e.,
30-300 years) impacts of regulations on businesses are unknown, and
should be studied. (AHRI, No. 93 at p. 14) For the analysis of national
impacts of standards, DOE considers the lifetime impacts of equipment
shipped in a 30-year period, with energy and cost savings impacts
aggregated until all of the equipment shipped in the 30-year period is
retired. With respect to the valuation of CO2 emissions
reductions, the SCC estimates developed by the IWG are meant to
represent the full discounted value (using an appropriate range of
discount rates) of emissions reductions occurring in a given year.
Thus, DOE multiplies the SCC values for achieving the emissions
reductions in each year of the analysis by the carbon reductions
estimated for each of those same years. Neither the costs nor the
benefits of emissions reductions outside the analytic time frame are
included in the analysis.
2. Valuation of Other Emissions Reductions
As noted in section IV.K, DOE has taken into account how new or
amended energy conservation standards would reduce NOX
emissions in those 22 States not affected by emissions caps. DOE
estimated the monetized value of NOX emissions reductions
resulting from each of the TSLs considered for this final rule based on
estimates found in the relevant scientific literature. Estimates of
monetary value for reducing NOX from stationary sources
range from $476 to $4,893 per ton (2013$).\67\ DOE calculated monetary
benefits using a medium value for NOX emissions of $2,684
per short ton (in 2013$), and real discount rates of 3 percent and 7
percent.
---------------------------------------------------------------------------
\67\ 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. Available at:
www.whitehouse.gov/sites/default/files/omb/assets/omb/inforeg/2006_cb/2006_cb_final_report.pdf.
---------------------------------------------------------------------------
DOE is evaluating appropriate monetization of avoided
SO2 and Hg emissions in energy conservation standards
rulemakings. It has not included such monetization in the current
analysis.
M. Utility Impact Analysis
The utility impact analysis estimates several effects on the power
generation industry that would result from the adoption of new or
amended energy conservation standards. In the utility impact analysis,
DOE analyzes the changes in electric installed capacity and generation
that result for each TSL. The utility impact analysis uses a variant of
NEMS,\68\ which is a public domain, multi-sectored, partial equilibrium
model of the U.S. energy sector. DOE uses a variant of this model,
referred to as NEMS-BT,\69\ to account for selected utility impacts of
new or amended energy conservation standards. DOE's analysis consists
of a comparison between model results for the most recent AEO Reference
Case and for cases in which energy use is decremented to reflect the
impact of potential standards. The energy savings inputs associated
with each TSL come from the NIA. Chapter 15 of the final rule TSD
describes the utility impact analysis.
---------------------------------------------------------------------------
\68\ For more information on NEMS, refer to the U.S. Department
of Energy, Energy Information Administration documentation. A useful
summary is National Energy Modeling System: An Overview 2003, DOE/
EIA-0581(2003), March, 2003.
\69\ DOE/EIA approves use of the name ``NEMS'' to describe only
an official version of the model without any modification to code or
data. Because this analysis entails some minor code modifications
and the model is run under various policy scenarios that are
variations on DOE/EIA assumptions, DOE refers to it by the name
``NEMS-BT'' (``BT'' is DOE's Building Technologies Program, under
whose aegis this work has been performed).
---------------------------------------------------------------------------
DOE received one comment about the utility impact analysis. Policy
Analyst commented that DOE should commit to measuring the effects of
these energy savings on the security, reliability, and costs of
maintaining the nation's energy system. (Policy Analyst, No. 75 at p.
10) As discussed in Chapter 15 of the TSD, DOE does quantify the
effects of the energy savings on the nation's energy system. Given the
widely dispersed nature of automatic commercial ice makers on customer
premises across the country, physically measuring the impacts would be
time-consuming and costly and would likely not result in useful
measurements of the effects. DOE has over the course of many energy
conservation standards rulemakings developed the tools and processes
used in this rulemaking to estimate the impacts on the electric utility
system, and those impacts are discussed in Chapter 15 of the TSD.
N. Employment Impact Analysis
Employment impacts from new or amended energy conservation
standards include direct and indirect impacts. Direct employment
impacts, which are addressed in the MIA, are any changes in the number
of employees of manufacturers of the equipment subject to standards.
Indirect employment impacts, which are assessed as part of the
employment impact analysis, are changes in national employment that
occur due to the shift in expenditures and capital investment caused by
the purchase and operation of more-efficient equipment. Indirect
employment impacts from standards consist of the jobs created or
eliminated in the national economy due to (1) reduced spending by end
users on energy; (2) reduced spending on new energy supply by the
utility industry; (3) increased customer spending on the purchase of
new equipment; and (4) the effects of those three factors throughout
the economy.
One method for assessing the possible effects on the demand for
labor of such shifts in economic activity is to compare sector
employment statistics developed by the Labor Department's Bureau of
Labor Statistics (BLS). BLS regularly publishes its estimates of the
number of jobs per million dollars of economic activity in different
sectors of the economy, as well as the jobs created elsewhere in the
economy by this same economic activity. Data from BLS indicate that
expenditures in the utility sector generally create fewer jobs (both
directly and indirectly) than expenditures in other sectors of the
[[Page 4717]]
economy.\70\ There are many reasons for these differences, including
wage differences and the fact that the utility sector is more capital-
intensive and less labor-intensive than other sectors. Energy
conservation standards have the effect of reducing customer utility
bills. Because reduced customer expenditures for energy likely lead to
increased expenditures in other sectors of the economy, the general
effect of efficiency standards is to shift economic activity from a
less labor-intensive sector (i.e., the utility sector) to more labor-
intensive sectors (e.g., the retail and service sectors). Thus, based
on the BLS data alone, DOE believes net national employment may
increase because of shifts in economic activity resulting from amended
energy conservation standards for automatic commercial ice makers.
---------------------------------------------------------------------------
\70\ See U.S. Department of Commerce--Bureau of Economic
Analysis. Regional Multipliers: A User Handbook for the Regional
Input-Output Modeling System (RIMS II). 1992.
---------------------------------------------------------------------------
For the standard levels considered in this final rule, DOE
estimated indirect national employment impacts using an input/output
model of the U.S. economy called Impact of Sector Energy Technologies
version 3.1.1 (ImSET).\71\ ImSET is a special-purpose version of the
``U.S. Benchmark National Input-Output'' (I-O) model, which was
designed to estimate the national employment and income effects of
energy-saving technologies. The ImSET software includes a computer-
based I-O model having structural coefficients that characterize
economic flows among the 187 sectors. ImSET's national economic I-O
structure is based on a 2002 U.S. benchmark table, specially aggregated
to the 187 sectors most relevant to industrial, commercial, and
residential building energy use. DOE notes that ImSET is not a general
equilibrium forecasting model and understands the uncertainties
involved in projecting employment impacts, especially changes in the
later years of the analysis. Because ImSET does not incorporate price
changes, the employment effects predicted by ImSET may overestimate
actual job impacts over the long run. For the final rule, DOE used
ImSET only to estimate short-term (through 2022) employment impacts.
---------------------------------------------------------------------------
\71\ Scott, M.J., O.V. Livingston, P.J. Balducci, J.M. Roop, and
R.W. Schultz. ImSET 3.1: Impact of Sector Energy Technologies. 2009.
Pacific Northwest National Laboratory, Richland, WA. Report No.
PNNL-18412. www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf.
---------------------------------------------------------------------------
DOE received no comments specifically on the indirect employment
impacts. Comments received were related to manufacturing employment
impacts, and DOE reiterates that the indirect employment impacts
estimated with ImSET for the entire economy differ from the direct
employment impacts in the ACIM manufacturing sector estimated using the
GRIM in the MIA, as described at the beginning of this section. The
methodologies used and the sectors analyzed in the ImSET and GRIM
models are different.
For more details on the employment impact analysis and its results,
see chapter 16 of the TSD and section V.B.3.d of this preamble.
O. Regulatory Impact Analysis
DOE prepared a regulatory impact analysis (RIA) for this
rulemaking, which is described in chapter 17 of the final rule 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 qualitative 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
amended automatic commercial ice makers 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 identified the following major policy alternatives for
achieving increased automatic commercial ice makers efficiency:
No new regulatory action
Commercial customer tax credits
Commercial customer 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. See chapter 17 of the final rule
TSD for further details.
In response to the NOPR, DOE received comments from NAFEM stating
that NAFEM commented that DOE failed to consider the positive role of
ENERGY STAR in the marketplace, that the Federal Energy Management
Program (FEMP) already encourages manufacturers to innovate and create
energy savings, the effects of local and state initiatives, and the
effects of voluntary building standards that require high efficiency
products in the marketplace. (NAFEM, No. 82 at pp. 8-9)
In response to the NAFEM comment, DOE notes first that FEMP and
other voluntary programs tend to use ENERGY STAR as the efficiency
target levels for equipment classes covered by ENERGY STAR. DOE
recognizes that the market has achieved a roughly 60-percent success
rate in reaching the ENERGY STAR criteria for the time that ENERGY STAR
has covered automatic commercial ice makers. The market-driven
accomplishments are reflected in the distribution of shipments by
efficiency level for the base conditions, and very much influence the
results of the analysis. The selected TSL 3 yields a shipments-weighted
average efficiency improvement of approximately 8 percent. If all
customers purchased efficiency level 1 equipment (i.e., baseline
equipment), the shipments-weighted average efficiency improvement would
be over 18 percent. The difference is attributable to the combination
of ENERGY STAR, FEMP, utility incentive programs, incentive programs
operated by governmental entities and others, and customer economic
decision making.
In deciding what efficiency targets to model in the RIA, DOE noted
that modeling the new ENERGY STAR criteria would show modest energy
savings and NPV results because, as noted above, the baseline already
reflects the market-driven accomplishments. Further, ENERGY STAR
changes their criteria periodically. The first set of automatic
commercial ice maker criteria was in effect for approximately 5 years,
and the second set became effective February 1, 2013. If the ENERGY
STAR criteria are updated again after a 5-year period, the criteria
will be revised by the compliance date of this rule. Because future
ENERGY STAR criteria are unknown, DOE performed the regulatory impact
analysis using TSL 3 efficiency levels matched with the 60-percent
ENERGY STAR success rate. DOE believes that in performing the analysis
in this fashion, DOE was acknowledging the ability of the ENERGY STAR
program to reach customers and impact their decision-making.
V. Analytical Results
A. Trial Standard Levels
1. Trial Standard Level Formulation Process and Criteria
DOE selected between two and seven efficiency levels for all
equipment
[[Page 4718]]
classes for analysis. For all equipment classes, the first efficiency
level is the baseline efficiency level. Based on the results of the NIA
and other analyses, DOE selected five TSLs above the baseline level for
each equipment class for the NOPR stage of this rulemaking. Table V.1
shows the mapping between TSLs and efficiency levels.
TSL 5 was selected as the max-tech level for all equipment classes.
At this level, DOE's analysis considered that equipment would require
use of design options that generally are not used by ice makers, but
that are currently commercially available; specifically drain water
heat exchangers for batch ice makers and ECM motors for all ice maker
classes. The range of energy use reduction at the max-tech level varies
widely with the equipment class, from 7% for IMH-W-Large-B to 33% for
SCU-A-Small-B.
TSL 4 was chosen as an intermediate level between the max-tech
level and the maximum customer NPV level, subject to the requirement
that the TSL 4 NPV must be positive. ``Customer NPV'' is the NPV of
future savings obtained from the NIA. It provides a measure of the
benefits only to the customers of the automatic commercial ice makers
and does not account for the net benefits to the nation. The net
benefits to the nation also include monetized values of emissions
reductions in addition to the customer NPV. Where a sufficient number
of efficiency levels allow it, TSL 4 is set at least one level below
max-tech and one level above the efficiency level with the highest NPV.
In one case, the TSL 4 efficiency level is the maximum NPV level
because the next higher level had a negative NPV. In cases where the
maximum NPV efficiency level is the penultimate efficiency level and
the max-tech level showed a positive NPV, the TSL 4 efficiency level is
also the max-tech level.
TSL 3 was chosen to represent the group of efficiency levels with
the highest customer NPV at a 7-percent discount rate.
TSL 2 was selected to provide intermediate efficiency levels
between the TSLs 1 and 3. Note that with the number of efficiency
levels available for each equipment class, there is often overlap
between TSL levels. Thus, TSL 2 includes efficiency levels that overlap
with both TSLs 1 and 3. The intent of TSL 2 is to provide an
intermediate level that examines in efficiency options between TSLs 1
and 3.
TSL 1 was set equal to efficiency level 2. In the NOPR analysis,
DOE set efficiency level 2 to be equivalent to ENERGY STAR in effect at
the time DOE started the analysis for products rated by ENERGY STAR and
to an equivalent efficiency improvement for other equipment classes.
However, the ENERGY STAR level for automatic commercial ice makers has
since been revised.\72\ Therefore, in the NODA and final rule analysis
DOE has instead used a more consistent 10-percent level for efficiency
level 2, representing energy use 10 percent lower than the baseline
energy use. This level reflects but is not fully consistent with the
former ENERGY STAR level for those classes covered by ENERGY STAR. The
new ENERGY STAR level, defined for all air-cooled equipment classes
(i.s. IMH-A, RCU, and SCU-A classes for both batch and continuous ice
makers) does not consistently align with any of the TSLs selected by
DOE. For example, for IMH-A batch classes, the current ENERGY STAR
level corresponds roughly to TSL 1 at 300 lb ice/24 hours, TSL 3 at 800
lb ice/24 hours, and is more stringent than TSL 5 at 1,500 lb ice/24
hours. Graphical comparison of the TSLs, ENERGY STAR, and existing
products is providing in Chapter 3 of the TSL.
---------------------------------------------------------------------------
\72\ ENERGY STAR Version 2.0 for Automatic Commercial Ice Makers
became effective on February 1, 2013.
Table V.1--Mapping Between TSLs and Efficiency Levels *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Equipment class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Small-B...................... Level 2............... Level 2............... Level 3.............. Level 3.............. Level 5.
IMH-W-Med-B........................ Level 2............... Level 2............... Level 2.............. Level 3.............. Level 4.
IMH-W-Large-B [dagger]
IMH-W-Large-B-1................ Level 1............... Level 1............... Level 1.............. Level 1.............. Level 2.
IMH-W-Large-B-2................ Level 1............... Level 1............... Level 1.............. Level 1.............. Level 2.
IMH-A-Small-B...................... Level 2............... Level 3............... Level 3A............. Level 3A............. Level 6.
IMH-A-Large-B [dagger]
IMH-A-Large-B1................. Level 2............... Level 3............... Level 3A............. Level 4.............. Level 5.
IMH-A-Large-B2................. Level 2............... Level 2............... Level 3.............. Level 3.............. Level 3.
RCU-Large-B[dagger]
RCU-Large-B1................... Level 2............... Level 2............... Level 2.............. Level 3.............. Level 4.
RCU-Large-B2................... Level 2............... Level 2............... Level 2.............. Level 2.............. Level 3.
SCU-W-Large-B...................... Level 2............... Level 4............... Level 5.............. Level 6.............. Level 6.
SCU-A-Small-B...................... Level 2............... Level 4............... Level 5.............. Level 6.............. Level 7.
SCU-A-Large-B...................... Level 2............... Level 4............... Level 5.............. Level 6.............. Level 6.
IMH-A-Small-C...................... Level 2............... Level 3............... Level 4.............. Level 4.............. Level 6.
IMH-A-Large-C...................... Level 2............... Level 2............... Level 3.............. Level 3.............. Level 5.
RCU-Small-C........................ Level 2............... Level 3............... Level 4.............. Level 4.............. Level 6.
SCU-A-Small-C...................... Level 2............... Level 3............... Level 4.............. Level 4.............. Level 6.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* For three large equipment classes--IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B--because the harvest capacity range is so wide, DOE analyzed two
typical models to model the low and the high portions of the applicable range with greater accuracy. The smaller of the two is noted as B1 and the
larger as B2.
[dagger] DOE analyzed impacts for the B1 and B2 typical units and aggregated impacts to the equipment class level.
[[Page 4719]]
Table V.2 illustrates the efficiency improvements incorporated in
all TSLs.
Table V.2--Percentage Efficiency Improvement From Baseline by TSL *
----------------------------------------------------------------------------------------------------------------
Equipment class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B................... 10.0% 10.0% 15.0% 15.0% 23.9%
IMH-W-Med-B..................... 10.0 10.0 10.0 15.0 18.1
IMH-W-Large-B................... 0.0 0.0 0.0 0.0 8.1
IMH-W-Large-B1.............. 0.0 0.0 0.0 0.0 8.3
IMH-W-Large-B2.............. 0.0 0.0 0.0 0.0 7.4
IMH-A-Small-B................... 10.0 15.0 18.1 18.1 25.5
IMH-A-Large-B................... 10.0 14.2 15.2 18.7 21.6
IMH-A-Large-B1.............. 10.0 15.0 15.8 20.0 23.4
IMH-A-Large-B2.............. 10.0 10.0 11.8 11.8 11.8
RCU-Large-B..................... 10.0 10.0 10.0 14.7 17.1
RCU-Large-B1................ 10.0 10.0 10.0 15.0 17.3
RCU-Large-B2................ 10.0 10.0 10.0 10.0 13.9
SCU-W-Large-B................... 10.0 20.0 25.0 29.8 29.8
SCU-A-Small-B................... 10.0 20.0 25.0 30.0 32.7
SCU-A-Large-B................... 10.0 20.0 25.0 29.1 29.1
IMH-A-Small-C................... 10.0 15.0 20.0 20.0 25.7
IMH-A-Large-C................... 10.0 10.0 15.0 15.0 23.3
RCU-Small-C..................... 10.0 15.0 20.0 20.0 26.6
SCU-A-Small-C................... 10.0 15.0 20.0 20.0 26.6
----------------------------------------------------------------------------------------------------------------
* Percentage improvements for IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B are a weighted average of the B1 and
B2 units, using weights provided in TSD chapter 7.
Table V.3 illustrates the design options associated with each TSL
level, for each analyzed product class. The design options are
discussed in section IV.D.3 of this final rule and in chapter 5 of the
TSD.
Table V.3--Design Options for Analyzed Products Classes at Each TSL
--------------------------------------------------------------------------------------------------------------------------------------------------------
Equipment class Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Design Options for Each TSL (options are cumulative--TSL 5 includes all preceding options)
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Small-B................... No BW Fill........ + Comp EER........ Same EL as TSL 1.. + Cond............ Same EL as TSL 3.. BW Fill
SPM PM............ + Cond............ + Evap
ECM PM
DWHX.
IMH-W-Small-B (22 inch wide).... No BW Fill........ + Comp EER........ Same EL as TSL 1.. + Cond............ Same EL as TSL 3.. N/A for 22-inch.
SPM PM............ + Cond............ BW Fill...........
IMH-W-Med-B..................... BW Fill........... + Comp EER........ Same EL as TSL 1.. Same EL as TSL 1.. + Cond............ DWHX.
SPM PM............ ECM PM............
IMH-W-Large-B1.................. BW Fill........... Same EL as Same EL as Same EL as Same EL as + Comp EER
SPM PM............ Baseline. Baseline. Baseline. Baseline. + Cond
ECM PM
DWHX.
IMH-W-Large-B2.................. BW Fill........... Same EL as Same EL as Same EL as Same EL as + Comp EER
SPM PM............ Baseline. Baseline. Baseline. Baseline. + Cond
ECM PM
DWHX.
IMH-A-Small-B................... BW Fill........... + Comp EER........ + Evap............ + Evap............ Same EL as TSL 3.. + Evap
SPM PM............ + Cond............ ECM PM
SPM FM............ + Evap............ DWHX.
ECM FM............
IMH-A-Small-B (22 inch wide).... BW Fill........... + Comp EER........ + Evap............ ECM PM............ Same EL as TSL 3.. N/A for 22-inch.
SPM PM............ + Cond............ DWHX..............
SPM FM............ + Evap............
ECM FM............
IMH-A-Large-B1.................. No BW Fill........ + Comp EER........ ECM FM............ BW Fill........... BW Fill........... DWHX.
SPM PM............ PSC FM............ BW Fill........... ECM PM............
SPM FM............ + Cond............
IMH-A-Large-B1 (22 inch wide)... No BW Fill........ + Comp EER........ BW Fill........... DWHX.............. N/A for 22-inch... N/A for 22-inch.
SPM PM............ ECM FM............ ECM PM............
SPM FM............ BW Fill........... DWHX..............
IMH-A-Large-B2.................. BW Fill........... + Comp EER........ Same EL as TSL 1.. DWHX.............. Same EL as TSL 3.. Same EL as TSL 3.
SPM PM............ ECM FM............
SPM FM............ ECM PM............
+ Cond............
DWHX..............
[[Page 4720]]
RCU-Large-B1.................... BW Fill........... + Cond............ Same EL as TSL 1.. Same EL as TSL 1.. ECM FM............ DWHX.
SPM PM............ + Comp EER........ ECM PM............
PSC FM............ + Cond............
DWHX..............
RCU-Large-B2.................... BW Fill........... + Comp EER........ Same EL as TSL 1.. Same EL as TSL 1.. Same EL as TSL 1.. DWHX.
SPM PM............ ECM FM............
PSC FM............ + Cond............
ECM PM............
SCU-W-Large-B................... No BW Fill........ BW Fill........... +Evap............. + Cond............ + Cond............ DWHX.
SPM PM............ + Evap............ + Cond............
SCU-A-Small-B................... No BW Fill........ + Cond............ + Comp EER........ PSC FM............ BW Fill........... ECM FM
SPM PM............ + Comp............ BW Fill........... ECM PM............ DWHX.
SPM FM............ EER............... ECM FM............
SCU-A-Large-B................... No BW Fill........ +Cond............. + Comp EER........ BW Fill........... ECM PM............ Same EL as TSL 4.
SPM PM............ + Comp EER........ BW Fill........... ECM FM............ DWHX..............
