CHAPTER 9. TRIAL STANDARD LEVELS
 

TABLE OF CONTENTS
 

9.1 INTRODUCTION............................................................................................................... 9-1
 

9.2 TRIAL STANDARD LEVELS........................................................................................... 9-1
 

LIST OF TABLES 

Table 9.2.1 Trial Standard Levels for Class A Equipment Expressed in Terms of Daily 

Energy Consumption ........................................................................................... 9-3 

Table 9.2.2 Trial Standard Levels for Class B Equipment Expressed in Terms of Daily 

Table 9.2.3 Trial Standard Levels Expressed in Terms of Equations and Coefficients 

Energy Consumption ........................................................................................... 9-3 

for Each Equipment Class .................................................................................... 9-4 

LIST OF FIGURES 

Figure 9.2.1 Comparison of Trial Standard Level 3 Correlations Between NOPR and 

Final Rule for Class B Equipment ....................................................................... 9-5 

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CHAPTER 9. TRIAL STANDARD LEVELS
 

9.1 INTRODUCTION 

Title III of Energy Policy and Conservation Act (EPCA) sets forth a variety of provisions 

designed to improve energy efficiency. Part A of Title III (42 U.S.C. 6291-6309) provides for the 

Energy Conservation Program for Consumer Products Other Than Automobiles. Part A-1 of 

Title III (42 U.S.C. 6311-6317) establishes a similar program for certain types of commercial 

and industrial equipment. This part was originally titled Part C; however, it was renamed Part A1 after Part B of Title III was repealed by the Energy Policy Act of 2005 (EPACT 2005). This 

Act, Pub. L. 109-58, included an amendment to Part A-1 requiring that the U.S. Department of 

Energy (DOE) prescribe energy conservation standards for the beverage vending machines that 

are the subject of this rulemaking (EPACT 2005, section 135(c)(4); 42 U.S.C. 6295(v)) The test 

procedures for beverage vending machines appear at Title 10 Code of Federal Regulations (CFR) 

sections 431.293 and 431.294. 

Because of its placement in Part A of Title III of EPCA, the rulemaking for beverage 

vending machine energy conservation standards is bound by the requirements of 42 U.S.C. 6295. 

However, since beverage vending machines are commercial equipment and consistent with 

DOE’s previous action to incorporate the EPACT 2005 requirements for commercial equipment 

into Title 10 CFR, part 431 Energy Efficiency Program for Certain Commercial and Industrial 

Equipment, DOE has placed the requirements for beverage vending machines in subpart Q of 

10 CFR part 431. The location of the provisions within the CFR does not affect either their 

substance or applicable procedure, so DOE is placing them in the appropriate CFR part based on 

their nature or type. The EPCA as amended specifies that any new or amended energy 

conservation standard DOE prescribes for the equipment covered by this notice shall be designed 

to “achieve the maximum improvement in energy efficiency . . . which the Secretary determines 

is technologically feasible and economically justified.” (42 United States Code (U.S.C.) 

6295(o)(2)(A), and (v)). Further, the new or amended standard must “result in significant 

conservation of energy.” (42 U.S.C. 6295(o)(3)(B) and (v)) In accordance with these and other 

statutory criteria discussed in this notice, DOE proposes to adopt new energy conservation 

standards for refrigerated bottled or canned beverage vending machines, hereafter referred to as 

“beverage vending machines.” 

On August 8, 2005, section 135(c)(4) of EPACT 2005 amended section 325 of EPCA, in 

part, to direct DOE to issue energy conservation standards for the equipment covered by this 

rulemaking, which standards would apply to equipment manufactured three years after 

publication of the final rule establishing the energy conservation standards. (42 U.S.C. 

6295(v)(1), (2) and (3)) The relevant statutory provisions were renumbered pursuant to section 

316 of the Energy Independence and Security Act of 2007, Pub. L. 110–140. The energy use of 

this equipment has never been regulated at the Federal level. 

9.2 TRIAL STANDARD LEVELS 

DOE analyzed seven energy consumption levels for Class A equipment and six energy 

consumption levels for Class B equipment in the life-cycle cost (LCC) analysis and national 

impact analysis (NIA). For the notice of proposed rulemaking (NOPR), DOE determined that 

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each of these levels should be presented as a possible trial standard level (TSL) and 

correspondingly identified seven TSLs for Class A and six TSLs for Class B equipment. For 

each equipment class, the range of TSLs selected includes the energy consumption level 

providing the maximum national energy savings (NES) level for the class, the level providing the 

maximum NES while providing a positive net present value (NPV), the level providing the 

maximum NPV, and the level approximately equivalent to ENERGY STAR Tier 2. Many of the 

higher levels selected correspond to equipment designs which incorporate specific noteworthy 

technologies that can provide energy savings benefits. For Class A, DOE also included two 

intermediate efficiency levels to fill in significant energy consumption gaps between the levels 

identified above the ENERGY STAR Tier 2 equivalent level. For Class A machines, the 

ENERGY STAR Tier 2 equivalent TSL level, TSL 1, allows for the highest energy consumption. 

For Class B, DOE included one TSL with energy consumption higher than that provided by 

ENERGY STAR Tier 2. 

For the advance notice of proposed rulemaking (ANOPR), DOE proposed four candidate 

standard levels for each equipment class based on the levels that provided maximum energy 

savings, maximum efficiency level with positive LCC savings, maximum LCC savings, and the 

highest efficiency level with a payback of less than 3 years. 

DOE preserved energy consumption levels that met the same economic criteria as was 

used in the ANOPR in the NOPR, but in addition, included the Tier 2 equivalency level and 

several additional TSLs. These additional levels, as discussed previously, either provide 

additional intermediate efficiency levels or include specific noteworthy technologies examined in 

the engineering analysis. 

Table 9.2.1 and Table 9.2.2 show the TSL levels DOE selected for the equipment classes 

and sizes analyzed. For Class A equipment, TSL 7 is the max-tech level