SPM FM............
RCU-Small-C..................... PSC AM............ + Comp EER........ ECM FM............ ECM FM............ Same EL as TSL3... + Cond
SPM FM............ PSC FM............ + Cond............ ECM AM.
IMH-A-Small-C................... PSC AM............ + Comp EER........ + Cond............ ECM FM............ Same EL as TSL 3.. ECM AM.
SPM FM............ + Cond............ ECM FM............ + Cond............
IMH-A-Large-C................... PSC AM............ + Comp EER........ Same EL as TSL 1.. + Comp EER........ Same EL as TSL 3.. + Cond
SPM FM............ + Cond............ ECM FM
ECM AM.
SCU-A-Small-C................... PSC AM............ + Cond............ + Comp EER........ + Comp EER........ Same EL as TSL 3.. ECM FM
SPM FM............ + Comp EER........ ECM FM............ ECM AM.
--------------------------------------------------------------------------------------------------------------------------------------------------------
EL = Efficiency Level
SPM = Shaded Pole Motor
PSC = Permanent Split Capacitor Motor
ECM = Electronically Commutated Motor
FM = Fan Motor (Air-Cooled Units)
AM = Auger Motor (Continuous Units)
BW Fill = Batch Water Fill Option Included
+ Cond = Increase in Condenser Size
+ Evap = Increase in Evaporator Size
+ Comp EER = Increase in Compressor EER
DWHX = Addition of Drain Water Heat Exchanger
Chapter 5 of the TSD contains full descriptions of the design
options, DOE's analyses for the equipment size increase associated with
the design options selected, and DOE's analyses of the efficiency gains
for each design option considered.
2. Trial Standard Level Equations
Table V.4 and Table V.5 translate the TSLs into potential
standards. In Table V.4, the TSLs are translated into energy
consumption standards for the batch classes, while Table V.5 provides
the potential energy consumption standards for the continuous classes.
Note that the size nomenclature for the classes (Small, Medium, Large,
and Extended) in many cases designate different capacity ranges than
the current class sizes. However, the discussion throughout this
preamble is based primarily on the current class capacity ranges--the
alternative designation is made in Table V.4 and Table V.5 for future
use when the new energy conservation standards take effect.
Table V.4--Equations Representing the TSLs for Batch Equipment Classes
[Maximum energy use in kWh/100 lb ice]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Capacity range
Batch equipment class lb ice/24 TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
hours
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Small-B........................................... <300 7.19-0.0055H 7.19-0.0055H 6.88-0.0055H 6.88-0.0055H 6.32-0.0055H
IMH-W-Med-B............................................. >=300 and <850 6.28-0.00247H 6.28-0.00247H 5.8-0.00191H 5.9-0.00224H 5.17-0.00165H
IMH-W-Large-B........................................... >=850 and 4.42-0.00028H 4.42-0.00028H 4.0 4.0 3.86-0.00012H
<1500
IMH-W-Extended-B........................................ >=1,500 and 4.0 4.0 4.0 4.0 3.62 +
<2,600 0.00004H
>=2,600 4.0 4.0 4.0 4.0 3.72
IMH-A-Small-B........................................... <300 10.09-0.0106H 10.05-0.01173H 10-0.01233H 10-0.01233H 9.38-0.01233H
IMH-A-Medium-B.......................................... >=300 and <800 7.81-0.003H 7.38-0.00284H 7.05-0.0025H 7.19-0.00298H 6.31-0.0021H
IMH-A-Large-B........................................... >=800 and 6.21-0.00099H 5.56-0.00056H 5.55-0.00063H 5.04-0.00029H 4.65-0.00003H
<1,500
[[Page 4721]]
IMH-A-Extended-B........................................ >1,500 4.73 4.72 4.61 4.61 4.61
RCU-NRC-Small-B......................................... <988 * 7.97-0.00342H 7.97-0.00342H 7.97-0.00342H 7.52-0.00323H 7.35-0.00312H
RCU-NRC-Large-B......................................... >=988 * and 4.59 4.59 4.59 4.34 4.23
<1,500
RCU-NRC-Extended-B...................................... >=1,500 and 4.59 4.59 4.59 3.92 + 3.96 +
<2,400 0.00028H 0.00018H
>=2,400 4.59 4.59 4.59 4.59 4.39
RCU-RC-Small-B.......................................... <930 ** 7.97-0.00342H 7.97-0.00342H 7.97-0.00342H 7.52-0.00323H 7.35-0.00312H
RCU-RC-Large-B.......................................... >=930 ** and 4.79 4.79 4.79 4.54 4.43
<1,500
RCU-RC-Extended-B....................................... >=1,500 and < 4.79 4.79 4.79 4.12 + 4.16 +
2,400 0.00028H 0.00018H
>=2,400 4.79 4.79 4.79 4.79 4.59
SCU-W-Small-B........................................... <200 10.64-0.019H 9.88-0.019H 9.5-0.019H 9.14-0.019H 9.14-0.019H
SCU-W-Large-B........................................... >=200 6.84 6.08 5.7 5.34 5.34
SCU-A-Small-B........................................... <110 16.72-0.0469H 15.43-0.0469H 14.79-0.0469H 14.15-0.0469H 13.76-0.0469H
SCU-A-Large-B........................................... >=110 and <200 14.91-0.03044H 13.24-0.027H 12.42-0.02533H 11.47-0.02256H 10.6-0.02
SCU-A-Extended-B........................................ >=200 8.82 7.84 7.35 6.96 6.96
--------------------------------------------------------------------------------------------------------------------------------------------------------
* 985 for TSL4, 1,000 for TSL5
** 923 for TSL4, 936 for TSL5
Table V.5--Equations Representing the TSLs for Continuous Equipment Classes
[Maximum energy use in kWh/100 lb ice]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Capacity range
Continuous equipment class lb ice/24 TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
hours
--------------------------------------------------------------------------------------------------------------------------------------------------------
IMH-W-Small-C........................................... <801 7.29-0.003H 6.89-0.00283H 6.48-0.00267H 6.48-0.00267H 5.75-0.00237H
IMH-W-Large-C........................................... >=801 4.59 4.59 4.34 4.34 3.93
IMH-A-Small-C........................................... <310 10.1-0.00629H 9.64-0.00629H 9.19-0.00629H 9.19-0.00629H 8.38-0.00629H
IMH-A-Large-C........................................... >=310 and <820 9.49-0.00433H 8.75-0.00343H 8.23-0.0032H 8.23-0.0032H 7.25-0.00265H
IMH-A-Extended-C........................................ >=820 5.94 5.94 5.61 5.61 5.08
RCU-NRC-Small-C......................................... <800 9.85-0.00519H 9.78-0.0055H 9.7-0.0058H 9.7-0.0058H 9.26-0.0058H
RCU-NRC-Large-C......................................... >=800 5.7 5.38 5.06 5.06 4.62
RCU-RC-Small-C.......................................... <800 10.05-0.00519H 9.98-0.0055H 9.9-0.0058H 9.9-0.0058H 9.46-0.0058H
RCU-RC-Large-C.......................................... >=800 5.9 5.58 5.26 5.26 4.82
SCU-W-Small-C........................................... <900 8.55-0.0034H 8.08 0.0032H 7.6-0.00302H 7.6-0.00302H 6.84-0.00272H
SCU-W-Large-C........................................... >=900 5.49 5.19 4.88 4.88 4.39
SCU-A-Small-C........................................... <200 15.26-0.03 14.73-0.03H 14.22-0.03H 14.22-0.03H 13.4-0.03H
SCU-A-Large-C........................................... >=200 and 700 10.66-0.00702H 10.06-0.00663H 9.47-0.00624H 9.47-0.00624H 8.52-0.00562H
SCU-A-Extended-C........................................ >=700 5.75 5.42 5.1 5.1 4.59
--------------------------------------------------------------------------------------------------------------------------------------------------------
In developing TSLs, DOE analyzed representative units for each
equipment class group, defined for the purposes of this discussion by
the ``Type of Ice Maker,'' ``Equipment Type,'' and ``Type of Condenser
Cooling'' (see Table IV.2--within each class group, further segregation
into equipment classes involves only specification of harvest capacity
rate). DOE first established a percentage reduction in energy use
associated with each TSL for the representative units. DOE calculated
the energy use (in kWh/100 lb ice) associated with this reduction for
the harvest capacity rates associated with the representative units
(called representative capacities). This provided one or more points
with which to define a TSL curve for the entire equipment class group
as a function of harvest capacity rate. DOE selected the TSL curve to
(a) pass through the points defining energy use for the TSL at the
representative capacities; (b) be continuous, with no gaps at the
representative capacities or at any other capacities; and (c) be
consistent with the energy and capacity trends for
[[Page 4722]]
commercialized products of the equipment class group.
For the IMH-A-B equipment classes, DOE sought to set efficiency
levels that do not vary with harvest capacity for the largest-capacity
equipment, but doing so would have violated EPCA's anti-backsliding
provisions. As a result, the efficiency levels for large-capacity
equipment for this class in the range up to 2,500 lb ice/24 hours were
set using multiple segments. This is discussed in section IV.D.2.c.
For the RCU-RC-Large-B, RCU-RC-Small-C, and RCU-RC-Large-C
equipment classes, the efficiency levels are 0.2 kWh/100 lb of ice
higher than those of the RCU-NRC-Large-B, RCU-NRC-Small-C, and RCU-NRC-
Large-C equipment classes, respectively, as discussed in section
IV.D.2.a. The RCU-RC-Small-B and RCU-NRC-Small-B efficiency levels are
equal, and the harvest capacity break points for the RCU-NRC classes
have been set to avoid gaps in allowable energy usage at the
breakpoints.
The TSL energy use levels calculated for the representative
capacities of the directly-analyzed equipment classes are presented
Table V.6.
Table V.6--Energy Consumption by TSL for the Representative Automatic Commercial Ice Maker Units
----------------------------------------------------------------------------------------------------------------
Representative Representative automatic commercial ice maker unit kWh/100 lb
Equipment class harvest rate lb ----------------------------------------------------------------
ice/24 hours TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B............... 300 5.54 5.54 5.23 5.23 4.67
IMH-W-Med-B................. 850 4.18 4.18 4.18 4.00 3.76
IMH-W-Large-B-1............. 1,500 4.00 4.00 4.00 4.00 3.68
IMH-W-Large-B-2............. 2,600 4.00 4.00 4.00 4.00 3.72
IMH-A-Small-B............... 300 6.91 6.53 6.30 6.30 5.68
IMH-A-Large-B-1............. 800 5.41 5.11 5.05 4.81 4.63
IMH-A-Large-B-2............. 1,500 4.72 4.72 4.61 4.61 4.61
RCU-NRC-Large-B-1........... 1,500 4.59 4.59 4.59 4.34 4.23
RCU-NRC-Large-B-2........... 2,400 4.59 4.59 4.59 4.59 4.39
SCU-W-Large-B............... 300 6.84 6.08 5.70 5.34 5.34
SCU-A-Small-B............... 110 11.56 10.27 9.63 8.99 8.60
SCU-A-Large-B............... 200 8.82 7.84 7.35 6.96 6.96
IMH-A-Small-C............... 310 8.15 7.69 7.24 7.24 6.43
IMH-A-Large-C............... 820 5.94 5.94 5.61 5.61 5.08
RCU-Small-C................. 800 5.70 5.38 5.06 5.06 4.62
SCU-A-Small-C............... 220 9.11 8.61 8.10 8.10 7.29
----------------------------------------------------------------------------------------------------------------
B. Economic Justification and Energy Savings
1. Economic Impacts on Commercial Customers
a. Life-Cycle Cost and Payback Period
Customers affected by new or amended standards usually incur higher
purchase prices and lower operating costs. DOE evaluates these impacts
on individual customers by calculating changes in LCC and the PBP
associated with the TSLs. The results of the LCC analysis for each TSL
were obtained by comparing the installed and operating costs of the
equipment in the base-case scenario (scenario with no amended energy
conservation standards) against the standards-case scenarios at each
TSL. The energy consumption values for both the base-case and
standards-case scenarios were calculated based on the DOE test
procedure conditions specified in the 2012 test procedure final rule,
which adopts an industry-accepted test method. Using the approach
described in section IV.F, DOE calculated the LCC savings and PBPs for
the TSLs considered in this final rule. The LCC analysis is carried out
in the form of Monte Carlo simulations, and the results of LCC analysis
are distributed over a range of values. DOE presents the mean or median
values, as appropriate, calculated from the distributions of results.
Table V.7 through Table V.25 show the results of the LCC analysis
for each equipment class. Each table presents the results of the LCC
analysis, including mean LCC, mean LCC savings, median PBP, and
distribution of customer impacts in the form of percentages of
customers who experience net cost, no impact, or net benefit.
Only five equipment classes have positive LCC savings values at TSL
5, while the remaining classes have negative LCC savings. Negative
average LCC savings imply that, on average, customers experience an
increase in LCC of the equipment as a consequence of buying equipment
associated with that particular TSL. In four of the five classes, the
TSL 5 level is not negative, but the LCC savings are less than one-
third the TSL 3 savings. All of these results indicate that the cost
increments associated with the max-tech design option are high, and the
increase in LCC (and corresponding decrease in LCC savings) indicates
that the design options embodied in TSL 5 result in negative customer
impacts. TSL 5 is associated with the max-tech level for all the
equipment classes. Drain water heat exchanger technology is the design
option associated with the max-tech efficiency levels for batch
equipment classes. For continuous equipment classes, the max-tech
design options are auger motors using permanent magnets.
The mean LCC savings associated with TSL 4 are all positive values
for all equipment classes. The mean LCC savings at all lower TSL levels
are also positive. The trend is generally an increase in LCC savings
for TSL 1 through 3, with LCC savings either remaining constant or
declining at TSL 4. In two cases, the highest LCC savings are at TSL 2:
IMH-A-Large-B1 and SCU-W-Large-B. In one case, IMH-A-Small-B, the
highest LCC savings occur at TSL1. Two of the three classes with LCC
savings maximums below TSL 3 have high one-time installation cost
adders for building renovations expected to take place when existing
units are replaced, causing the TSL3 LCC savings to be depressed
relative to the lower levels. The drop-off in LCC savings at TSL 4 is
generally associated with the relatively large cost for the max-tech
design options, the savings for which frequently span the last two
efficiency levels.
As described in section IV.H.2, DOE used a ``roll-up'' scenario in
this rulemaking. Under the roll-up scenario, DOE assumes that the
market shares of
[[Page 4723]]
the efficiency levels (in the base case) that do not meet the standard
level under consideration would be ``rolled up'' into (meaning ``added
to'') the market share of the efficiency level at the standard level
under consideration, and the market shares of efficiency levels that
are above the standard level under consideration would remain
unaffected. Customers, in the base-case scenario, who buy the equipment
at or above the TSL under consideration, would be unaffected if the
amended standard were to be set at that TSL. Customers, in the base-
case scenario, who buy equipment below the considered TSL, would be
affected if the amended standard were to be set at that TSL. Among
these affected customers, some may benefit from lower LCC of the
equipment and some may incur a net cost due to higher LCC, depending on
the inputs to LCC analysis, such as electricity prices, discount rates,
installation costs, and markups. DOE's results indicate that, with two
exceptions, nearly all customers either benefit or are unaffected by
setting standards at TSLs 1, 2, or 3, with 0 to 2 percent of customers
experiencing a net cost in all but two classes. Some customers
purchasing IMH-A-Small-B (21 percent) and IMH-A-Large-B2 (10 percent)
equipment will experience net costs at TSL3. In almost all cases, a
portion of the market would experience net costs starting with TSL 4,
although in several equipment classes the percentage is below 10
percent. At TSL 5, only in IMH-A-Large-B2 (10 percent) and SCU-W-Large-
B (44 percent) do less than 50 percent of customers show a net cost,
while in the other classes the percentage of customers with a net cost
ranges as high as 96 percent.
The median PBP values for TSLs 1 through 3 are generally less than
3 years, except for IMH-A-Small-B where the TSL 3 PBP is 4.7 years and
IMH-A-Large-B2 with a PBP of 6.9 years. The median PBP values for TSL 4
range from 0.7 years to 6.9 years.
PBP values for TSL 5 range from 4.9 years to nearly 12 years. In
eight cases, the the PBP exceeds the expected 8.5-year equipment life.
Table V.7--Summary LCC and PBP Results for IMH-W-Small-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 2,551 2,476 9,533 12,009 175 0 63 37 2.5
2............................................................... 2,551 2,476 9,533 12,009 175 0 63 37 2.5
3............................................................... 2,411 2,537 9,381 11,918 214 1 47 52 2.7
4............................................................... 2,411 2,537 9,381 11,918 214 1 47 52 2.7
5............................................................... 2,162 3,371 9,200 12,571 (534) 96 0 4 13.4
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.8--Summary LCC and PBP Results for IMH-W-Med-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 5,439 4,325 21,470 25,795 308 0 44 56 2.1
2............................................................... 5,439 4,325 21,470 25,795 308 0 44 56 2.1
3............................................................... 5,439 4,325 21,470 25,795 308 0 44 56 2.1
4............................................................... 5,138 4,607 21,251 25,857 165 28 24 47 5.0
5............................................................... 4,951 4,943 21,115 26,058 (63) 65 9 26 7.6
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.9--Summary LCC and PBP Results for IMH-W-Large-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 10,750 6,129 42,992 49,121 0 NA NA NA NA
2............................................................... 10,750 6,129 42,992 49,121 0 NA NA NA NA
3............................................................... 10,750 6,129 42,992 49,121 0 NA NA NA NA
4............................................................... 10,750 6,129 42,992 49,121 0 NA NA NA NA
5............................................................... 9,891 6,913 42,381 49,294 (172) 67 13 20 10.6
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.10--Summary LCC and PBP Results for IMH-W-Large-B1 Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 9,166 5,004 37,051 42,055 0 NA NA NA NA
2............................................................... 9,166 5,004 37,051 42,055 0 NA NA NA NA
[[Page 4724]]
3............................................................... 9,166 5,004 37,051 42,055 0 NA NA NA NA
4............................................................... 9,166 5,004 37,051 42,055 0 NA NA NA NA
5............................................................... 8,405 5,747 36,509 42,256 (200) 70 13 17 11.1
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.11--Summary LCC and PBP Results for IMH-W-Large-B2 Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 15,868 9,763 62,182 71,945 0 NA NA NA NA
2............................................................... 15,868 9,763 62,182 71,945 0 NA NA NA NA
3............................................................... 15,868 9,763 62,182 71,945 0 NA NA NA NA
4............................................................... 15,868 9,763 62,182 71,945 0 NA NA NA NA
5............................................................... 14,693 10,681 61,346 72,027 (80) 59 13 29 8.9
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.12--Summary LCC and PBP Results for IMH-A-Small-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 3,184 2,539 8,420 10,959 136 1 76 22 3.4
2............................................................... 3,009 2,655 8,293 10,948 72 21 47 32 4.8
3............................................................... 2,901 2,695 8,214 10,909 77 21 0 79 4.7
4............................................................... 2,901 2,695 8,214 10,909 77 21 0 79 4.7
5............................................................... 2,640 3,331 8,048 11,379 (393) 95 0 5 11.9
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.13--Summary LCC and PBP Results for IMH-A-Large-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
--------------------------------------------------------------------------------------------------
Affected % of customers that experience Payback
TSL Energy usage Discounted customers' ------------------------------------------ period,
kWh/yr Installed operating LCC average median years
cost cost savings Net cost % No impact % Net benefit
2013$ %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1................................................................. 7,272 4,337 14,598 18,935 382 1 69 30 2.2
2................................................................. 6,964 4,418 14,230 18,648 501 1 45 53 2.4
3................................................................. 6,881 4,435 14,170 18,605 361 2 12 86 2.3
4................................................................. 6,622 4,711 13,988 18,699 265 31 12 57 3.9
5................................................................. 6,411 5,068 13,834 18,902 55 53 10 37 5.6
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.14--Summary LCC and PBP Results for IMH-A-Large-B1 Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
--------------------------------------------------------------------------------------------------
Affected % of customers that experience Payback
TSL Energy usage Discounted customers' ------------------------------------------ period,
kWh/yr Installed operating LCC average median years
cost cost savings Net cost % No impact % Net benefit
2013$ %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1................................................................. 6,617 4,172 13,943 18,115 439 0 66 34 1.2
2................................................................. 6,251 4,269 13,506 17,775 580 0 38 62 1.5
3................................................................. 6,192 4,275 13,464 17,738 407 0 3 97 1.5
4................................................................. 5,885 4,602 13,247 17,850 294 35 3 63 3.4
5................................................................. 5,636 5,025 13,066 18,091 45 61 0 39 5.4
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4725]]
Table V.15--Summary LCC and PBP Results for IMH-A-Large-B2 Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
--------------------------------------------------------------------------------------------------
Affected % of customers that experience Payback
TSL Energy usage Discounted customers' ------------------------------------------ period,
kWh/yr Installed operating LCC average median years
cost cost savings Net cost % No impact % Net benefit
2013$ %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1................................................................. 10,802 5,222 18,129 23,350 76 9 83 8 7.4
2................................................................. 10,802 5,222 18,129 23,350 76 9 83 8 7.4
3................................................................. 10,591 5,298 17,975 23,273 110 10 61 29 6.9
4................................................................. 10,591 5,298 17,975 23,273 110 10 61 29 6.9
5................................................................. 10,591 5,298 17,975 23,273 110 10 61 29 6.9
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.16--Summary LCC and PBP Results for RCU-Large-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
--------------------------------------------------------------------------------------------------
Affected % of customers that experience Payback
TSL Energy usage Discounted customers' ------------------------------------------ period,
kWh/yr Installed operating LCC average median years
cost cost savings Net cost % No impact % Net benefit
2013$ %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1................................................................. 10,908 6,423 14,588 21,012 748 0 56 44 1.1
2................................................................. 10,908 6,423 14,588 21,012 748 0 56 44 1.1
3................................................................. 10,908 6,423 14,588 21,012 748 0 56 44 1.1
4................................................................. 10,362 6,813 14,213 21,026 418 23 22 55 3.3
5................................................................. 10,066 7,207 14,000 21,206 144 55 2 42 5.0
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.17--Summary LCC and PBP Results for RCU-Large-B1 Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
--------------------------------------------------------------------------------------------------
Affected % of customers that experience Payback
TSL Energy usage Discounted customers' ------------------------------------------ period,
kWh/yr Installed operating LCC average median years
cost cost savings Net cost % No impact % Net benefit
2013$ %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1................................................................. 10,514 6,220 14,190 20,410 743 0 56 44 0.9
2................................................................. 10,514 6,220 14,190 20,410 743 0 56 44 0.9
3................................................................. 10,514 6,220 14,190 20,410 743 0 56 44 0.9
4................................................................. 9,931 6,635 13,790 20,425 391 25 20 55 3.4
5................................................................. 9,664 6,985 13,595 20,580 161 55 1 44 4.9
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.18--Summary LCC and PBP Results for RCU-Large-B2 Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 16,807 9,465 20,540 30,005 820 1 56 43 3.0
2............................................................... 16,807 9,465 20,540 30,005 820 1 56 43 3.0
3............................................................... 16,807 9,465 20,540 30,005 820 1 56 43 3.0
4............................................................... 16,807 9,465 20,540 30,005 820 1 56 43 3.0
5............................................................... 16,077 10,516 20,046 30,562 (109) 57 20 23 7.0
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.19--Summary LCC and PBP Results for SCU-W-Large-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
--------------------------------------------------------------------------------------------------
Affected % of customers that experience Payback
TSL Energy usage Discounted customers' ------------------------------------------ period,
kWh/yr Installed operating LCC average median years
cost cost savings Net cost % No impact % Net benefit
2013$ %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1................................................................. 3,151 3,540 10,617 14,158 444 0 28 72 1.1
2................................................................. 2,804 3,620 10,364 13,984 613 0 28 72 1.6
3................................................................. 2,630 3,664 10,238 13,902 550 0 5 94 1.8
4................................................................. 2,464 4,114 10,117 14,231 192 44 0 56 5.1
5................................................................. 2,464 4,114 10,117 14,231 192 44 0 56 5.1
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4726]]
Table V.20--Summary LCC and PBP Results for SCU-A-Small-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 1,962 2,799 7,193 9,992 110 0 48 52 2.2
2............................................................... 1,747 2,845 7,051 9,896 161 1 20 79 2.4
3............................................................... 1,639 2,918 6,843 9,761 281 1 12 87 2.6
4............................................................... 1,532 3,000 6,778 9,778 230 16 0 84 3.5
5............................................................... 1,473 3,416 6,737 10,153 (145) 77 0 23 8.9
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.21--Summary LCC and PBP Results for SCU-A-Large-B Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
--------------------------------------------------------------------------------------------------
Affected % of customers that experience Payback
TSL Energy usage Discounted customers' ------------------------------------------ period,
kWh/yr Installed operating LCC average median years
cost cost savings Net cost % No impact % Net benefit
2013$ %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1................................................................. 2,713 3,275 10,070 13,344 163 0 37 63 1.8
2................................................................. 2,414 3,345 9,685 13,030 400 0 1 99 1.6
3................................................................. 2,265 3,402 9,590 12,992 439 0 1 99 2.1
4................................................................. 2,141 3,854 9,500 13,355 71 54 0 46 6.5
5................................................................. 2,141 3,854 9,500 13,355 71 54 0 46 6.5
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.22--Summary LCC and PBP Results for IMH-A-Small-C Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 3,872 6,674 8,869 15,543 245 0 69 31 1.5
2............................................................... 3,658 6,709 8,723 15,432 292 0 58 42 1.6
3............................................................... 3,445 6,745 8,572 15,317 313 0 39 61 1.7
4............................................................... 3,445 6,745 8,572 15,317 313 0 39 61 1.7
5............................................................... 3,201 7,264 8,552 15,816 (165) 68 14 18 8.8
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative values.
Table V.23--Summary LCC and PBP Results for IMH-A-Large-C Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
--------------------------------------------------------------------------------------------------
Affected % of customers that experience Payback
TSL Energy usage Discounted customers' ------------------------------------------ period,
kWh/yr Installed operating LCC average median years
cost cost savings Net cost % No impact % Net benefit
2013$ %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1................................................................. 7,445 5,538 14,275 19,813 539 0 57 43 0.7
2................................................................. 7,445 5,538 14,275 19,813 539 0 57 43 0.7
3................................................................. 7,033 5,568 13,979 19,547 626 0 35 65 0.7
4................................................................. 7,033 5,568 13,979 19,547 626 0 35 65 0.7
5................................................................. 6,348 6,310 13,705 20,015 28 54 9 37 5.9
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.24--Summary LCC and PBP Results for RCU-Small-C Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 6,966 5,690 8,588 14,278 498 0 72 28 0.7
2............................................................... 6,580 5,758 8,319 14,078 448 0 44 55 1.2
3............................................................... 6,195 5,808 8,046 13,854 505 0 11 89 1.2
4............................................................... 6,195 5,808 8,046 13,854 505 0 11 89 1.2
5............................................................... 5,688 6,523 7,878 14,402 (73) 64 6 31 5.8
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative values.
[[Page 4727]]
Table V.25--Summary LCC and PBP Results for SCU-A-Small-C Equipment Class
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost, all customers 2013$ Life-cycle cost savings
----------------------------------------------------------------------------------------------------
Energy usage Affected % of customers that experience Payback
TSL kWh/yr Installed Discounted customers' ------------------------------------------ period,
cost operating LCC average Net benefit median years
cost savings 2013$ Net cost % No impact % %
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................................... 3,077 3,622 8,175 11,797 224 0 56 44 0.8
2............................................................... 2,907 3,646 8,059 11,705 278 0 47 53 1.1
3............................................................... 2,738 3,685 7,948 11,633 290 1 32 67 1.5
4............................................................... 2,738 3,685 7,948 11,633 290 1 32 67 1.5
5............................................................... 2,515 4,224 7,950 12,174 (268) 86 0 14 11.4
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative values.
b. Life-Cycle Cost Subgroup Analysis
As described in section IV.I, DOE estimated the impact of amended
energy conservation standards for automatic commercial ice makers, at
each TSL, on two customer subgroups--the foodservice sector and the
lodging sector. For the automatic commercial ice makers, DOE has not
distinguished between subsectors of the foodservice industry. In other
words, DOE has been treating it as one sector as opposed to modeling
limited or full service restaurants and other types of foodservice
firms separately. Foodservice was chosen as one representative subgroup
because of the large percentage of the industry represented by family-
owned or locally owned restaurants. Likewise, lodging was chosen due to
the large percentage of the industry represented by locally owned or
franchisee-owned hotels. DOE carried out two LCC subgroup analyses, one
each for restaurants and lodging, by using the LCC spreadsheet
described in chapter 8 of the final rule TSD, but with certain
modifications. This included fixing the input for business type to the
identified subgroup, which ensured that the discount rates and
electricity price rates associated with only that subgroup were
selected in the Monte Carlo simulations (see chapter 8 of the TSD).
Another major change from the LCC analysis was an added assumption that
the subgroups do not have access to national capital markets, which
results in higher discount rates for the subgroups. The higher discount
rates lead the subgroups to place a lower value on future savings and a
higher value on the upfront equipment purchase costs. The LCC subgroup
analysis is described in chapter 11 of the TSD.
Table V.26 presents the comparison of mean LCC savings for the
small business subgroup in foodservice sector with the national average
values (LCC savings results from chapter 8 of the TSD). For TSLs 1-3,
in most equipment classes, the LCC savings for the small business
subgroup are only slightly different from the average, with some
slightly higher and others slightly lower. Table V.27 presents the
percentage change in LCC savings compared to national average values.
DOE modeled all equipment classes in this analysis, although DOE
believes it is likely that the very large equipment classes are not
commonly used in foodservice establishments. For TSLs 1-3, the
differences range from -7 percent for IMH-A-Large-B2 at TSLs 1 and 2,
to +3 percent for the same class at TSL 3 and IMH-A-Small-B at TSL 2.
For most equipment classes in Table V.27, the percentage change ranges
from a decrease in LCC savings of less than 2 percent to an increase of
2 percent. In summary, the differences are minor at TSLs 1-3.
Table V.28 presents the comparison of median PBPs for the small
business subgroup in the foodservice sector with national median values
(median PBPs from chapter 8 of the TSD). The PBP values are the same as
or shorter than the small business subgroup in all cases. This arises
because the first-year operating cost savings--which are used for
payback period--are higher, leading to a shorter payback. However,
given their higher discount rates, these customers value future savings
less, leading to lower LCC savings. First-year savings are higher
because the foodservice electricity prices are higher than the average
of all classes.
Table V.29 presents the comparison of mean LCC savings for the
small business subgroup in the lodging sector (hotels and casinos) with
the national average values (LCC savings results from chapter 8 of the
TSD). Table V.30 presents the percentage difference between LCC savings
of the lodging sector customer subgroup and national average values.
For lodging sector small business, LCC savings are lower across the
board. For TSLs 1-3, the lodging subgroup LCC savings range from 9 to
13 percent lower. The reason for this is that the energy price for
lodging is slightly lower than the average of all commercial business
types (97 percent of the average). This, combined with a higher
discount rate, reduces the value of future operating and maintenance
benefits as well as the present value of the benefits, thus resulting
in lower LCC savings. For IMH-A-Small-B the difference exceeds 20
percent, which is likely due to the higher installation cost for this
class in combination with the much higher than average discount rate.
The IMH-A-Large-B2 class is also significantly lower, in percentage
terms. DOE notes that the difference is relatively small in terms of
dollars; however, because the national average savings are small, the
difference is significant in percentage terms. The lodging subgroup
savings for IMH-A-Large-B2 are 88 percent lower than the average at
TSLs 1 and 2, and 37 percent lower at TSL 3--the level recommended for
the standard.
Table V.31 presents the comparison of median PBPs for the small
business subgroup in the lodging sector with national median values
(median PBPs from chapter 8 of the TSD). The PBP values are slightly
longer or the same for all equipment classes in the lodging small
business subgroup at all TSLs. As noted above, the energy savings would
be lower than a national average. Thus, the slightly lower median PBP
appears to be a result of a narrower electricity saving results
distribution that is close to but below the national average.
[[Page 4728]]
Table V.26--Comparison of Mean LCC Savings for the Foodservice Sector Small Business Subgroup With the National
Average Values
----------------------------------------------------------------------------------------------------------------
Mean LCC savings 2013$ *
Equipment class Category ------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B..................... Small Business....... 174 174 212 212 (535)
All Business Types... 175 175 214 214 (534)
IMH-W-Med-B....................... Small Business....... 312 312 312 168 (60)
All Business Types... 308 308 308 165 (63)
IMH-W-Large-B..................... Small Business....... NA NA NA NA (169)
All Business Types... NA NA NA NA (172)
IMH-W-Large-B1.................... Small Business....... NA NA NA NA (198)
All Business Types... NA NA NA NA (200)
IMH-W-Large-B2.................... Small Business....... NA NA NA NA (77)
All Business Types... NA NA NA NA (80)
IMH-A-Small-B..................... Small Business....... 139 75 78 78 (390)
All Business Types... 136 72 77 77 (393)
IMH-A-Large-B..................... Small Business....... 387 498 359 264 54
All Business Types... 382 501 361 265 55
IMH-A-Large-B1.................... Small Business....... 444 575 404 292 43
All Business Types... 439 580 407 294 45
IMH-A-Large-B2.................... Small Business....... 81 81 114 114 114
All Business Types... 76 76 110 110 110
RCU-Large-B....................... Small Business....... 754 754 754 424 150
All Business Types... 748 748 748 418 144
RCU-Large-B1...................... Small Business....... 749 749 749 397 166
All Business Types... 743 743 743 391 161
RCU-Large-B2...................... Small Business....... 832 832 832 832 (99)
All Business Types... 820 820 820 820 (109)
SCU-W-Large-B..................... Small Business....... 431 601 541 184 184
All Business Types... 444 613 550 192 192
SCU-A-Small-B..................... Small Business....... 112 162 276 226 (148)
All Business Types... 110 161 281 230 (145)
SCU-A-Large-B..................... Small Business....... 164 392 432 65 65
All Business Types... 163 400 439 71 71
IMH-A-Small-C..................... Small Business....... 248 296 317 317 (155)
All Business Types... 245 292 313 313 (165)
IMH-A-Large-C..................... Small Business....... 544 544 630 630 44
All Business Types... 539 539 626 626 28
RCU-Small-C....................... Small Business....... 503 453 509 509 (57)
All Business Types... 498 448 505 505 (73)
SCU-A-Small-C..................... Small Business....... 225 281 293 293 (257)
All Business Types... 224 278 290 290 (268)
----------------------------------------------------------------------------------------------------------------
* Values in parenthesis are negative numbers.
Table V.27--Percentage Change in Mean LCC Savings for the Foodservice Sector Small Business Subgroup Compared to
National Average Values *
----------------------------------------------------------------------------------------------------------------
Equipment class TSL 1 (%) TSL 2 (%) TSL 3 (%) TSL 4 (%) TSL 5 (%)
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B.................................. -1 -1 -1 -1 0
IMH-W-Med-B.................................... 1 1 1 2 5
IMH-W-Large-B.................................. NA NA NA NA 1
IMH-W-Large-B1................................. NA NA NA NA 1
IMH-W-Large-B2................................. NA NA NA NA 4
IMH-A-Small-B.................................. 2 3 2 2 1
IMH-A-Large-B.................................. 1 -1 -1 -1 -2
IMH-A-Large-B1................................. 1 -1 -1 -1 -4
IMH-A-Large-B2................................. 7 7 3 3 3
RCU-Large-B.................................... 1 1 1 1 4
RCU-Large-B1................................... 1 1 1 1 3
RCU-Large-B2................................... 1 1 1 1 9
SCU-W-Large-B.................................. -3 -2 -2 -4 -4
SCU-A-Small-B.................................. 1 1 -2 -2 -2
SCU-A-Large-B.................................. 1 -2 -2 -9 -9
IMH-A-Small-C.................................. 1 1 1 1 6
IMH-A-Large-C.................................. 1 1 1 1 57
RCU-Small-C.................................... 1 1 1 1 22
SCU-A-Small-C.................................. 1 1 1 1 4
----------------------------------------------------------------------------------------------------------------
* Negative percentage values imply decrease in LCC savings, and positive percentage values imply increase in LCC
savings.
[[Page 4729]]
Table V.28--Comparison of Median Payback Periods for the Foodservice Sector Small Business Subgroup With
National Median Values
----------------------------------------------------------------------------------------------------------------
Median payback period years
Equipment class Category ------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B..................... Small Business....... 2.3 2.3 2.7 2.7 12.7
All Business Types... 2.5 2.5 2.7 2.7 13.4
IMH-W-Med-B....................... Small Business....... 2.0 2.0 2.0 4.8 7.2
All Business Types... 2.1 2.1 2.1 5.0 7.6
IMH-W-Large-B..................... Small Business....... NA NA NA NA 10.0
All Business Types... NA NA NA NA 10.6
IMH-W-Large-B1.................... Small Business....... NA NA NA NA 10.5
All Business Types... NA NA NA NA 11.1
IMH-W-Large-B2.................... Small Business....... NA NA NA NA 8.4
All Business Types... NA NA NA NA 8.9
IMH-A-Small-B..................... Small Business....... 3.2 4.5 4.4 4.4 11.4
All Business Types... 3.4 4.8 4.7 4.7 11.9
IMH-A-Large-B..................... Small Business....... 2.1 2.3 2.2 3.7 5.3
All Business Types... 2.2 2.4 2.3 3.9 5.6
IMH-A-Large-B1.................... Small Business....... 1.1 1.4 1.4 3.2 5.1
All Business Types... 1.2 1.5 1.5 3.4 5.4
IMH-A-Large-B2.................... Small Business....... 7.0 7.0 6.5 6.5 6.5
All Business Types... 7.4 7.4 6.9 6.9 6.9
RCU-Large-B....................... Small Business....... 1.0 1.0 1.0 3.2 4.8
All Business Types... 1.1 1.1 1.1 3.3 5.0
RCU-Large-B1...................... Small Business....... 0.9 0.9 0.9 3.2 4.7
All Business Types... 0.9 0.9 0.9 3.4 4.9
RCU-Large-B2...................... Small Business....... 2.8 2.8 2.8 2.8 6.7
All Business Types... 3.0 3.0 3.0 3.0 7.0
SCU-W-Large-B..................... Small Business....... 1.1 1.5 1.7 4.9 4.9
All Business Types... 1.1 1.6 1.8 5.1 5.1
SCU-A-Small-B..................... Small Business....... 2.0 2.2 2.5 3.3 8.4
All Business Types... 2.2 2.4 2.6 3.5 8.9
SCU-A-Large-B..................... Small Business....... 1.7 1.6 2.0 6.2 6.2
All Business Types... 1.8 1.6 2.1 6.5 6.5
IMH-A-Small-C..................... Small Business....... 1.4 1.5 1.6 1.6 8.3
All Business Types... 1.5 1.6 1.7 1.7 8.8
IMH-A-Large-C..................... Small Business....... 0.6 0.6 0.7 0.7 5.5
All Business Types... 0.7 0.7 0.7 0.7 5.9
RCU-Small-C....................... Small Business....... 0.7 1.1 1.2 1.2 5.5
All Business Types... 0.7 1.2 1.2 1.2 5.8
SCU-A-Small-C..................... Small Business....... 0.7 1.0 1.4 1.4 10.6
All Business Types... 0.8 1.1 1.5 1.5 11.4
----------------------------------------------------------------------------------------------------------------
Table V.29--Comparison of LCC Savings for the Lodging Sector Small Business Subgroup With the National Average
Values
----------------------------------------------------------------------------------------------------------------
Mean LCC savings 2013$ *
Equipment class Category ------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B..................... Small Business....... 155 155 189 189 (561)
All Business Types... 175 175 214 214 (534)
IMH-W-Med-B....................... Small Business....... 275 275 275 123 (109)
All Business Types... 308 308 308 165 (63)
IMH-W-Large-B..................... Small Business....... NA NA NA NA (221)
All Business Types... NA NA NA NA (172)
IMH-W-Large-B1.................... Small Business....... NA NA NA NA (244)
All Business Types... NA NA NA NA (200)
IMH-W-Large-B2.................... Small Business....... NA NA NA NA (148)
All Business Types... NA NA NA NA (80)
IMH-A-Small-B..................... Small Business....... 118 54 61 61 (423)
All Business Types... 136 72 77 77 (393)
IMH-A-Large-B..................... Small Business....... 337 443 321 211 (10)
All Business Types... 382 501 361 265 55
IMH-A-Large-B1.................... Small Business....... 398 523 368 237 (25)
All Business Types... 439 580 407 294 45
IMH-A-Large-B2.................... Small Business....... 9 9 70 70 70
All Business Types... 76 76 110 110 110
RCU-Large-B....................... Small Business....... 679 679 679 347 71
All Business Types... 748 748 748 418 144
[[Page 4730]]
RCU-Large-B1...................... Small Business....... 676 676 676 322 90
All Business Types... 743 743 743 391 161
RCU-Large-B2...................... Small Business....... 718 718 718 718 (205)
All Business Types... 820 820 820 820 (109)
SCU-W-Large-B..................... Small Business....... 404 553 494 129 129
All Business Types... 444 613 550 192 192
SCU-A-Small-B..................... Small Business....... 98 142 248 196 (182)
All Business Types... 110 161 281 230 (145)
SCU-A-Large-B..................... Small Business....... 146 361 392 18 18
All Business Types... 163 400 439 71 71
IMH-A-Small-C..................... Small Business....... 222 263 282 282 (189)
All Business Types... 245 292 313 313 (165)
IMH-A-Large-C..................... Small Business....... 493 493 571 571 (33)
All Business Types... 539 539 626 626 28
RCU-Small-C....................... Small Business....... 456 406 456 456 (133)
All Business Types... 498 448 505 505 (73)
SCU-A-Small-C..................... Small Business....... 204 253 261 261 (288)
All Business Types... 224 278 290 290 (268)
----------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative numbers.
Table V.30--Percentage Change in Mean LCC Savings for the Lodging Sector Small Business Subgroup Compared to
National Average Values *
----------------------------------------------------------------------------------------------------------------
Equipment class TSL1 (%) TSL2 (%) TSL3 (%) TSL4 (%) TSL5 (%)
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B.................................. -11 -11 -12 -12 -5
IMH-W-Med-B.................................... -11 -11 -11 -26 -72
IMH-W-Large-B.................................. NA NA NA NA -29
IMH-W-Large-B1................................. NA NA NA NA -22
IMH-W-Large-B2................................. NA NA NA NA -84
IMH-A-Small-B.................................. -13 -25 -21 -21 -7
IMH-A-Large-B.................................. -12 -12 -11 -20 -118
IMH-A-Large-B1................................. -9 -10 -10 -19 -155
IMH-A-Large-B2................................. -88 -88 -37 -37 -37
RCU-Large-B.................................... -9 -9 -9 -17 -50
RCU-Large-B1................................... -9 -9 -9 -18 -44
RCU-Large-B2................................... -12 -12 -12 -12 -88
SCU-W-Large-B.................................. -9 -10 -10 -33 -33
SCU-A-Small-B.................................. -11 -11 -12 -15 -26
SCU-A-Large-B.................................. -10 -10 -11 -75 -75
IMH-A-Small-C.................................. -9 -10 -10 -10 -15
IMH-A-Large-C.................................. -9 -9 -9 -9 -215
RCU-Small-C.................................... -8 -9 -10 -10 -83
SCU-A-Small-C.................................. -9 -9 -10 -10 -7
----------------------------------------------------------------------------------------------------------------
* Negative percentage values imply decrease in LCC savings, and positive percentage values imply increase in LCC
savings.
Table V.31--Comparison of Median Payback Periods for the Lodging Sector Small Business Subgroup With the
National Median Values
----------------------------------------------------------------------------------------------------------------
Median payback period years
Equipment class Category ------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B..................... Small Business....... 2.5 2.5 2.8 2.8 13.5
All Business Types... 2.5 2.5 2.7 2.7 13.4
IMH-W-Med-B....................... Small Business....... 2.1 2.1 2.1 5.1 7.7
All Business Types... 2.1 2.1 2.1 5.0 7.6
IMH-W-Large-B..................... Small Business....... NA NA NA NA 10.7
All Business Types... NA NA NA NA 10.6
IMH-W-Large-B1.................... Small Business....... NA NA NA NA 11.2
All Business Types... NA NA NA NA 11.1
IMH-W-Large-B2.................... Small Business....... NA NA NA NA 9.0
All Business Types... NA NA NA NA 8.9
IMH-A-Small-B..................... Small Business....... 3.4 4.8 4.7 4.7 12.3
[[Page 4731]]
All Business Types... 3.4 4.8 4.7 4.7 11.9
IMH-A-Large-B..................... Small Business....... 2.2 2.4 2.3 3.9 5.7
All Business Types... 2.2 2.4 2.3 3.9 5.6
IMH-A-Large-B1.................... Small Business....... 1.2 1.5 1.5 3.4 5.4
All Business Types... 1.2 1.5 1.5 3.4 5.4
IMH-A-Large-B2.................... Small Business....... 7.5 7.5 6.9 6.9 6.9
All Business Types... 7.4 7.4 6.9 6.9 6.9
RCU-Large-B....................... Small Business....... 1.1 1.1 1.1 3.4 5.1
All Business Types... 1.1 1.1 1.1 3.3 5.0
RCU-Large-B1...................... Small Business....... 0.9 0.9 0.9 3.5 5.0
All Business Types... 0.9 0.9 0.9 3.4 4.9
RCU-Large-B2...................... Small Business....... 3.0 3.0 3.0 3.0 7.1
All Business Types... 3.0 3.0 3.0 3.0 7.0
SCU-W-Large-B..................... Small Business....... 1.1 1.6 1.8 5.2 5.2
All Business Types... 1.1 1.6 1.8 5.1 5.1
SCU-A-Small-B..................... Small Business....... 2.2 2.4 2.6 3.5 8.9
All Business Types... 2.2 2.4 2.6 3.5 8.9
SCU-A-Large-B..................... Small Business....... 1.8 1.6 2.1 6.6 6.6
All Business Types... 1.8 1.6 2.1 6.5 6.5
IMH-A-Small-C..................... Small Business....... 1.5 1.6 1.7 1.7 9.0
All Business Types... 1.5 1.6 1.7 1.7 8.8
IMH-A-Large-C..................... Small Business....... 0.7 0.7 0.7 0.7 6.0
All Business Types... 0.7 0.7 0.7 0.7 5.9
RCU-Small-C....................... Small Business....... 0.7 1.2 1.2 1.2 5.9
All Business Types... 0.7 1.2 1.2 1.2 5.8
SCU-A-Small-C..................... Small Business....... 0.8 1.1 1.5 1.5 11.7
All Business Types... 0.8 1.1 1.5 1.5 11.4
----------------------------------------------------------------------------------------------------------------
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of amended energy
conservation standards on manufacturers of automatic commercial ice
makers. The following section describes the expected impacts on
manufacturers at each TSL. Chapter 12 of the final rule TSD explains
the analysis in further detail.
a. Industry Cash Flow Analysis Results
The following tables depict the financial impacts of the new and
amended energy conservation standards on manufacturers of automatic
commercial ice makers. The financial impacts are represented by changes
in the industry net present value (INPV.) In addition, the tables
depict the conversion costs that DOE estimates manufacturers would
incur for all equipment classes at each TSL. The impact of the energy
efficiency standards on industry cash flow were analyzed under two
markup scenarios that correspond to the range of anticipated market
responses to amended energy conservation standards.
The first markup scenario assessed the lower bound of potential
impacts (higher profitability). DOE modeled a preservation of gross
margin percentage markup scenario, in which a uniform ``gross margin
percentage'' markup is applied across all efficiency levels. In this
scenario, DOE assumed that a manufacturer's absolute dollar markup
would increase as production costs increase in the amended energy
conservation standards case. Manufacturers have indicated that it is
optimistic to assume that they would be able to maintain the same gross
margin percentage markup as their production costs increase in response
to a new or amended energy conservation standard, particularly at
higher TSLs.
The second markup scenario assessed the upper bound of potential
impacts (lower profitability). DOE modeled the preservation of the EBIT
markup scenario, which assumes that manufacturers would not be able to
preserve the same overall gross margin, but instead would lower their
markup for marginally compliant products to maintain a cost-competitive
product offering and keep the same overall level of EBIT as in the base
case. Table V.32 and Table V.33 show the range of potential INPV
impacts for manufacturers of automatic commercial ice makers. The first
table reflects the lower bound of impacts (higher profitability), and
the second represents the upper bound of impacts (lower profitability).
Each scenario 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 sum of discounted cash flows through
2047, the difference in INPV between the base case and each standards
case, and the total industry conversion costs required for each
standards case.
[[Page 4732]]
Table V.32--Manufacturer Impact Analysis for Automatic Commercial Ice Makers--Preservation of Gross Margin
Percentage Markup Scenario *
----------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
INPV........................ 2013$ millions. 121.6 115.0 112.3 109.5 109.3 109.8
Change in INPV.............. 2013$ millions. .......... (6.6) (9.3) (12.1) (12.3) (11.8)
%.............. .......... (5.4) (7.7) (10.0) (10.1) (9.7)
Product Conversion Costs.... 2013$ millions. .......... 12.3 18.1 23.8 28.1 40.3
Capital Conversion Costs.... 2013$ millions. .......... 0.2 0.6 1.3 2.0 3.9
-----------------------------------------------------------------------------------
Total Conversion Costs.. 2013$ millions. .......... 12.6 18.7 25.1 30.0 44.1
----------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative numbers.
Table V.33--Manufacturer Impact Analysis for Automatic Commercial Ice Makers--Preservation of EBIT Markup
Scenario *
----------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
INPV........................ 2013$ millions. 121.6 114.1 110.4 106.5 103.0 91.6
Change in INPV.............. 2013$ millions. .......... (7.5) (11.2) (15.1) (18.6) (30.0)
%.............. .......... (6.2) (9.2) (12.5) (15.3) (24.6)
Product Conversion Costs.... 2013$ millions. .......... 12.3 18.1 23.8 28.1 40.3
Capital Conversion Costs.... 2013$ millions. .......... 0.2 0.6 1.3 2.0 3.9
-----------------------------------------------------------------------------------
Total Conversion Costs.. 2013$ millions. .......... 12.6 18.7 25.1 30.0 44.1
----------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative numbers.
Beyond impacts on INPV, DOE includes a comparison of free cash flow
between the base case and the standards case at each TSL in the year
before amended standards take effect to provide perspective on the
short-run cash flow impacts in the discussion of the following results.
At TSL 1, DOE estimates impacts on INPV for manufacturers of
automatic commercial ice makers to range from -$7.5 million to -$6.6
million, or a change in INPV of -6.2 percent to -5.4 percent. At this
TSL, industry free cash flow is estimated to decrease to $6.7 million,
or a drop of 35.7 percent, compared to the base-case value of $10.4
million in the year before the compliance date (2017).
DOE estimates that approximately 27 percent of all batch commercial
ice makers and 29 percent of all continuous commercial ice makers on
the market will require redesign to meet standards at TSL 1. At this
TSL DOE expects capital and product conversion costs of $0.2 million
and $12.3 million, respectively. Combined, the total conversion cost is
$12.5 million.
At TSL 2, DOE estimates impacts on INPV for manufacturers of
automatic commercial ice makers to range from -$11.2 million to -$9.3
million, or a change in INPV of -9.2 percent to -7.7 percent. At this
TSL, industry free cash flow is estimated to decrease to $4.8 million,
or a drop of 53.5 percent, compared to the base-case value of $10.4
million in the year before the compliance date (2017).
DOE estimates that approximately 39 percent of all batch commercial
ice makers and 41 percent of all continuous commercial ice makers on
the market will require redesign to meet standards at TSL 2. At this
TSL, DOE expects industry capital and product conversion costs of $0.6
million and of $18.1 million, respectively. Combined, the total
conversion cost is $18.7 million, 48 percent higher than those incurred
by industry at TSL 1.
At TSL 3, DOE estimates impacts on INPV for manufacturers of
automatic commercial ice makers to range from -$15.1 million to -$12.1
million, or a change in INPV of -12.5 percent to -10.0 percent. At this
TSL, industry free cash flow is estimated to decrease to $2.9 million,
or a drop of 72.4 percent, compared to the base-case value of $10.4
million in the year before the compliance date (2017).
DOE estimates that approximately 51 percent of all batch commercial
ice makers and 55 percent of all continuous commercial ice makers on
the market will require redesign to meet standards at TSL 3. At this
TSL, DOE expects industry capital and product conversion costs of $23.8
million and of $1.3 million, respectively. Combined, the total
conversion cost is $25.1 million, 34 percent higher than those incurred
by industry at TSL 2.
At TSL 4, DOE estimates impacts on INPV for manufacturers of
automatic commercial ice makers to range from -$18.6 million to -$12.3
million, or a change in INPV of -15.3 percent to -10.1 percent. At this
TSL, industry free cash flow is estimated to decrease to $0.9 million,
or a drop of 91.1 percent, compared to the base-case value of $10.4
million in the year before the compliance date (2017).
DOE estimates that approximately 66 percent of all batch commercial
ice makers and 55 percent of all continuous commercial ice makers on
the market will require redesign to meet standards at TSL 4.
Additionally, for four equipment classes, there is only one
manufacturer with products that currently meet the standard. At this
TSL, DOE expects industry capital and product conversion costs of $2.0
million and of $28.1 million, respectively. Combined, the total
conversion cost is $30.0 million, 20 percent higher than those incurred
by industry at TSL 3.
At TSL 5, DOE estimates impacts on INPV for manufacturers of
automatic commercial ice makers to range from -$30.0 million to -$11.8
million, or a change in INPV of -24.6 percent to -9.7 percent. At this
TSL, industry free cash flow is estimated to decrease to -$5.3 million,
or a drop of 151.1 percent, compared to the base-case
[[Page 4733]]
value of $10.4 million in the year before the compliance date (2017).
DOE estimates that approximately 84 percent of all batch commercial
ice makers and 78 percent of all continuous commercial ice makers on
the market will require redesign to meet standards at TSL 5.
Additionally, for five equipment classes, there is only one
manufacturer with products that currently meet the standard. At this
TSL, DOE expects industry capital and product conversion costs of $3.9
million and of $40.3 million, respectively. Combined, the total
conversion cost is $44.1 million, 47 percent higher than those incurred
by industry at TSL 4.
b. Impacts on Direct Employment
DOE used the GRIM to estimate the domestic labor expenditures and
number of domestic production workers in the base case and at each TSL
from 2015 through 2047. DOE used statistical data from the most recent
U.S Census Bureau's 2011 Annual Survey of Manufactures (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 the manufacture of a product are a function of the labor intensity
of the product, the sales volume, and an assumption that wages in real
terms remain constant.
In the GRIM, DOE used the labor content of each product and the
manufacturing production costs from the engineering analysis to
estimate the annual labor expenditures in the automatic commercial ice
maker industry. 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
worker (production worker hours multiplied by the labor rate found in
the U.S. Census Bureau's ASM).
The estimates of production workers in this section cover workers,
including line-supervisors, who are directly involved in fabricating
and assembling automatic commercial ice makers within an original
equipment manufacturer (OEM) facility. Workers performing services that
are closely associated with production operations, such as material
handling with a forklift, are also included as production labor.
The employment impacts shown in Table V.34 represent the potential
production employment changes that could result following the
compliance date of new and amended energy conservation standards. The
upper end of the employment results in Table V.34 estimates the maximum
increase in the number of production workers after implementation of
new or amended energy conservation standards and it assumes that
manufacturers continue to produce the same scope of covered products in
the U.S. The lower end of employment results in Table V.34 represent
the maximum decrease to the total number of U.S. production workers in
the industry due to manufacturers moving production outside of the U.S.
While the results present a range of employment impacts following the
compliance date of the new and amended energy conservation standards,
the following discussion also includes a qualitative discussion of the
likelihood of negative employment impacts at the various TSLs. Finally,
the employment impacts shown are independent of the employment impacts
from the broader U.S. economy, which are documented in chapter 13 of
the final rule TSD.
DOE estimates that in the absence of amended energy conservation
standards, there would be 389 domestic production workers involved in
manufacturing automatic commercial ice makers in 2018. Using 2011
Census Bureau data and interviews with manufacturers, DOE estimates
that approximately 84 percent of automatic commercial ice makers sold
in the United States are manufactured domestically. Table V.34 shows
the range of the impacts of potential amended energy conservation
standards on U.S. production workers in the automatic commercial ice
maker industry.
Table V.34--Potential Changes in the Total Number of Domestic Automatic Commercial Ice Maker Production Workers
in 2018
----------------------------------------------------------------------------------------------------------------
Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
Total Number of Domestic 389 391 402 414 418 444
Production Workers in 2018
(without changes in production
locations).......................
Potential Changes in Domestic ........... (389) to 2 (389) to 13 (389) to 25 (389) to 29 (389) to 55
Production Workers in 2018 *.....
----------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Values in parentheses are negative numbers.
At all TSLs, most of the design options analyzed by DOE do not
greatly alter the labor content of the final product. For example, the
use of higher efficiency compressors or fan motors involve one-time
changes to the final product but do not significantly change the amount
of production hours required for the final assembly. One manufacturer
suggested that their domestic production employment levels would only
change if market demand contracted following higher overall prices.
However, more than one manufacturer suggested that where they already
have overseas manufacturing capabilities, they would consider moving
additional manufacturing to those facilities if they felt the need to
offset a significant rise in materials costs. Provided the changes in
materials costs do not support the relocation of manufacturing
facilities, DOE would expect only modest changes to domestic
manufacturing employment balancing additional requirements for assembly
labor with the effects of price elasticity.
c. Impacts on Manufacturing Capacity
According to the majority of automatic commercial ice maker
manufacturers interviewed, new or amended energy conservation standards
that require modest changes to product efficiency will not
significantly affect manufacturers' production capacities. Any redesign
of automatic commercial ice makers would not change the fundamental
assembly of the equipment, but manufacturers do anticipate some
potential for additional lead time immediately following standards
associated with changes in sourcing of higher efficiency components,
which may be supply constrained.
One manufacturer cited the possibility of a 3- to 6-month shutdown
in the event that amended standards were set high enough to require
retooling of their entire product line. Most of the design options that
were evaluated are already available on the market as product options.
Thus, DOE
[[Page 4734]]
believes that, short of widespread retooling, manufacturers will be
able to maintain manufacturing capacity levels and continue to meet
market demand under amended energy conservation standards.
d. Impacts on Subgroups of Manufacturers
Small business, low-volume, niche equipment manufacturers, and
manufacturers exhibiting a cost structure substantially different from
the industry average could be affected disproportionately. As discussed
in section IV.J, using average cost assumptions to develop an industry
cash flow estimate is inadequate to assess differential impacts among
manufacturer subgroups.
For automatic commercial ice makers, DOE identified and evaluated
the impact of amended energy conservation standards on one subgroup:
small manufacturers. The SBA defines a ``small business'' as having
fewer than 750 employees for NAICS 333415, ``Air-Conditioning and Warm
Air Heating Equipment and Commercial and Industrial Refrigeration
Equipment Manufacturing,'' which includes ice-making machinery
manufacturing. DOE identified seven manufacturers in the automatic
commercial ice makers industry that meet this definition.
For a discussion of the impacts on the small manufacturer subgroup,
see the regulatory flexibility analysis in section VI.B of this
preamble and chapter 12 of the final rule TSD.
e. Cumulative Regulatory Burden
While any one regulation may not impose a significant burden on
manufacturers, the combined effects of recent or 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. In addition
to energy conservation standards, other regulations can significantly
affect manufacturers' financial operations. Multiple regulations
affecting the same manufacturer can strain profits and 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
equipment efficiency.
For the cumulative regulatory burden analysis, DOE looks at other
regulations that could affect ACIM manufacturers that will take effect
approximately 3 years before or after the 2018 compliance date of
amended energy conservation standards for these products. In written
comments, manufacturers cited Federal regulations on equipment other
than automatic commercial ice makers that contribute to their
cumulative regulatory burden. The compliance years and expected
industry conversion costs of relevant amended energy conservation
standards are indicated in Table V.35.
Table V.35--Compliance Dates and Expected Conversion Expenses of Federal
Energy Conservation Standards Affecting Automatic Commercial Ice Maker
Manufacturers
------------------------------------------------------------------------
Estimated total
Federal energy conservation Approximate industry
standards compliance date conversion expense
------------------------------------------------------------------------
Commercial refrigeration 2017 $184.0M, (2012$)
equipment, 79 FR 17725 (March
28, 2014).....................
Walk-in Coolers and Freezers, 2017 $33.6.0M, (2012$)
79 FR 32049 (June 3, 2014)....
Miscellaneous Refrigeration TBD TBD
Equipment *...................
------------------------------------------------------------------------
* The final rule for this energy conservation standard has not been
published. The compliance date and analysis of conversion costs have
not been finalized at this time.
DOE discusses these and other requirements and includes the full
details of the cumulative regulatory burden analysis in chapter 12 of
the final rule TSD.
3. National Impact Analysis
a. Amount and Significance of Energy Savings
DOE estimated the NES by calculating the difference in annual
energy consumption for the base-case scenario and standards-case
scenario at each TSL for each equipment class and summing up the annual
energy savings for the automatic commercial ice maker equipment
purchased during the 30-year 2018 through 2047 analysis period. Energy
impacts include the 30-year period, plus the life of equipment
purchased in the last year of the analysis, or roughly 2018 through
2057. The energy consumption calculated in the NIA is full-fuel-cycle
(FFC) energy, which quantifies savings beginning at the source of
energy production. DOE also reports primary or source energy that takes
into account losses in the generation and transmission of electricity.
FFC and primary energy are discussed in section IV.H.3.
Table V.36 presents the source NES for all equipment classes at
each TSL and the sum total of NES for each TSL.
Table V.37 presents the energy savings at each TSL for each
equipment class in the form of percentage of the cumulative energy use
of the equipment stock in the base-case scenario.
Table V.36--Cumulative National Energy Savings at Source for Equipment Purchased in 2018-2047
[Quads]
----------------------------------------------------------------------------------------------------------------
Standard level * **
Equipment class ----------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B.................................. 0.002 0.002 0.004 0.004 0.009
IMH-W-Med-B.................................... 0.005 0.005 0.005 0.008 0.010
IMH-W-Large-B [dagger]......................... 0.000 0.000 0.000 0.000 0.002
IMH-W-Large-B1................................. 0.000 0.000 0.000 0.000 0.001
IMH-W-Large-B2................................. 0.000 0.000 0.000 0.000 0.001
IMH-A-Small-B.................................. 0.011 0.023 0.037 0.037 0.071
IMH-A-Large-B [dagger]......................... 0.019 0.034 0.039 0.058 0.075
[[Page 4735]]
IMH-A-Large-B1................................. 0.016 0.031 0.035 0.055 0.071
IMH-A-Large-B2................................. 0.002 0.002 0.003 0.003 0.003
RCU-Large-B [dagger]........................... 0.015 0.015 0.015 0.029 0.037
RCU-Large-B1................................... 0.014 0.014 0.014 0.027 0.035
RCU-Large-B2................................... 0.001 0.001 0.001 0.001 0.002
SCU-W-Large-B.................................. 0.000 0.001 0.001 0.001 0.001
SCU-A-Small-B.................................. 0.007 0.018 0.024 0.032 0.036
SCU-A-Large-B.................................. 0.006 0.014 0.019 0.023 0.023
IMH-A-Small-C.................................. 0.002 0.004 0.006 0.006 0.009
IMH-A-Large-C.................................. 0.002 0.002 0.003 0.003 0.006
RCU-Small-C.................................... 0.001 0.002 0.003 0.003 0.005
SCU-A-Small-C.................................. 0.006 0.010 0.015 0.015 0.023
----------------------------------------------------------------
Total...................................... 0.077 0.130 0.171 0.219 0.307
----------------------------------------------------------------------------------------------------------------
* A value equal to 0.000 means the NES rounds to less than 0.001 quads.
** Numbers may not add to totals, due to rounding.
[dagger] IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the two typical
units denoted by B1 and B2.
Table V.37--Cumulative Source Energy Savings by TSL as a Percentage of Cumulative Baseline Energy Usage of
Automatic Commercial Ice Maker Equipment Purchased in 2018-2047
----------------------------------------------------------------------------------------------------------------
Base case TSL Savings as percent of baseline usage
energy ----------------------------------------------------------------
Equipment class usage
(quads) TSL 1 (%) TSL 2 (%) TSL 3 (%) TSL 4 (%) TSL 5 (%)
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B..................... 0.064 4 4 6 6 15
IMH-W-Med-B....................... 0.089 5 5 5 9 12
IMH-W-Large-B *................... 0.028 0 0 0 0 6
IMH-W-Large-B1.................... 0.018 0 0 0 0 7
IMH-W-Large-B2.................... 0.010 0 0 0 0 6
IMH-A-Small-B..................... 0.467 2 5 8 8 15
IMH-A-Large-B *................... 0.644 3 5 6 9 12
IMH-A-Large-B1.................... 0.495 3 6 7 11 14
IMH-A-Large-B2.................... 0.149 2 2 2 2 2
RCU-Large-B *..................... 0.368 4 4 4 8 10
RCU-Large-B1...................... 0.343 4 4 4 8 10
RCU-Large-B2...................... 0.026 4 4 4 4 7
SCU-W-Large-B..................... 0.004 7 14 18 23 23
SCU-A-Small-B..................... 0.150 5 12 16 21 24
SCU-A-Large-B..................... 0.102 6 14 19 23 23
IMH-A-Small-C..................... 0.071 3 5 8 8 12
IMH-A-Large-C..................... 0.044 4 4 7 7 14
RCU-Small-C....................... 0.031 3 6 10 10 16
SCU-A-Small-C..................... 0.145 4 7 10 10 16
-----------------------------------------------------------------------------
Total......................... 2.206 3 6 8 10 14
----------------------------------------------------------------------------------------------------------------
* IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the 2 typical units
denoted by B1 and B2.
Table V.38 presents energy savings at each TSL for each equipment
class with the FFC adjustment. The NES increases from 0.081 quads at
TSL 1 to 0.321 quads at TSL 5.
Table V.38--Cumulative National Energy Savings Including Full-Fuel-Cycle for Equipment Purchased in 2018-2047
[Quads]
----------------------------------------------------------------------------------------------------------------
Standard level * **
Equipment class ----------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B.................................. 0.002 0.002 0.004 0.004 0.010
IMH-W-Med-B.................................... 0.005 0.005 0.005 0.008 0.011
IMH-W-Large-B [dagger]......................... 0.000 0.000 0.000 0.000 0.002
[[Page 4736]]
IMH-W-Large-B1................................. 0.000 0.000 0.000 0.000 0.001
IMH-W-Large-B2................................. 0.000 0.000 0.000 0.000 0.001
IMH-A-Small-B.................................. 0.011 0.024 0.039 0.039 0.075
IMH-A-Large-B [dagger]......................... 0.020 0.035 0.040 0.061 0.078
IMH-A-Large-B1................................. 0.017 0.033 0.037 0.057 0.075
IMH-A-Large-B2................................. 0.003 0.003 0.004 0.004 0.004
RCU-Large-B [dagger]........................... 0.016 0.016 0.016 0.030 0.038
RCU-Large-B1................................... 0.015 0.015 0.015 0.029 0.037
RCU-Large-B2................................... 0.001 0.001 0.001 0.001 0.002
SCU-W-Large-B.................................. 0.000 0.001 0.001 0.001 0.001
SCU-A-Small-B.................................. 0.008 0.019 0.026 0.033 0.037
SCU-A-Large-B.................................. 0.006 0.015 0.020 0.024 0.024
IMH-A-Small-C.................................. 0.002 0.004 0.006 0.006 0.009
IMH-A-Large-C.................................. 0.002 0.002 0.003 0.003 0.007
RCU-Small-C.................................... 0.001 0.002 0.003 0.003 0.005
SCU-A-Small-C.................................. 0.007 0.011 0.016 0.016 0.024
----------------------------------------------------------------
Total...................................... 0.081 0.136 0.179 0.229 0.321
----------------------------------------------------------------------------------------------------------------
* A value equal to 0.000 means the NES rounds to less than 0.001 quads
** Numbers may not add to totals due to rounding.
[dagger] IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the 2 typical
units denoted by B1 and B2.
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 9, rather than 30, years of product
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.\73\
The review timeframe established in EPCA generally is not synchronized
with the product lifetime, product manufacturing cycles or other
factors specific to automatic commercial ice makers. Thus, this
information is presented for informational purposes only and is not
indicative of any change in DOE's analytical methodology. The NES
results based on a 9-year analysis period are presented in Table V.39 .
The impacts are counted over the lifetime of equipment purchased in
2018 through 2026.
---------------------------------------------------------------------------
\73\ For automatic commercial ice makers, DOE is required to
review standards at least every five years after the effective date
of any amended standards. (42 U.S.C. 6313(d)(3)(B)) If new standards
are promulgated, EPCA requires DOE to provide manufacturers a
minimum of 3 and a maximum of 5 years to comply with the standards.
(42 U.S.C. 6313(d)(3)(C)) In addition, for certain other types of
commercial equipment that are not specified in 42 U.S.C. 6311(1)(B)-
(G), EPCA requires DOE to review its standards at least once every 6
years (42 U.S.C. 6295(m)(1) and 6316(a)), and either a 3-year or a
5-year period after any new standard is promulgated before
compliance is required. (42 U.S.C. 6295(m)(4) and 6316(a)) As a
result, DOE's standards for automatic commercial ice makers can be
expected to be in effect for 8 to 10 years between compliance dates,
and its standards governing certain other commercial equipment, the
period is 9 to 11 years. A 9-year analysis was selected as
representative of the time between standard revisions.
Table V.39--National Full-Fuel-Cycle Energy Savings for 9-Year Analysis Period for Equipment Purchased in 2018-
2026
[Quads]
----------------------------------------------------------------------------------------------------------------
Standard level * **
Equipment class ----------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B.................................. 0.001 0.001 0.001 0.001 0.003
IMH-W-Med-B.................................... 0.001 0.001 0.001 0.002 0.003
IMH-W-Large-B [dagger]......................... 0.000 0.000 0.000 0.000 0.001
IMH-W-Large-B1................................. 0.000 0.000 0.000 0.000 0.000
IMH-W-Large-B2................................. 0.000 0.000 0.000 0.000 0.000
IMH-A-Small-B.................................. 0.003 0.007 0.012 0.012 0.022
IMH-A-Large-B [dagger]......................... 0.006 0.011 0.012 0.018 0.023
IMH-A-Large-B1................................. 0.005 0.010 0.011 0.017 0.022
IMH-A-Large-B2................................. 0.001 0.001 0.001 0.001 0.001
RCU-Large-B [dagger]........................... 0.005 0.005 0.005 0.009 0.012
RCU-Large-B1................................... 0.005 0.005 0.005 0.009 0.011
RCU-Large-B2................................... 0.000 0.000 0.000 0.000 0.001
SCU-W-Large-B.................................. 0.000 0.000 0.000 0.000 0.000
SCU-A-Small-B.................................. 0.002 0.006 0.008 0.010 0.011
[[Page 4737]]
SCU-A-Large-B.................................. 0.002 0.004 0.006 0.007 0.007
IMH-A-Small-C.................................. 0.001 0.001 0.002 0.002 0.003
IMH-A-Large-C.................................. 0.001 0.001 0.001 0.001 0.002
RCU-Small-C.................................... 0.000 0.001 0.001 0.001 0.002
SCU-A-Small-C.................................. 0.002 0.003 0.005 0.005 0.007
----------------------------------------------------------------
Total...................................... 0.024 0.041 0.054 0.069 0.097
----------------------------------------------------------------------------------------------------------------
* A value equal to 0.000 means the NES rounds to less than 0.001 quads.
** Numbers may not add to totals due to rounding.
[dagger] IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the 2 typical
units denoted by B1 and B2.
b. Net Present Value of Customer Costs and Benefits
DOE estimated the cumulative NPV to the Nation of the total savings
for the customers that would result from potential standards at each
TSL. 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 opportunity cost of capital in the
private sector, because 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 amended 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 CPI),
which has averaged about 3 percent on a pre-tax basis for the last 30
years.
Table V.40 and Table V.41 show the customer NPV results for each of
the TSLs DOE considered for automatic commercial ice makers at both 7-
percent and 3-percent discount rates, respectively. In each case, the
impacts cover the expected lifetime of equipment purchased from 2018
through 2047. Detailed NPV results are presented in chapter 10 of the
final rule TSD.
The NPV results at a 7-percent discount rate for TSL 5 were
negative for 9 classes, and also for one of the typical size units of a
large batch equipment class for which the class total was positive. In
all cases the TSL 5 NPV was significantly lower than the TSL 3 results.
This is consistent with the LCC analysis results for TSL 5, which
showed significant increase in LCC and significantly higher PBPs that
were in some cases greater than the average equipment lifetimes.
Efficiency levels for TSL 4 were chosen to correspond to the highest
efficiency level with a positive NPV for all classes at a 7-percent
discount rate. Similarly, the criteria for choice of efficiency levels
for TSL 3, TSL 2, and TSL 1 were such that the NPV values for all the
equipment classes show positive values. The criterion for TSL 3 was to
select efficiency levels with the highest NPV at a 7-percent discount
rate. Consequently, the total NPV for automatic commercial ice makers
was highest for TSL 3, with a value of $0.430 billion (2013$) at a 7-
percent discount rate. TSL 4 showed the second highest total NPV, with
a value of $0.337 billion (2013$) at a 7-percent discount rate. TSL 1,
TSL 2 and TSL 5 have a total NPV lower than TSL 3 or 4.
Table V.40--Net Present Value at a 7-Percent Discount Rate for Equipment Purchased in 2018-2047
[Billion 2013$]
----------------------------------------------------------------------------------------------------------------
Standard level *
Equipment class -------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B............................... 0.006 0.006 0.011 0.011 (0.049)
IMH-W-Med-B................................. 0.010 0.010 0.010 0.006 (0.008)
IMH-W-Large-B **............................ 0.000 0.000 0.000 0.000 (0.002)
IMH-W-Large-B1.............................. 0.000 0.000 0.000 0.000 (0.002)
IMH-W-Large-B2.............................. 0.000 0.000 0.000 0.000 (0.000)
IMH-A-Small-B............................... 0.017 0.017 0.036 0.036 (0.238)
IMH-A-Large-B **............................ 0.043 0.109 0.120 0.109 0.021
IMH-A-Large-B1.............................. 0.043 0.109 0.119 0.107 0.020
IMH-A-Large-B2.............................. (0.000) (0.000) 0.001 0.001 0.001
RCU-Large-B **.............................. 0.042 0.042 0.042 0.035 0.007
RCU-Large-B1................................ 0.040 0.040 0.040 0.033 0.008
RCU-Large-B2................................ 0.002 0.002 0.002 0.002 (0.001)
SCU-W-Large-B............................... 0.002 0.002 0.003 0.001 0.001
SCU-A-Small-B............................... 0.016 0.037 0.076 0.068 (0.060)
SCU-A-Large-B............................... 0.014 0.059 0.064 0.004 0.004
IMH-A-Small-C............................... 0.006 0.009 0.014 0.014 (0.014)
IMH-A-Large-C............................... 0.005 0.005 0.009 0.009 (0.001)
RCU-Small-C................................. 0.002 0.004 0.008 0.008 (0.003)
[[Page 4738]]
SCU-A-Small-C............................... 0.018 0.027 0.036 0.036 (0.062)
-------------------------------------------------------------------
Total................................... 0.183 0.328 0.430 0.337 (0.406)
----------------------------------------------------------------------------------------------------------------
* A value equal to 0.000 means the NPV rounds to less than $0.001 (2013$). Values in parentheses are negative
numbers.
** IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the 2 typical units
denoted by B1 and B2.
Table V.41--Net Present Value at a 3-Percent Discount Rate for Equipment Purchased in 2018-2047
[Billion 2013$]
----------------------------------------------------------------------------------------------------------------
Standard level *
Equipment class -------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B............................... 0.014 0.014 0.025 0.025 (0.074)
IMH-W-Med-B................................. 0.022 0.022 0.022 0.016 (0.008)
IMH-W-Large-B **............................ 0.000 0.000 0.000 0.000 (0.003)
IMH-W-Large-B1.............................. 0.000 0.000 0.000 0.000 (0.003)
IMH-W-Large-B2.............................. 0.000 0.000 0.000 0.000 (0.000)
IMH-A-Small-B............................... 0.039 0.046 0.092 0.092 (0.360)
IMH-A-Large-B **............................ 0.091 0.234 0.259 0.271 0.122
IMH-A-Large-B1.............................. 0.090 0.233 0.254 0.266 0.117
IMH-A-Large-B2.............................. 0.001 0.001 0.005 0.005 0.005
RCU-Large-B **.............................. 0.088 0.088 0.088 0.084 0.039
RCU-Large-B1................................ 0.084 0.084 0.084 0.080 0.039
RCU-Large-B2................................ 0.004 0.004 0.004 0.004 (0.001)
SCU-W-Large-B............................... 0.003 0.005 0.005 0.002 0.002
SCU-A-Small-B............................... 0.035 0.079 0.169 0.159 (0.075)
SCU-A-Large-B............................... 0.030 0.127 0.138 0.031 0.031
IMH-A-Small-C............................... 0.012 0.019 0.030 0.030 (0.022)
IMH-A-Large-C............................... 0.011 0.011 0.019 0.019 0.001
RCU-Small-C................................. 0.005 0.009 0.017 0.017 (0.002)
SCU-A-Small-C............................... 0.038 0.057 0.076 0.076 (0.103)
-------------------------------------------------------------------
Total................................... 0.389 0.712 0.942 0.822 (0.453)
----------------------------------------------------------------------------------------------------------------
* A value equal to 0.000 means the NPV rounds to less than $0.001 (2013$). Values in parentheses are negative
numbers.
** IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the 2 typical units
denoted by B1 and B2.
The NPV results based on the aforementioned 9-year analysis period
are presented in Table V.42 and Table V.43. The impacts are counted
over the lifetime of equipment purchased in 2018-2026. 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.42--Net Present Value at a 7-Percent Discount Rate for 9-Year Analysis Period for Equipment Purchased in
2018-2026
[Billion 2013$]
----------------------------------------------------------------------------------------------------------------
Standard level *
Equipment class -------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B............................... 0.003 0.003 0.005 0.005 (0.030)
IMH-W-Med-B................................. 0.005 0.005 0.005 0.003 (0.004)
IMH-W-Large-B............................... 0.000 0.000 0.000 0.000 (0.001)
IMH-W-Large-B-1............................. 0.000 0.000 0.000 0.000 (0.001)
IMH-W-Large-B-2............................. 0.000 0.000 0.000 0.000 (0.000)
IMH-A-Small-B............................... 0.009 0.009 0.018 0.018 (0.137)
IMH-A-Large-B............................... 0.021 0.051 0.057 0.036 (0.005)
IMH-A-Large-B-1............................. 0.021 0.052 0.057 0.036 (0.006)
IMH-A-Large-B-2............................. (0.000) (0.000) 0.001 0.001 0.001
RCU-Large-B................................. 0.021 0.021 0.021 0.018 0.004
RCU-Large-B-1............................... 0.020 0.020 0.020 0.017 0.005
RCU-Large-B-2............................... 0.001 0.001 0.001 0.001 (0.001)
SCU-W-Large-B............................... 0.001 0.001 0.001 0.000 0.000
SCU-A-Small-B............................... 0.008 0.018 0.036 0.032 (0.030)
[[Page 4739]]
SCU-A-Large-B............................... 0.007 0.028 0.030 0.001 0.001
IMH-A-Small-C............................... 0.003 0.004 0.007 0.007 (0.007)
IMH-A-Large-C............................... 0.003 0.003 0.005 0.005 (0.000)
RCU-Small-C................................. 0.001 0.002 0.004 0.004 (0.001)
SCU-A-Small-C............................... 0.009 0.013 0.018 0.018 (0.030)
-------------------------------------------------------------------
Total................................... 0.090 0.158 0.207 0.147 (0.241)
----------------------------------------------------------------------------------------------------------------
* A value equal to 0.000 means the NPV rounds to less than $0.001 (2013$). Values in parentheses are negative
numbers.
Table V.43--Net Present Value at a 3-Percent Discount Rate for 9-Year Analysis Period for Equipment Purchased in
2018-2026
[Billion 2013$]
----------------------------------------------------------------------------------------------------------------
Standard level *
Equipment class -----------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B................................. 0.005 0.005 0.009 0.009 (0.038)
IMH-W-Med-B................................... 0.008 0.008 0.008 0.006 (0.002)
IMH-W-Large-B................................. 0.000 0.000 0.000 0.000 (0.001)
IMH-W-Large-B-1............................... 0.000 0.000 0.000 0.000 (0.001)
IMH-W-Large-B-2............................... 0.000 0.000 0.000 0.000 (0.000)
IMH-A-Small-B................................. 0.014 0.017 0.035 0.035 (0.168)
IMH-A-Large-B................................. 0.033 0.081 0.090 0.067 0.016
IMH-A-Large-B-1............................... 0.033 0.081 0.089 0.065 0.014
IMH-A-Large-B-2............................... 0.001 0.001 0.002 0.002 0.002
RCU-Large-B................................... 0.032 0.032 0.032 0.031 0.015
RCU-Large-B-1................................. 0.030 0.030 0.030 0.030 0.016
RCU-Large-B-2................................. 0.002 0.002 0.002 0.002 (0.000)
SCU-W-Large-B................................. 0.001 0.002 0.002 0.001 0.001
SCU-A-Small-B................................. 0.013 0.029 0.057 0.054 (0.029)
SCU-A-Large-B................................. 0.011 0.043 0.047 0.010 0.010
IMH-A-Small-C................................. 0.004 0.007 0.011 0.011 (0.008)
IMH-A-Large-C................................. 0.004 0.004 0.007 0.007 0.001
RCU-Small-C................................... 0.002 0.003 0.006 0.006 (0.001)
SCU-A-Small-C................................. 0.014 0.021 0.028 0.028 (0.037)
-----------------------------------------------------------------
Total..................................... 0.142 0.253 0.332 0.264 (0.241)
----------------------------------------------------------------------------------------------------------------
* A value equal to 0.000 means the NPV rounds to less than $0.001 (2013$). Values in parentheses are negative
numbers.
c. Water Savings
One energy-saving design option for batch type ice makers had the
additional benefit of reducing potable water usage for some types of
batch type ice makers. The water savings are identified on Table V.44.
DOE is not, as part of this rulemaking, establishing a potable water
standard. The water savings identified through the analyses are
products of the analysis of energy-saving design options.
Table V.44--Water Savings
----------------------------------------------------------------------------------------------------------------
Water savings by standard level * ** million gallons
Equipment class ----------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B.................................. 761 761 1,733 1,733 1,733
IMH-W-Med-B.................................... 0 0 0 0 0
IMH-W-Large-B.................................. 0 0 0 0 0
IMH-W-Large-B1................................. 0 0 0 0 0
IMH-W-Large-B2................................. 0 0 0 0 0
IMH-A-Small-B.................................. 0 0 0 0 -5,424
IMH-A-Large-B.................................. 0 12,501 12,501 11,733 11,733
IMH-A-Large-B1................................. 0 12,501 12,501 11,733 11,733
IMH-A-Large-B2................................. 0 0 0 0 0
RCU-Large-B.................................... 0 0 0 0 0
RCU-Large-B1................................... 0 0 0 0 0
RCU-Large-B2................................... 0 0 0 0 0
[[Page 4740]]
SCU-W-Large-B.................................. 336 336 336 336 336
SCU-A-Small-B.................................. 0 0 13,580 13,580 13,580
SCU-A-Large-B.................................. 0 9,388 9,388 9,388 9,388
IMH-A-Small-C.................................. 0 0 0 0 0
IMH-A-Large-C.................................. 0 0 0 0 0
RCU-Small-C.................................... 0 0 0 0 0
SCU-A-Small-C.................................. 0 0 0 0 0
----------------------------------------------------------------
Total...................................... 1,097 22,987 37,539 36,771 31,347
----------------------------------------------------------------------------------------------------------------
* A zero indicates no water usage reductions were identified.
** IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the 2 typical units
denoted by B1 and B2.
d. Indirect Employment Impacts
In addition to the direct impacts on manufacturing employment
discussed in section IV.N, DOE develops general estimates of the
indirect employment impacts of the new and amended standards on the
economy. DOE expects amended energy conservation standards for
automatic commercial ice makers to reduce energy bills for commercial
customers and expects 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 automatic commercial ice maker
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 new and
amended standards. These impacts may affect a variety of businesses not
directly involved in the decision to make, operate, or pay the utility
bills for automatic commercial ice makers. 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 BLS data (as described in section IV.J of this rulemaking; see
chapter 16 of the final rule TSD for more details).
Customers who purchase more-efficient equipment pay lower amounts
towards utility bills, which results in job losses in the electric
utilities sector. In this input/output model, the dollars saved on
utility bills from more-efficient automatic commercial ice makers are
spent in economic sectors that create more jobs than are lost in
electric and water utilities sectors. Thus, the new and amended energy
conservation standards for automatic commercial ice makers are likely
to slightly increase the net demand for labor in the economy. 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
includes the quality of jobs. As shown in Table V.45, DOE estimates
that net indirect employment impacts from new and amended automatic
commercial ice makers standard are small relative to the national
economy.
Table V.45--Net Short-Term Change in Employment
[Number of employees]
------------------------------------------------------------------------
Trial standard level 2018 2022
------------------------------------------------------------------------
1.............................. 18 to 21........... 104 to 107.
2.............................. 31 to 38........... 196 to 204.
3.............................. 41 to 52........... 263 to 276.
4.............................. 41 to 63........... 315 to 340.
5.............................. 4 to 82............ 376 to 464.
------------------------------------------------------------------------
4. Impact on Utility or Performance of Equipment
In performing the engineering analysis, DOE considers design
options that would not lessen the utility or performance of the
individual classes of equipment. (42 U.S.C. 6295(o)(2)(B)(i)(IV) and
6313(d)(4)) As presented in the screening analysis (chapter 4 of the
final rule TSD), DOE eliminates from consideration any design options
that reduce the utility of the equipment. For this rulemaking, DOE did
not consider TSLs for automatic commercial ice makers that reduce the
utility or performance of the equipment.
5. Impact of Any Lessening of Competition
EPCA directs DOE to consider any lessening of competition likely to
result from amended standards. It directs the Attorney General of the
United States (Attorney General) to determine in writing the impact, if
any, of any lessening of competition likely to result from a proposed
standard. (42 U.S.C. 6295(o)(2)(B)(i)(V) and 6313(d)(4)) To assist the
Attorney General in making such a determination, DOE provided the DOJ
with copies of this rule and the TSD for review. During MIA interviews,
domestic manufacturers indicated that foreign manufacturers have begun
to enter the automatic commercial ice maker industry, but not in
significant numbers. Manufacturers also stated that consolidation has
occurred among automatic commercial ice makers manufacturers in recent
years. Interviewed manufacturers believe that these trends may continue
in this market even in the absence of amended standards.
More than one manufacturer suggested that where they already have
overseas manufacturing capabilities, they would consider moving
additional manufacturing to those facilities if they felt the need to
offset a significant rise in materials costs. The Department
acknowledges that to be competitive in the marketplace manufacturers
must constantly re-examine their supply chains and manufacturing
infrastructure. DOE does not believe however, that at the levels
specified in this final rule, amended standards would result in
domestic firms relocating significant portions of their domestic
production capacity to other countries. The majority of automatic
commercial ice makers are manufactured in the U.S. and the amended
standards are at levels which are already met by a large portion of the
product models being manufactured. The amended standards can largely be
met using existing capital assets and during interviews, manufacturers
in general indicated they would modify their existing facilities to
comply with amended energy conservation standards.
[[Page 4741]]
6. Need of the Nation To Conserve Energy
An improvement in the energy efficiency of the equipment subject to
this final rule is likely to improve the security of the Nation's
energy system by reducing overall demand for energy. Reduced
electricity demand resulting from energy conservation may also improve
the reliability of the electricity system. As a measure of this reduced
demand, chapter 15 in the final rule TSD presents the estimated
reduction in national generating capacity for the TSLs that DOE
considered in this rulemaking.
Energy savings from new and amended standards for automatic
commercial ice makers could also produce environmental benefits in the
form of reduced emissions of air pollutants and GHGs associated with
electricity production. Table V.46 provides DOE's estimate of
cumulative CO2, NOX, Hg, N2O,
CH4 and SO2 emissions reductions projected to
result from the TSLs considered in this rule. The table includes both
power sector emissions and upstream emissions. The upstream emissions
were calculated using the multipliers discussed in section IV.K. DOE
reports annual emissions reductions for each TSL in chapter 13 of the
final rule TSD.
Table V.46--Summary of Emissions Reduction Estimated for Automatic Commercial Ice Makers TSLs
[Cumulative for equipment purchased in 2018-2047]
----------------------------------------------------------------------------------------------------------------
TSL
----------------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Power Sector and Site Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)...................... 4.68 7.87 10.38 13.25 18.62
NOX (thousand tons)............................ 3.71 6.23 8.22 10.50 14.75
Hg (tons)...................................... 0.01 0.02 0.03 0.04 0.05
N2O (thousand tons)............................ 0.06 0.11 0.14 0.18 0.25
CH4 (thousand tons)............................ 0.44 0.73 0.97 1.24 1.74
SO2 (thousand tons)............................ 4.13 6.95 9.17 11.70 16.45
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)...................... 0.25 0.42 0.56 0.72 1.00
NOX (thousand tons)............................ 3.59 6.03 7.96 10.17 14.29
Hg (tons)...................................... 0.00 0.00 0.00 0.00 0.00
N2O (thousand tons)............................ 0.00 0.00 0.00 0.01 0.01
CH4 (thousand tons)............................ 20.91 35.15 46.40 59.23 83.24
SO2 (thousand tons)............................ 0.04 0.08 0.10 0.13 0.18
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)...................... 4.93 8.29 10.94 13.97 19.63
NOX (thousand tons)............................ 7.30 12.26 16.19 20.67 29.04
Hg (tons)...................................... 0.01 0.02 0.03 0.04 0.05
N2O (thousand tons)............................ 0.06 0.11 0.14 0.18 0.26
CH4 (thousand tons)............................ 21.35 35.89 47.37 60.47 84.97
SO2 (thousand tons)............................ 4.18 7.02 9.27 11.83 16.62
----------------------------------------------------------------------------------------------------------------
As part of the analysis for this final rule, DOE estimated monetary
benefits likely to result from the reduced emissions of CO2
and NOX that were estimated for each of the TSLs considered.
As discussed in section IV.L, 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 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 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 four SCC values for CO2 emissions
reductions in 2015, expressed in 2013$, are $12/ton, $40.5/ton, $62.4/
ton, and $119.0/ton. These values for later years are higher due to
increasing emissions-related costs as the magnitude of projected
climate change is expected to increase.
Table V.47 presents the global value of CO2 emissions
reductions at each TSL. DOE calculated domestic values as a range from
7 percent to 23 percent of the global values, and these results are
presented in chapter 14 of the final rule TSD.
[[Page 4742]]
Table V.47--Global Present Value of CO2 Emissions Reduction for Potential Standards for Automatic Commercial Ice
Makers
----------------------------------------------------------------------------------------------------------------
SCC scenario *
---------------------------------------------------------------
TSL 3% Discount
5% Discount 3% Discount 2.5% Discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
million 2013$
----------------------------------------------------------------------------------------------------------------
Power Sector and Site Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 34.5 154.3 243.8 476.2
2............................................... 57.9 259.4 409.9 800.5
3............................................... 76.4 342.3 541.0 1,056.6
4............................................... 97.6 437.0 690.6 1,348.9
5............................................... 137.1 614.1 970.5 1,895.5
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 1.8 8.2 13.0 25.4
2............................................... 3.0 13.8 21.9 42.7
3............................................... 4.0 18.2 28.8 56.3
4............................................... 5.1 23.3 36.8 71.9
5............................................... 7.2 32.7 51.8 101.0
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 36.3 162.5 256.8 501.6
2............................................... 61.0 273.2 431.7 843.1
3............................................... 80.5 360.6 569.8 1,112.9
4............................................... 102.7 460.3 727.5 1,420.8
5............................................... 144.3 646.8 1,022.3 1,996.5
----------------------------------------------------------------------------------------------------------------
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12, $40.5, $62.4, and $119.0
per metric ton (2013$).
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 rulemaking 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 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 final rule 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 emission reductions
anticipated to result from the new and amended standards for the
automatic commercial ice makers. The dollar-per-ton values that DOE
used are discussed in section IV.L. Table V.48 presents the present
value of cumulative NOX emissions reductions for each TSL
calculated using the average dollar-per-ton values and 7-percent and 3-
percent discount rates.
Table V.48--Present Value of NOX Emissions Reduction for Potential
Standards for Automatic Commercial Ice Makers
------------------------------------------------------------------------
3% 7%
TSL Discount Discount
rate rate
------------------------------------------------------------------------
million 2013$
------------------------------------------------------------------------
Power Sector and Site Emissions *
------------------------------------------------------------------------
1................................................. 5.6 2.9
2................................................. 9.4 4.9
3................................................. 12.4 6.5
4................................................. 15.8 8.2
5................................................. 22.2 11.6
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1................................................. 5.2 2.5
2................................................. 8.7 4.3
3................................................. 11.4 5.6
4................................................. 14.6 7.2
5................................................. 20.5 10.1
------------------------------------------------------------------------
Total Emissions
------------------------------------------------------------------------
1................................................. 10.7 5.4
2................................................. 18.0 9.2
3................................................. 23.8 12.1
4................................................. 30.4 15.4
5................................................. 42.7 21.7
------------------------------------------------------------------------
The NPV of the monetized benefits associated with emission
reductions can be viewed as a complement to the NPV of the customer
savings calculated for each TSL considered in this rulemaking. Table
V.49 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 table correspond to the four
scenarios for the valuation of CO2 emission reductions
presented in section IV.L.
[[Page 4743]]
Table V.49--Automatic Commercial Ice Makers TSLs: Net Present Value of Customer Savings Combined With Net
Present Value of Monetized Benefits From CO2 and NOX Emissions Reductions
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 3% Discount Rate added with:
---------------------------------------------------------------
SCC Value of SCC Value of SCC Value of SCC Value of
TSL $12/metric ton $40.5/metric $62.4/metric $119.0/metric
CO2 * and ton CO2 * and ton CO2 * and ton CO2 * and
medium value medium value medium value medium value
for NOX * for NOX * for NOX * for NOX *
----------------------------------------------------------------------------------------------------------------
billion 2013$
---------------------------------------------------------------
1............................................... 0.436 0.563 0.657 0.902
2............................................... 0.791 1.004 1.162 1.574
3............................................... 1.046 1.326 1.536 2.079
4............................................... 0.955 1.313 1.580 2.273
5............................................... (0.266) 0.237 0.612 1.587
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 7% Discount Rate added with:
---------------------------------------------------------------
TSL SCC Value of SCC Value of SCC Value of SCC Value of
$12/metric ton $40.5/metric $62.4/metric $119.0/metric
CO2 * and ton CO2 * and ton CO2 * and ton CO2 * and
medium value medium value medium value medium value
for NOX * for NOX * for NOX * for NOX *
----------------------------------------------------------------------------------------------------------------
billion 2013$
---------------------------------------------------------------
1............................................... 0.225 0.351 0.445 0.690
2............................................... 0.398 0.611 0.769 1.181
3............................................... 0.523 0.803 1.012 1.555
4............................................... 0.455 0.813 1.080 1.773
5............................................... (0.240) 0.263 0.638 1.613
----------------------------------------------------------------------------------------------------------------
* These label values represent the global SCC in 2015, in 2013$. The present values have been calculated with
scenario-consistent discount rates. For NOX emissions, each case uses the medium value, which corresponds to
$2,684 per ton.
Although adding the value of customer savings to the values of
emission reductions provides a valuable perspective, the following
should be considered. First, the national customer savings are domestic
U.S. customer monetary savings that occur as a result of market
transactions, while the values of emission reductions are based on
estimates of marginal social costs, which, in the case of
CO2, are based on a global value. Second, the assessments of
customer operating cost savings and emission-related benefits are
performed with quite different time frames for analysis. For automatic
commercial ice makers, the present value of national customer savings
is measured for the lifetime of units shipped from 2018 through 2047.
The SCC values, on the other hand, reflect the present value of future
climate-related impacts resulting from the emission of one metric ton
of CO2 in each year. Because of the long residence time of
CO2 in the atmosphere, these impacts continue well beyond
2100.
7. 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. (42 U.S.C. 6295(o)(2)(B)(i)(VII) and
6313(d)(4)) DOE considered LCC impacts on identifiable groups of
customers, such as customers of different business types, who may be
disproportionately affected by any new or amended national energy
conservation standard level. The LCC subgroup impacts are discussed in
section V.B.1.b and in final rule TSD chapter 11. DOE also considered
the reduction in generation capacity that could result from the
imposition of any new or amended national energy conservation standard
level. Electric utility impacts are presented in final rule TSD chapter
15.
C. Conclusions/Proposed Standard
Any new or amended energy conservation standard for any type (or
class) of covered product must be designed to achieve the maximum
improvement in energy efficiency that the Secretary determines is
technologically feasible and economically justified. (42 U.S.C.
6295(o)(2)(A) and 6313(d)(4)) In determining whether a proposed
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 6313(d)(4)) The new or
amended standard must also result in a significant conservation of
energy. (42 U.S.C. 6295(o)(3)(B) and 6313(d)(4))
DOE considered the impacts of potential 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.
To aid the reader in understanding the benefits and/or burdens of
each TSL, tables are presented to summarize the quantitative analytical
results for each TSL, based on the assumptions and methodology
discussed herein. The efficiency levels contained in each TSL are
described in section V.A. In addition to the quantitative results
presented in the tables below, DOE also considers other burdens and
benefits that affect economic justification including the effect of
technological feasibility, manufacturer costs, and impacts on
competition on the economic results presented. Table V.50, Table V.51,
Table V.52 and Table V.53 present a summary of the results of DOE's
quantitative analysis for each TSL. Results in Table
[[Page 4744]]
V.50 through Table V.53 are impacts from equipment purchased in the
period from 2018 through 2047. In addition to the quantitative results
presented in the tables, DOE also considers other burdens and benefits
that affect economic justification of certain customer subgroups that
are disproportionately affected by the proposed standards. Section
V.B.1.b presents the estimated impacts of each TSL for these subgroups.
Table V.50--Summary of Results for Automatic Commercial Ice Makers TSLs: National Impacts *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative National Energy Savings 2018 through 2047
Quads
--------------------------------------------------------------------------------------------------------------------------------------------------------
Undiscounted values................ 0.081................. 0.136................. 0.179................ 0.229................ 0.321.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative National Water Savings 2018 through 2047
billion gallons
--------------------------------------------------------------------------------------------------------------------------------------------------------
Undiscounted values................ 1.0................... 23.0.................. 37.5................. 36.8................. 31.3.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative NPV of Customer Benefits 2018 through 2047
billion 2013$
--------------------------------------------------------------------------------------------------------------------------------------------------------
3% discount rate................... 0.389................. 0.712................. 0.942................ 0.822................ (0.453).
7% discount rate................... 0.183................. 0.328................. 0.430................ 0.337................ (0.406).
--------------------------------------------------------------------------------------------------------------------------------------------------------
Industry Impacts
--------------------------------------------------------------------------------------------------------------------------------------------------------
Change in Industry NPV (2013$ (7.5) to (6.6)........ (11.2) to (9.3)....... (15.1) to (12.1)..... (18.6) to (12.3)..... (30.0) to (11.8).
million).
Change in Industry NPV (%)......... (6.2) to (5.4)........ (9.2) to (7.7)........ (12.5) to (10.0)..... (15.3) to (10.1)..... (24.6) to (9.7).
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative Emissions Reductions 2018 through 2047 **
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (MMt).......................... 4.93.................. 8.29.................. 10.94................ 13.97................ 19.63.
NOX (kt)........................... 7.30.................. 12.26................. 16.19................ 20.67................ 29.04.
Hg (t)............................. 0.01.................. 0.02.................. 0.03................. 0.04................. 0.05.
N2O (kt)........................... 0.06.................. 0.11.................. 0.14................. 0.18................. 0.26.
N2O (kt CO2eq)..................... 17.14................. 28.81................. 38.03................ 48.55................ 68.23.
CH4 (kt)........................... 21.35................. 35.89................. 47.37................ 60.47................ 84.97.
CH4 (kt CO2eq)..................... 597.78................ 1004.79............... 1326.27.............. 1693.16.............. 2379.30.
SO2 (kt)........................... 4.18.................. 7.02.................. 9.27................. 11.83................ 16.62.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Monetary Value of Cumulative Emissions Reductions 2018 through 2047 [dagger]
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (2013$ billion)................ 0.036 to 0.502........ 0.061 to 0.843........ 0.080 to 1.113....... 0.103 to 1.421....... 0.144 to 1.997.
NOX--3% discount rate (2013$ 10.7.................. 18.0.................. 23.8................. 30.4................. 42.7.
million).
NOX--7% discount rate (2013$ 5.4................... 9.2................... 12.1................. 15.4................. 21.7.
million).
--------------------------------------------------------------------------------------------------------------------------------------------------------
Employment Impacts
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Change in Indirect Domestic 104 to 107............ 196 to 204............ 263 to 276........... 315 to 340........... 376 to 464.
Jobs by 2022.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative numbers.
** ``MMt'' stands for million metric tons; ``kt'' stands for kilotons; ``t'' stands for tons. CO2eq is the quantity of CO2 that would have the same
global warming potential (GWP).
[dagger] Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. Economic value of NOX
reductions is based on estimates at $2,684/ton.
Table V.51--Summary of Results for Automatic Commercial Ice Makers TSLs: Mean LCC Savings
[2013$]
----------------------------------------------------------------------------------------------------------------
Standard level
Equipment class -----------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B................................. $175 $175 $214 $214 ($534)
IMH-W-Med-B................................... $308 $308 $308 $165 ($63)
IMH-W-Large-B *............................... NA NA NA NA ($172)
IMH-W-Large-B1................................ NA NA NA NA ($200)
IMH-W-Large-B2................................ NA NA NA NA ($80)
IMH-A-Small-B................................. $136 $72 $77 $77 ($393)
IMH-A-Large-B *............................... $382 $501 $361 $265 $55
IMH-A-Large-B1................................ $439 $580 $407 $294 $45
IMH-A-Large-B2................................ $76 $76 $110 $110 $110
[[Page 4745]]
RCU-Large-B *................................. $748 $748 $748 $418 $144
RCU-Large-B1.................................. $743 $743 $743 $391 $161
RCU-Large-B2.................................. $820 $820 $820 $820 ($109)
SCU-W-Large-B................................. $444 $613 $550 $192 $192
SCU-A-Small-B................................. $110 $161 $281 $230 ($145)
SCU-A-Large-B................................. $163 $400 $439 $71 $71
IMH-A-Small-C................................. $245 $292 $313 $313 ($165)
IMH-A-Large-C................................. $539 $539 $626 $626 $28
RCU-Small-C................................... $498 $448 $505 $505 ($73)
SCU-A-Small-C................................. $224 $278 $290 $290 ($268)
----------------------------------------------------------------------------------------------------------------
* LCC results for IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B are a weighted average of the two sub-equipment
class level typical units shown on the table, using weights provided in TSD chapter 7.
Table V.52--Summary of Results for Automatic Commercial Ice Makers TSLs: Median Payback Period
----------------------------------------------------------------------------------------------------------------
Standard level years
Equipment class ----------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B.................................. 2.5 2.5 2.7 2.7 13.4
IMH-W-Med-B.................................... 2.1 2.1 2.1 5.0 7.6
IMH-W-Large-B*................................. NA NA NA NA 10.6
IMH-W-Large-B1................................. NA NA NA NA 11.1
IMH-W-Large-B2................................. NA NA NA NA 8.9
IMH-A-Small-B.................................. 3.4 4.8 4.7 4.7 11.9
IMH-A-Large-B*................................. 2.2 2.4 2.3 3.9 5.6
IMH-A-Large-B1................................. 1.2 1.5 1.5 3.4 5.4
IMH-A-Large-B2................................. 7.4 7.4 6.9 6.9 6.9
RCU-Large-B*................................... 1.1 1.1 1.1 3.3 5.0
RCU-Large-B1................................... 0.9 0.9 0.9 3.4 4.9
RCU-Large-B2................................... 3.0 3.0 3.0 3.0 7.0
SCU-W-Large-B.................................. 1.1 1.6 1.8 5.1 5.1
SCU-A-Small-B.................................. 2.2 2.4 2.6 3.5 8.9
SCU-A-Large-B.................................. 1.8 1.6 2.1 6.5 6.5
IMH-A-Small-C.................................. 1.5 1.6 1.7 1.7 8.8
IMH-A-Large-C.................................. 0.7 0.7 0.7 0.7 5.9
RCU-Small-C.................................... 0.7 1.2 1.2 1.2 5.8
SCU-A-Small-C.................................. 0.8 1.1 1.5 1.5 11.4
----------------------------------------------------------------------------------------------------------------
* PBP results for IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B are weighted averages of the results for the two
sub-equipment class level typical units, using weights provided in TSD chapter 7.
Table V.53--Summary of Results for Automatic Commercial Ice Maker TSLs: Distribution of Customer LCC Impacts
----------------------------------------------------------------------------------------------------------------
Standard Level percentage of customers (%)
Category ----------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
IMH-W-Small-B
Net Cost (%)............................... 0 0 1 1 96
No Impact (%).............................. 63 63 47 47 0
Net Benefit (%)............................ 37 37 52 52 4
IMH-W-Med-B
Net Cost (%)............................... 0 0 0 28 65
No Impact (%).............................. 44 44 44 24 9
Net Benefit (%)............................ 56 56 56 47 26
IMH-W-Large-B *
Net Cost (%)............................... NA NA NA NA 67
No Impact (%).............................. NA NA NA NA 13
Net Benefit (%)............................ NA NA NA NA 20
IMH-W-Large-B1
Net Cost (%)............................... NA NA NA NA 70
No Impact (%).............................. NA NA NA NA 13
Net Benefit (%)............................ NA NA NA NA 17
[[Page 4746]]
IMH-W-Large-B2
Net Cost (%)............................... NA NA NA NA 59
No Impact (%).............................. NA NA NA NA 13
Net Benefit (%)............................ NA NA NA NA 29
IMH-A-Small-B
Net Cost (%)............................... 1 21 21 21 95
No Impact (%).............................. 76 47 0 0 0
Net Benefit (%)............................ 22 32 79 79 5
IMH-A-Large-B *
Net Cost (%)............................... 1 1 2 31 53
No Impact (%).............................. 69 45 12 12 10
Net Benefit (%)............................ 30 53 86 57 37
IMH-A-Large-B1
Net Cost (%)............................... 0 0 0 35 61
No Impact (%).............................. 66 38 3 3 0
Net Benefit (%)............................ 34 62 97 63 39
IMH-A-Large-B2
Net Cost (%)............................... 9 9 10 10 10
No Impact (%).............................. 83 83 61 61 61
Net Benefit (%)............................ 8 8 29 29 29
RCU-Large-B *
Net Cost (%)............................... 0 0 0 23 55
No Impact (%).............................. 56 56 56 22 2
Net Benefit (%)............................ 44 44 44 55 42
RCU-Large-B1
Net Cost (%)............................... 0 0 0 25 55
No Impact (%).............................. 56 56 56 20 1
Net Benefit (%)............................ 44 44 44 55 44
RCU-Large-B2
Net Cost (%)............................... 1 1 1 1 57
No Impact (%).............................. 56 56 56 56 20
Net Benefit (%)............................ 43 43 43 43 23
SCU-W-Large-B
Net Cost (%)............................... 0 0 0 44 44
No Impact (%).............................. 28 28 5 0 0
Net Benefit (%)............................ 72 72 94 56 56
SCU-A-Small-B
Net Cost (%)............................... 0 1 1 16 77
No Impact (%).............................. 48 20 12 0 0
Net Benefit (%)............................ 52 79 87 84 23
SCU-A-Large-B
Net Cost (%)............................... 0 0 0 54 54
No Impact (%).............................. 37 1 1 0 0
Net Benefit (%)............................ 63 99 99 46 46
IMH-A-Small-C
Net Cost (%)............................... 0 0 0 0 68
No Impact (%).............................. 69 58 39 39 14
Net Benefit (%)............................ 31 42 61 61 18
IMH-A-Large-C
Net Cost (%)............................... 0 0 0 0 54
No Impact (%).............................. 57 57 35 35 9
Net Benefit (%)............................ 43 43 65 65 37
RCU-Small-C
Net Cost (%)............................... 0 0 0 0 64
No Impact (%).............................. 72 44 11 11 6
Net Benefit (%)............................ 28 55 89 89 31
SCU-A-Small-C
Net Cost (%)............................... 0 0 1 1 86
No Impact (%).............................. 56 47 32 32 0
Net Benefit (%)............................ 44 53 67 67 14
Average of Equipment Types **
Net Cost (%)............................... 1 7 6 20 75
No Impact (%).............................. 62 40 16 12 3
Net Benefit (%)............................ 37 53 77 68 22
----------------------------------------------------------------------------------------------------------------
* LCC results for IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B are a weighted average of the two sub-equipment
class level typical units shown on the table.
** Average of equipment types created by weighting the class results by 2018 shipment estimates.
[[Page 4747]]
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 explain why consumers appear to undervalue
energy efficiency improvements. 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 benefits; (3) a lack of sufficient savings to warrant
delaying or altering purchases (e.g., an inefficient ventilation fan in
a new building or the delayed replacement of a water pump); (4)
excessive focus on the short term, in the form of inconsistent
weighting 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,
consumers may trade off these types of investments at a higher-than-
expected rate between current consumption and uncertain future energy
cost savings. This undervaluation suggests that regulation that
promotes energy efficiency can produce significant net private gains
(as well as producing social gains by, for example, reducing
pollution).
While DOE is not prepared at present to provide a fuller
quantifiable framework for estimating the benefits and costs of changes
in consumer purchase decisions due to an amended energy conservation
standard, 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 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.\74\ DOE welcomes comments on how to more fully assess the
potential impact of energy conservation standards on consumer choice
and methods to quantify this impact in its regulatory analysis.
---------------------------------------------------------------------------
\74\ Sanstad, A. Notes on the Economics of Household Energy
Consumption and Technology Choice. 2010. Lawrence Berkeley National
Laboratory, Berkeley, CA. www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf
---------------------------------------------------------------------------
TSL 5 corresponds to the max-tech level for all the equipment
classes and offers the potential for the highest cumulative energy
savings through the analysis period from 2018 to 2047. The estimated
energy savings from TSL 5 is 0.321 quads of energy. Because one energy-
saving design option reduces potable water usage, potential savings are
estimated to be 31 billion gallons, although such savings should not be
construed to be the result of a potable water standard. DOE projects a
negative NPV for customers valued at $0.406 billion at a 7-percent
discount rate. Estimated emissions reductions are 19.6 MMt of
CO2, up to 29.0 kt of NOX and 0.05 tons of Hg.
The CO2 emissions have a value of up to $2.0 billion and the
NOX emissions have a value of $21.7 million at a 7-percent
discount rate.
For TSL 5, the mean LCC savings for five equipment classes are
positive, implying a decrease in LCC, with the decrease ranging from
$28 for the IMH-A-Large-C equipment class to $192 for the SCU-W-Large-B
equipment class.\75\ The results shown on Table V.53 indicates a large
fraction of customers would experience net LCC increases (i.e., LCC
costs rather than savings) from adoption of TSL 5, with 44 to 96
percent of customers experiencing net LCC increases. As shown on Table
V.52, customers would experience payback periods of 5 years or longer
in all equipment classes, and in many cases customers would experience
payback periods exceeding the estimated 8.5 year equipment lifetime.
---------------------------------------------------------------------------
\75\ For this section of the final rule, the discussion is
limited to results for full equipment classes. Thus, for the large
equipment classes for which DOE analyzed 2 typical unit sizes, this
discussion focuses on the weighted average or totals of the two
typical units.
---------------------------------------------------------------------------
At TSL 5, the projected change in INPV ranges from a decrease of
$30.0 million to a decrease of $11.8 million, depending on the chosen
manufacturer markup scenario. The upper bound is considered optimistic
by industry because it assumes manufacturers could pass on all
compliance costs as price increases to their customers. DOE recognizes
the risk of negative impacts if manufacturers' expectations concerning
reduced profit margins are realized. If the lower bound of the range of
impacts is reached, TSL 5 could result in a net loss of up to 24.6
percent in INPV for the ACIM industry.
DOE estimates that approximately 84 percent of all batch commercial
ice makers and 78 percent of all continuous commercial ice makers on
the market will require redesign to meet standards at TSL 5. DOE
expects industry conversion costs of $44.1 million. Also of concern,
for five equipment classes, there is only 1 manufacturer with products
that could currently meet this standard.
After carefully considering the analysis results and weighing the
benefits and burdens of TSL 5, DOE finds that at TSL 5, the benefits to
the nation in the form of energy savings and emissions reductions are
outweighed by a decrease of $0.406 billion in customer NPV and a
decrease of up to 24.6 percent in INPV. Additionally, the majority of
individual customers purchasing automatic commercial ice makers built
to TSL 5 standards experience negative life-cycle cost savings, with
over 90 percent of customers of 2 equipment classes experiencing
negative life-cycle cost savings. After weighing the burdens of TSL 5
against the benefits, DOE finds TSL 5 not to be economically justified.
DOE does not propose to adopt TSL 5 in this rulemaking.
TSL 4, the next highest efficiency level, corresponds to the
highest efficiency level with a positive NPV at a 7-percent discount
rate for all equipment classes. The estimated energy savings from 2018
to 2047 are 0.229 quads of energy--an amount DOE deems significant.
Because one energy-saving design option reduces potable water usage,
potential water savings are estimated to be 37 billion gallons,
although such savings should not be construed to be the result of a
potable water standard. At TSL 4, DOE projects an increase in customer
NPV of $0.337 billion (2013$) at a 7-percent discount rate; estimated
emissions reductions of 14.0 MMt of CO2, 20.7 kt of
NOx, and 0.04 tons of Hg. The monetary value for
CO2 was estimated to be up to $1.4 billion. The monetary
value for NOX was estimated to be $15.4 million at a 7-
percent discount rate.
At TSL 4, the mean LCC savings are positive for all equipment
classes. As shown on Table V.51, mean LCC savings vary from $71 for
SCU-A-Large-B to $626 for IMH-A-Large-C, which implies that, on
average, customers will experience an LCC benefit. As shown on Table
V.53, for 7 of the 13 classes, some fraction of the customers will
experience net costs, while for 5 classes, 1 percent or less will
experience net costs. Customers in 3 classes would experience net LCC
costs of 30 percent or more, with the percentage ranging up to 54
percent for one equipment class. Median payback periods range from 0.7
years up to 6.5 years.
At TSL 4, the projected change in INPV ranges from a decrease of
$18.6 million to a decrease of $12.3 million. If the lower bound of the
range of
[[Page 4748]]
impacts is reached, TSL 4 could result in a net loss of up to 15.3
percent in INPV for manufacturers.
DOE estimates that approximately 66 percent of all batch commercial
ice makers and 55 percent of all continuous commercial ice makers on
the market will require redesign to meet standards at TSL 4. At this
TSL DOE expects industry conversion costs to total $30.0 million.
Additionally, for four equipment classes, there is only 1 manufacturer
with products that currently meet the standard.
After carefully considering the analysis results and weighing the
benefits and burdens of TSL 4, DOE finds that at TSL 4, the benefits to
the nation in the form of energy savings and emissions reductions plus
an increase of $0.337 billion in customer NPV are outweighed by a
decrease of up to 15.3 percent in INPV and issues regarding
availability of product from multiple manufacturers in some product
classes. After weighing the burdens of TSL 4 against the benefits, DOE
finds TSL 4 not to be economically justified. DOE does not propose to
adopt TSL 4 in this rule.
At TSL 3, the next highest efficiency level, estimated energy
savings from 2018 through 2047 are 0.179 quads of primary energy--an
amount DOE considers significant. Because one energy-saving design
option reduces potable water usage, potential water savings are
estimated to be 37 billion gallons, although such savings should not be
construed to be the result of a potable water standard. TSL 3 was
defined as the set of efficiencies with the highest NPV for each
analyzed equipment class. At TSL 3, DOE projects an increase in
customer NPV of $0.430 billion at a 7-percent discount rate, and an
increase of $0.942 billion at a 3-percent discount rate. Estimated
emissions reductions are 10.9 MMt of CO2, up to 16.2 kt of
NOX and 0.03 tons of Hg at TSL 3. The monetary value of the
CO2 emissions reductions was estimated to be up to $1.1
billion at TSL 3. The monetary value of the NOX emission
reductions was estimated to be $12.1 million at a 7-percent discount
rate.
At TSL 3, nearly all customers for all equipment classes are shown
to experience positive LCC savings. As shown on Table V.53 Table V.53,
the percent of customers experiencing a net cost is 2 percent or less
in 12 of 13 classes, with IMH-A-Small-B being the exception with 21
percent of customers experiencing a net cost. The payback period for
IMH-A-Small-B is 4.7 years, while for all other equipment classes the
median payback periods are 3 years or less. LCC savings range from $77
for IMH-A-Small-B to $748 for RCU-Large-B.
At TSL 3, the projected change in INPV ranges from a decrease of
$15.1 million to a decrease of $12.1 million. If the lower bound of the
range of impacts is reached, TSL 3 could result in a net loss of up to
12.5 percent in INPV for manufacturers.
DOE estimates that approximately 51 percent of all batch commercial
ice makers and 55 percent of all continuous commercial ice makers on
the market will require redesign to meet standards at TSL 3. At TSL 3,
DOE expects industry conversion costs to total $25.1 million. There are
multiple manufacturers with product that could meet this standard at
all analyzed equipment classes.
At TSL 3, the monetized CO2 emissions reduction values
range from $0.080 to $1.113 billion. The mid-range value used by DOE to
calculate total net benefits is the monetized CO2 emissions
reduction at $40.5 per ton in 2013$, which for TSL 3, is $0.361
billion. The monetized NOX emissions reductions calculated
at an intermediate value of $2,684 per ton in 2013$ are $12.1 million
at a 7-percent discount rate and $23.8 million at a 3-percent rate.
These monetized emissions reduction values were added to the customer
NPV at 3-percent and 7-percent discount rates to obtain values of
$1.326 billion and 0.803 billion, respectively, at TSL 3.
Approximately 94 percent of customers are expected to experience
net benefits (or no impact) from equipment built to TSL 3 levels. The
payback periods for TSL 3 are expected to be 3 years or less for all
but the IMH-A-Small-B.
After carefully considering the analysis results and weighing the
benefits and burdens of TSL 3, DOE concludes that setting the standards
for automatic commercial ice makers at TSL 3 will offer the maximum
improvement in energy efficiency that is technologically feasible and
economically justified and will result in significant energy savings.
Therefore, DOE today is adopting standards at TSL 3 for automatic
commercial ice makers. TSL 3 is technologically feasible because the
technologies required to achieve these levels already exist in the
current market and are available from multiple manufacturers. TSL 3 is
economically justified because the benefits to the nation in the form
of energy savings, customer NPV at 3 percent and at 7 percent, and
emissions reductions outweigh the costs associated with reduced INPV
and potential effects of reduced manufacturing capacity.
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 these standards address are as follows:
(1) Insufficient information and the high costs of gathering and
analyzing relevant information leads some customers to miss
opportunities to make cost-effective investments in energy efficiency.
(2) In some cases the benefits of more efficient equipment are not
realized due to misaligned incentives between purchasers and users. An
example of such a case is when the equipment purchase decision is made
by a building contractor or building owner who does not pay the energy
costs.
(3) There are external benefits resulting from improved energy
efficiency of automatic commercial ice makers that are not captured by
the users of such equipment. These benefits include externalities
related to public health, environmental protection and national
security that are not reflected in energy prices, such as reduced
emissions of air pollutants and greenhouse gases that impact human
health and global warming.
In addition, DOE has determined that today's regulatory action is a
``significant regulatory action'' under Executive Order 12866. DOE
presented to the Office of Information and Regulatory Affairs (OIRA) in
the OMB for review the draft rule and other documents prepared for this
rulemaking, including a regulatory impact analysis (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 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
[[Page 4749]]
by Executive Order 13563 to: (1) Propose or adopt a regulation only
upon a reasoned determination that its benefits justify its costs
(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 this final rule 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 final regulatory flexibility analysis (FRFA) 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).
For manufacturers of automatic commercial ice makers, 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
by 65 FR 53533, 53544 (September 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/sites/default/files/files/Size_Standards_Table.pdf. Commercial refrigeration equipment
manufacturing is classified under NAICS 333415, ``Air-Conditioning and
Warm Air Heating Equipment and Commercial and Industrial Refrigeration
Equipment Manufacturing,'' which includes ice-making machinery
manufacturing. The SBA sets a threshold of 750 employees or less for an
entity to be considered as a small business for this category. Based on
this threshold, DOE present the following FRFA analysis:
1. Description and Estimated Number of Small Entities Regulated
During its market survey, DOE used available public information to
identify potential small manufacturers. DOE's research involved
industry trade association membership directories (including AHRI),
public databases (e.g., AHRI Directory,\76\ the SBA Database \77\),
individual company Web sites, and market research tools (e.g., Dunn and
Bradstreet reports \78\ and Hoovers reports \79\) to create a list of
companies that manufacture or sell products 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 DOE public meetings. DOE reviewed 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 covered automatic commercial ice makers. DOE screened out companies
that do not offer products covered by this rulemaking, do not meet the
definition of a ``small business,'' or are foreign owned.
---------------------------------------------------------------------------
\76\ ``AHRI Certification Directory.'' AHRI Certification
Directory. AHRI. (Available at: https://www.ahridirectory.org/ahridirectory/pages/home.aspx) (Last accessed October 10, 2011). See
www.ahridirectory.org/ahriDirectory/pages/home.aspx.
\77\ ``Dynamic Small Business Search.'' SBA. (Available at: See
https://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm) (Last accessed October
12, 2011).
\78\ ``D&B[verbar]Business Information[verbar]Get Credit
Reports[verbar]888 480-6007.''. Dun & Bradstreet (Available at:
www.dnb.com) (Last accessed October 10, 2011). See www.dnb.com/.
\79\ ``Hoovers[verbar]Company Information[verbar]Industry
Information[verbar]Lists.'' D&B (2013) (Available at: See https://www.hoovers.com/) (Last accessed December 12, 2012).
---------------------------------------------------------------------------
DOE identified 16 manufacturers of automatic commercial ice makers.
Seven of those are small businesses manufacturers operating in the
United States. DOE contacted each of these companies, but only one
accepted the invitation to participate in a confidential manufacturer
impact analysis interview with DOE contractors.
In establishing today's standard levels, DOE has carefully
considered the impacts on small manufacturers when establishing the
standards for this industry. DOE's review of the industry suggests that
the five of the seven small manufacturers identified specialize in
industrial higher capacity ``tube'', ``flake'' or ``cracked'' ice
machines. Industry literature indicates that these types of ice makers
are typically designed to produce 2,000-40,000 lb/day of ice, with some
designs going as low as 1,000 lb/day. Only at the lowest end of the
tube, flake, and cracked ice platforms, typically 2,000 and 4,000 lb/
day, do these manufacturers have products within the scope of this
rulemaking. Based on product listings from manufacturer Web sites, DOE
estimates that approximately 15% of the models produced by these five
manufacturers are covered product under today's rule.
Of the remaining two small manufacturers, one exclusively produces
continuous ice makers, and one exclusively produces gourmet, large
cube, ice makers. Based on publically available information, DOE
believes that approximately two-thirds of all the models made by the
manufacturer of continuous machines already meet the standard,
positioning it well compared to an industry-at-large compliance rate of
approximately 50 percent.
DOE estimates that 10 percent of the models made by the
manufacturer of gourmet, large cube machines already meet the standard.
The low percentage indicates that this manufacturer may be
disproportionately affected by the selected standard level, but as
discussed in section IV.B.1.f, DOE does not have nor did it receive in
response to requests for comments sufficient specific information to
evaluate whether larger
[[Page 4750]]
ice has specific consumer utility, nor to allow separate evaluation for
such equipment of costs and benefits associated with achieving the
efficiency levels considered in the rulemaking. In the absence of
information, DOE cannot conclude that this type of ice has unique
consumer utility justifying consideration of separate equipment
classes. DOE notes that manufacturers of this equipment have the option
seeking exception relief pursuant to 41 U.S.C. 7194 from DOE's Office
of Hearings and Appeals.
Based on a 2008 study by Koeller & Company,\80\ DOE understands
that the ACIM market is dominated by four manufacturers who produce
approximately 90 percent of the automatic commercial ice makers for
sale in the United States. The four major manufacturers with the
largest market share are Manitowoc, Scotsman, Hoshizaki, and Ice-O-
Matic. The remaining 12 large and small manufacturers account for ten
percent of domestic sales.
---------------------------------------------------------------------------
\80\ Koeller, John, P.E., and Herman Hoffman, P.E. A Report on
Potential Best Management Practices. Rep. The California Urban Water
Conservation Council, n.d. Web. 19 May 2014.
---------------------------------------------------------------------------
DOE considered comments that all manufacturers and stakeholders
made regarding the engineering analysis and made changes to the
analysis, which are described in some detail in section III.IV.D. These
changes reduced the highest efficiency levels determined to be possible
using the design options considered in the analyses and increased the
estimated costs associated with attaining most efficiency levels.
Consequently, the most cost-effective efficiency levels for the final
rule analysis were lower than for the NOPR. This applied to specific
equipment classes associated with the products sold by some of these
small businesses, for example continuous ice makers, IMH batch ice
makers, and RCU batch ice makers. The energy standards were
consequently set at efficiency levels that will be less burdensome to
attain for the affected small businesses.
2. Description and Estimate of Compliance Requirements
For the purposes of analysis, DOE assumes that the seven small
domestic manufacturers of automatic commercial ice makers identified
account for approximately 5 percent of industry shipments. While small
business manufacturers of automatic commercial ice makers have small
overall market share, some hold substantial market share in specific
equipment classes. Several of these smaller firms specialize in
producing industrial ice machines and the covered equipment they
manufacture are extensions of industrial product lines that fall within
the range of capacity covered by this rule. Others serve niche markets.
Most have substantial portions of their business derived from equipment
outside the scope of this rulemaking, as described further below, but
are still considered small businesses based on the SBA limits for
number of employees.
At the new and amended levels, small business manufacturers of
automatic commercial ice makers are expected to face negative impacts
on INPV. For the portions of their business covered by the standard,
the impacts are approximately four times as severe as those felt by the
industry at large: a loss of 49.8 percent of INPV for small businesses
alone as compared to a loss of 12.5 percent for the industry at large.
Where conversion costs are driven by the number of platforms requiring
redesign at a particular standard level, small business manufacturers
may be disproportionately affected. Product conversion costs including
the investments made to redesign existing equipment to meet new or
amended standards or to develop entirely new compliant equipment, as
well as industry certification costs, do not scale with sales volume.
As small manufacturers' investments are spread over a much lower volume
of shipments, recovering the cost of upfront investments is
proportionately more difficult. Additionally, smaller manufacturers
typically do not have the same technical resources and testing capacity
as larger competitors.
The product conversion investments required to comply are estimated
to be over 10 times larger than the typical R&D expenditures for small
businesses, whereas the industry as a whole is estimated to incur 4
times larger than typical R&D expenditures. Where the covered equipment
from several small manufacturers are adaptations of larger platforms
with capacities above the 4,000 lb ice/24 hour threshold, it may not
prove economical for them to invest in redesigning such a small portion
of their product offering to meet standards.
In confidential interviews, manufacturers indicated that many
design options evaluated in the engineering analysis (e.g., higher
efficiency motors and compressors) would require them to purchase more
expensive components. In many industries, small manufacturers typically
pay higher prices for components due to smaller purchasing volumes
while their large competitors receive volume discounts. However, this
effect is diminished for the automatic commercial ice maker
manufacturing industry for two distinct reasons. One reason relates to
the fact that the automatic commercial ice maker industry as a whole is
a low volume industry. In confidential interviews, manufacturers
indicated that they have little influence over their suppliers,
suggesting the volume of their component orders is similarly
insufficient to receive substantial discounts. The second reason
relates to the fact that, for most small businesses, the equipment
covered by this rulemaking represents only a fraction of overall
business. Where small businesses are ordering similar components for
non-covered equipment, their purchase volumes may not be as low as is
indicated by the total unit shipments for small businesses. For these
reasons, it is expected that any volume discount for components enjoyed
by large manufacturers would not be substantially different from the
prices paid by small business manufacturers.
To estimate how small manufacturers would be potentially impacted,
DOE developed specific small business inputs and scaling factors for
the GRIM. These inputs were scaled from those used in the whole
industry GRIM using information about the product portfolios of small
businesses and the estimated market share of these businesses in each
equipment class. DOE used this information in the GRIM to estimate the
annual revenue, EBIT, R&D expense, and capital expenditures for a
typical small manufacturer and to model the impact on INPV associated
with the production of covered product; noting that for five of the
seven small businesses in this analysis, only 15% of their product
portfolio, which was based on review capacity ranges of the product
offerings listed on these manufacturers' Web sites, is covered product
under today's rule DOE then compared these impacts to those modeled for
the industry at large, and found that small manufactures could lose up
to 49.8 percent of the INPV associated with the production of covered
product; as compared to a reduction in small business INPV of 78.8
percent at the NOPR stage. Table VI.1 and Table VI.2 summarize the
impacts on small business INPV at each TSL, and Table VI.3 and Table
VI.4 summarize the changes in results at TSL 3, between the NOPR and
Final Rule analysis.
[[Page 4751]]
Table VI.1--Comparison of Small Business Manufacturers of Automatic Commercial Ice Maker INPV * to That of the
Industry at Large by TSL Under the Preservation of Gross Margin Markup Scenario **
----------------------------------------------------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
Industry at Large--Impact on INPV (%).......... (6.2) (9.2) (12.5) (15.3) (24.6)
Small Businesses--Impact on INPV (%)........... (18.3) (34.2) (48.8) (51.5) (57.2)
----------------------------------------------------------------------------------------------------------------
* Small business manufacturer INPV represents only the INPV associated with the production and sale of covered
product. Many small business manufacturers produce products not covered by this rule.
** Values in parentheses are negative numbers.
Table VI.2--Comparison of Small Business Manufacturers of Automatic Commercial Ice Maker INPV * to That of the
Industry at Large by TSL Under the Preservation of EBIT Markup Scenario **
----------------------------------------------------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
Industry at Large--Impact on INPV (%).......... (5.4) (7.7) (10.0) (10.1) (9.7)
Small Businesses--Impact on INPV (%)........... (19.1) (35.1) (49.8) (52.6) (68.4)
----------------------------------------------------------------------------------------------------------------
* Small business manufacturer INPV represents only the INPV associated with the production and sale of covered
product. Many small business manufacturers produce products not covered by this rule.
** Values in parentheses are negative numbers.
Table VI.3--Comparison of Small Business Manufacturers of Automatic
Commercial Ice Maker INPV * to That of the Industry at Large Under the
Preservation of Gross Margin Markup Scenario **; NOPR vs. Final Rule
------------------------------------------------------------------------
Final
NOPR TSL rule TSL
3 3
------------------------------------------------------------------------
Industry at Large--Impact on INPV (%)............. (20.5) (12.5)
Small Businesses--Impact on INPV (%).............. (76.6) (48.8)
------------------------------------------------------------------------
* Small business manufacturer INPV represents only the INPV associated
with the production and sale of covered product. Many small business
manufacturers produce products not covered by this rule.
** Values in parentheses are negative numbers.
Table VI.4--Comparison of Small Business Manufacturers of Automatic
Commercial Ice Maker INPV * to That of the Industry at Large Under the
Preservation of EBIT Markup Scenario **; NOPR vs Final Rule
------------------------------------------------------------------------
Final
NOPR TSL rule TSL
3 3
------------------------------------------------------------------------
Industry at Large--Impact on INPV (%)............. (23.5) (10.0)
Small Businesses--Impact on INPV (%).............. (78.6) (49.8)
------------------------------------------------------------------------
* Small business manufacturer INPV represents only the INPV associated
with the production and sale of covered product. Many small business
manufacturers produce products not covered by this rule.
** Values in parentheses are negative numbers.
3. 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 adopted today.
4. Significant Alternatives to the Rule
The discussion above analyzes impacts on small businesses that
would result from DOE's new and amended standards. In addition to the
other TSLs being considered, the rulemaking TSD includes a regulatory
impact analysis (RIA). For automatic commercial ice making equipment,
the RIA discusses the following policy alternatives: (1) No change in
standard; (2) consumer rebates; (3) consumer tax credits; and (4)
manufacturer tax credits; (5) voluntary energy efficiency targets; (6)
bulk government purchases; and (7) extending the compliance date for
small entities. While these alternatives may mitigate to some varying
extent the economic impacts on small entities compared to the
standards, DOE did not consider these alternatives further because they
are either not feasible to implement without authority and funding from
Congress, or are expected to result in energy savings that are much
smaller (ranging from 39 percent to less than 53 percent) than those
that will be achieved by the new and amended standard levels. In
reviewing alternatives DOE analyzed a case in which the voluntary
programs targeted efficiencies corresponding to final rule TSL 3. DOE
also examined standards at lower efficiency levels, TSL 2 and TSL 1.
TSL 2 achieves 25 percent lower savings than TSL 3 and TSL 1 achieves
less than half the savings of TSL 3. (See Table V.50 for the estimated
impacts of standards at lower TSLs.) Voluntary programs at these levels
achieve only a fraction of the savings achieved by standards and would
provide even lower savings benefits. As shown in Table VI.1 through
Table VI.4, the changes to the efficiency levels comprising TSL 3
between the NOPR and final rule resulted in a substantial reduction in
the impacts faced by small businesses. To achieve further substantial
reductions in small business impacts would force the standard down to
TSL 1 levels, at the expense of substantial energy savings and NPV
benefits, which would be inconsistent with DOE's statutory mandate to
maximize the improvement in energy efficiency that the Secretary
determines is technologically feasible and economically justified. DOE
believes that establishing standards at TSL 3 provides the optimum
balance between energy savings benefits and impacts on small
businesses. Accordingly, DOE is declining to adopt any of these
alternatives and is adopting the standards set forth in this
rulemaking. (See chapter 17 of the TSD for further detail on the policy
alternatives DOE considered.)
Additional compliance flexibilities may be available through other
means. For example, individual manufacturers may petition for a waiver
of the applicable test procedure. Further, EPCA provides that a
manufacturer whose annual gross revenue from all of its operations does
not exceed $8,000,000 may apply for an exemption from all or part of an
energy conservation standard for a period not longer than 24 months
after the effective date of a final rule establishing the standard.
Additionally, Section 504 of the Department of Energy Organization Act,
42 U.S.C. 7194, provides authority for the Secretary to adjust a rule
issued under EPCA in order to prevent ``special
[[Page 4752]]
hardship, inequity, or unfair distribution of burdens'' that may be
imposed on that manufacturer as a result of such rule. Manufacturers
should refer to 10 CFR part 430, subpart E, and part 1003 for
additional details.
5. Response to Small Business Comments and Comments of the Office of
Advocacy
The Chief Counsel of the SBA Office of Advocacy submitted comments
regarding the impact of the proposed standards on small businesses and
recommended that DOE use its discretion to adopt an alternative to the
proposed standard that is achievable for small manufacturers. This
letter is posted to the docket at https://www.regulations.gov/#!docketDetail;D=EERE-2010-BT-STD-0037.
DOE has taken several steps to minimize the impact of the new and
amended standards on small businesses. The comments received in
response to the proposed standards led DOE to hold an additional public
meeting and allow stakeholders more time to submit additional
information to DOE's consultant pursuant to non-disclosure agreements
regarding efficiency gains and costs of potential design options. DOE
reviewed additional market data, including published ratings of
available ice makers, to recalibrate its engineering analysis, and as a
result, revised the proposed TSL levels. DOE issued a NODA to announce
the availability of the revised analysis and sought comment from
stakeholders. In this final rule, DOE is adopting the TSL 3 presented
in the NODA. As discussed previously, the changes to the efficiency
levels comprising TSL 3 between the NOPR and final rule resulted in a
standard that is less burdensome for small businesses.
In addition, in reviewing all available data sources received in
response to the proposed standards, DOE found that the IMH-W continuous
class ice makers consume more condenser water than DOE assumed at the
NOPR stage. In setting the standard for the continuous class condenser
water use, DOE intended that the baseline reflect the existing market
for continuous type units. Based on this new data, the standard for
condenser water use is set at 10 percent below the baseline condenser
water use level for IMH-W batch ice makers, rather than 20 percent, as
was proposed in the NOPR. As a result, all IMH-W continuous class
models produced by small business manufacturers are compliant with the
condenser water use standard for this class.
DOE notes that while any one regulation may not impose a
significant burden on small business manufacturers, the combined
effects of recent or impending regulations may have consequences for
some small business manufacturers. In researching the product offerings
of small business manufacturers covered by this rulemaking, DOE did not
identify any that also manufacture products impacted by the recently
issued energy conservation standards for commercial refrigeration
equipment or walk-in coolers and freezers. DOE will continue to work
with industry to ensure that cumulative impacts from its regulations
are not unduly burdensome.
The SBA Office of Advocacy also recommended that DOE adopt a lower
TSL for small businesses because the level proposed in the NOPR would
have a disproportionately negative impact on small business
manufacturers. As discussed previously, the changes to the analysis
between the NOPR and final rule resulted in different TSLs. As such,
the efficiency levels comprising TSL 3 as set forth in this final rule
result in a substantial reduction in the impacts faced by small
business manufacturers, as compared to those proposed in the NOPR. DOE
also examined standards at lower efficiency levels, TSL 2 and TSL 1.
TSL 2 achieves 25 percent lower savings than TSL 3 and TSL 1 achieves
less than half the savings of TSL 3. (See Table V.50 for the estimated
impacts of standards at lower TSLs.) The impacts on small manufacturers
were also considered in comparison to the impacts on larger
manufacturers to ensure that small business would remain competitive in
the market. Because they compete mostly in market niches not covered by
these standards, these rules apply to about 15 percent of these
companies product in comparison to 100 percent for large business. In
addition, for one of the remaining two manufacturers, DOE estimates
that approximately two-thirds of its models already meet the energy
efficiency standard and 100 percent of its models meet the condenser
water standard. In comparison, a typical large manufacturer will need
to redesign half of their products to meet the new and amended
standards. Pursuant to DOE's statutory mandate, any new or amended
standard must maximize the improvement in energy efficiency that the
Secretary determines is both technologically feasible and economically
justified. DOE determined that TSL 3 will achieve significant energy
savings and is economically justified, and therefore is adopting TSL 3
in this final rule. DOE believes that establishing standards at TSL 3
provides the optimum balance between energy savings benefits and
impacts on small businesses.
Finally, the SBA Office of Advocacy recommended that DOE consider
extending the compliance date for small entities. DOE notes that EPCA
requires that the amended standards established in this rulemaking must
apply to equipment that is manufactured on or after 3 years after the
final rule is published in the Federal Register 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. 6313(d)(3)(C)) As described previously, the standard levels
set forth in this final rule are less stringent relative to those
proposed in the NOPR, and fewer ice maker models will require redesign
to meet the new standard. Therefore, DOE has determined that the 3-year
period is adequate and is not extending the compliance date for small
business manufacturers.
C. Review Under the Paperwork Reduction Act
Manufacturers of automatic commercial ice makers 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 automatic commercial
ice makers, 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 commercial refrigeration equipment. (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
[[Page 4753]]
that collection of information displays a currently valid OMB Control
Number.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act (NEPA) of 1969,
DOE has determined that this final rule fits within the category of
actions included in Categorical Exclusion (CX) B5.1 and otherwise meets
the requirements for application of a CX. See 10 CFR part 1021, App. B,
B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). This final rule fits
within the category of actions because it is a rulemaking that
establishes energy conservation standards for consumer products or
industrial equipment, and for which none of the exceptions identified
in CX B5.1(b) apply. Therefore, DOE has made a CX determination for
this rulemaking, and DOE does not need to prepare an Environmental
Assessment or Environmental Impact Statement for this rule. DOE's CX
determination for this final rule is available at https://energy.gov/nepa/categorical-exclusion-determinations-b51.
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 this final rule.
States can petition DOE for exemption from such preemption to the
extent, and based on criteria, set forth in EPCA. (42 U.S.C. 6297) 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 (February 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 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 final 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 an amended 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 ``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.
DOE has concluded that this final rule would likely require
expenditures of $100 million or more on the private sector. Such
expenditures may include: (1) Investment in research and development
and in capital expenditures by automatic commercial ice maker
manufacturers in the years between the final rule and the compliance
date for the new standards, and (2) incremental additional expenditures
by consumers to purchase higher-efficiency automatic commercial ice
maker, 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 the final 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 notice of final rulemaking and
the ``Regulatory Impact Analysis'' section of the TSD for this final
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 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. 6295(o),
6313(d), this final rule would establish energy conservation standards
for automatic commercial ice maker 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'' chapter 17 of the TSD for today's final
rule.
[[Page 4754]]
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 (March 18, 1988), that this regulation would not
result in any takings that might require compensation under the Fifth
Amendment to the U.S. Constitution.
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 (February
22, 2002), and DOE's guidelines were published at 67 FR 62446 (October
7, 2002). DOE has reviewed this final rule 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 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 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 concluded that this regulatory action, which sets forth
energy conservation standards for automatic commercial ice makers, is
not a significant energy action because the new and amended 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 final 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 2664 (January
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 at 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 and/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.
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will report to Congress on the
promulgation of this rule prior to its effective date. The report will
state that it has been determined that the rule is a ``major rule'' as
defined by 5 U.S.C. 804(2).
VII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of today's final
rule.
List of Subjects in 10 CFR Part 431
Administrative practice and procedure, Confidential business
information, Energy conservation, Reporting and recordkeeping
requirements.
Issued in Washington, DC, on December 31, 2014.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Energy Efficiency and
Renewable Energy.
For the reasons set forth in the preamble, DOE amends 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
0
1. The authority citation for part 431 continues to read as follows:
Authority: 42 U.S.C. 6291-6317.
0
2. Section 431.136 is revised to read as follows:
Sec. 431.136 Energy conservation standards and their effective dates.
(a) All basic models of commercial ice makers must be tested for
performance using the applicable DOE test procedure in Sec. 431.134,
be compliant with the applicable standards set forth in paragraphs (b)
through (d) of this section, and be certified to the Department of
Energy under 10 CFR part 429 of this chapter.
(b) Each cube type automatic commercial ice maker with capacities
between 50 and 2,500 pounds per 24-hour period manufactured on or after
January 1, 2010 and before January 28, 2018, shall meet the following
standard levels:
[[Page 4755]]
----------------------------------------------------------------------------------------------------------------
Harvest
Equipment type Type of cooling rate lb ice/ Maximum energy use kWh/ Maximum condenser water
24 hours 100 lb ice use \1\ gal/100 lb ice
----------------------------------------------------------------------------------------------------------------
Ice-Making Head............... Water.......... <500 7.8-0.0055H \2\......... 200-0.022H.
Ice-Making Head............... Water.......... >=500 and 5.58-0.0011H............ 200-0.022H.
<1,436
Ice-Making Head............... Water.......... >=1,436 4.0..................... 200-0.022H.
Ice-Making Head............... Air............ <450 10.26-0.0086H........... Not Applicable.
Ice-Making Head............... Air............ >=450 6.89-0.0011H............ Not Applicable.
Remote Condensing (but not Air............ <1,000 8.85-0.0038H............ Not Applicable.
remote compressor).
Remote Condensing (but not Air............ >=1,000 5.1..................... Not Applicable.
remote compressor).
Remote Condensing and Remote Air............ <934 8.85-0.0038H............ Not Applicable.
Compressor.
Remote Condensing (but not Air............ >=934 5.3..................... Not Applicable.
remote compressor).
Self-Contained................ Water.......... <200 11.40-0.019H............ 191-0.0315H.
Self-Contained................ Water.......... >=200 7.6..................... 191-0.0315H.
Self-Contained................ Air............ <175 18.0-0.0469H............ Not Applicable.
Self-Contained................ Air............ >=175 9.8..................... Not Applicable.
----------------------------------------------------------------------------------------------------------------
\1\ Water use is for the condenser only and does not include potable water used to make ice.
\2\ H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.
Source: 42 U.S.C. 6313(d).
(c) Each batch type automatic commercial ice maker with capacities
between 50 and 4,000 pounds per 24-hour period manufactured on or after
January 28, 2018, shall meet the following standard levels:
----------------------------------------------------------------------------------------------------------------
Harvest Maximum energy use
Equipment type Type of cooling rate lb ice/ kilowatt-hours (kWh)/100 Maximum condenser water
24 hours lb ice \1\ use gal/100 lb ice \2\
----------------------------------------------------------------------------------------------------------------
Ice-Making Head............... Water.......... < 300 6.88-0.0055H............ 200-0.022H.
Ice-Making Head............... Water.......... >=300 and 5.80-0.00191H........... 200-0.022H.
<850
Ice-Making Head............... Water.......... >=850 and 4.42-0.00028H........... 200-0.022H.
<1,500
Ice-Making Head............... Water.......... >=1,500 and 4.0..................... 200-0.022H.
<2,500
Ice-Making Head............... Water.......... >=2,500 and 4.0..................... 145.
<4,000
Ice-Making Head............... Air............ < 300 10-0.01233H............. NA.
Ice-Making Head............... Air............ >= 300 and 7.05-0.0025H............ NA.
< 800
Ice-Making Head............... Air............ >= 800 and 5.55-0.00063H........... NA.
< 1,500
Ice-Making Head............... Air............ >= 1500 and 4.61.................... NA.
< 4,000
Remote Condensing (but not Air............ < 988 7.97-0.00342H........... NA.
remote compressor).
Remote Condensing (but not Air............ >= 988 and 4.59.................... NA.
remote compressor). < 4,000
Remote Condensing and Remote Air............ < 930 7.97-0.00342H........... NA.
Compressor.
Remote Condensing and Remote Air............ >= 930 and 4.79.................... NA.
Compressor. < 4,000
Self-Contained................ Water.......... < 200 9.5-0.019H.............. 191-0.0315H.
Self-Contained................ Water.......... >= 200 and 5.7..................... 191-0.0315H.
< 2,500
Self-Contained................ Water.......... >= 2,500 5.7..................... 112.
and < 4,000
Self-Contained................ Air............ < 110 14.79-0.0469H........... NA.
Self-Contained................ Air............ >= 110 and 12.42-0.02533H.......... NA.
< 200
Self-Contained................ Air............ >= 200 and 7.35.................... NA.
< 4,000
----------------------------------------------------------------------------------------------------------------
\1\ H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.
Source: 42 U.S.C. 6313(d).
\2\ Water use is for the condenser only and does not include potable water used to make ice.
[[Page 4756]]
(d) Each continuous type automatic commercial ice maker with
capacities between 50 and 4,000 pounds per 24-hour period manufactured
on or after January 28, 2018, shall meet the following standard levels:
----------------------------------------------------------------------------------------------------------------
Harvest
Equipment type Type of cooling rate lb ice/ Maximum energy use kWh/ Maximum condenser water
24 hours 100 lb ice \1\ use gal/100 lb ice \2\
----------------------------------------------------------------------------------------------------------------
Ice-Making Head............... Water.......... <801 6.48-0.00267H........... 180-0.0198H.
Ice-Making Head............... Water.......... >=801 and 4.34.................... 180-0.0198H.
<2,500
Ice-Making Head............... Water.......... >=2,500 and 4.34.................... 130.5.
<4,000
Ice-Making Head............... Air............ <310 9.19-0.00629H........... NA.
Ice-Making Head............... Air............ >=310 and 8.23-0.0032H............ NA.
<820
Ice-Making Head............... Air............ >=820 and 5.61.................... NA.
<4,000
Remote Condensing (but not Air............ <800 9.7-0.0058H............. NA.
remote compressor).
Remote Condensing (but not Air............ >=800 and 5.06.................... NA.
remote compressor). <4,000
Remote Condensing and Remote Air............ <800 9.9-0.0058H............. NA.
Compressor.
>=800 and 5.26.................... NA.
<4,000
Self-Contained................ Water.......... <900 7.6-0.00302H............ 153-0.0252H.
Self-Contained................ Water.......... >=900 and 4.88.................... 153-0.0252H.
<2,500
Self-Contained................ Water.......... >=2,500 and 4.88.................... 90.
<4,000
Self-Contained................ Air............ <200 14.22-0.03H............. NA.
Self-Contained................ Air............ >=200 and 9.47-0.00624H........... NA.
<700
Self-Contained................ Air............ >=700 and 5.1..................... NA.
<4,000
----------------------------------------------------------------------------------------------------------------
\1\ H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.
Source: 42 U.S.C. 6313(d).
\2\ Water use is for the condenser only and does not include potable water used to make ice.
Appendix
[The following letter from the Department of Justice will not appear
in the Code of Federal Regulations.]
U.S. Department of Justice, Antitrust Division, William J. Baer,
Acting Assistant Attorney General, RFK Main Justice Building, 950
Pennsylvania Ave., NW., Washington, DC 20530-0001, (202)514-2401/
(202)616-2645 (Fax)
December 24, 2014
Eric J. Fygi, Deputy General Counsel, Department of Energy,
Washington, DC 20585
Re: Energy Conservation Standards for Automatic Commercial Ice
Makers,
Dear Deputy General Counsel Fygi:
I am responding to your December 3, 2014 letter seeking the
views of the Attorney General about the potential impact on
competition of proposed energy conservation standards for automatic
commercial ice makers. Your request was submitted under Section
325(o)(2)(B)(i)(V) of the Energy Policy and Conservation Act, as
amended (ECPA), 42 U.S.C. 6295(o)(2)(B)(i)(V), which requires the
Attorney General to make a determination of the impact of any
lessening of competition that is likely to result from the
imposition of proposed energy conservation standards. The Attorney
General's responsibility for responding to requests from other
departments about the effect of a program on competition has been
delegated to the Assistant Attorney General for the Antitrust
Division in 28 CFR Sec. 0.40(g).
In conducting its analysis the Antitrust Division examines
whether a proposed standard may lessen competition, for example, by
substantially limiting consumer choice, by placing certain
manufacturers at an unjustified competitive disadvantage, or by
inducing avoidable inefficiencies in production or distribution of
particular products. A lessening of competition could result in
higher prices to manufacturers and consumers.
We have reviewed the proposed standards contained in the Notice
of Proposed Rulemaking (79 FR 14848, March 17, 2014) (NOPR). In
light of the short time frame for our review of the proposed
standards, we also consulted with DOE staff on the issues raised by
the proposed NOPR.
Based on this review and consultation with DOE staff, our
conclusion is that the proposed energy conservation standards for
automatic commercial ice makers are unlikely to have a significant
adverse impact on competition.
Sincerely,
William J. Baer
Enclosure
[FR Doc. 2015-00326 Filed 1-27-15; 8:45 am]
BILLING CODE 6450-01-P
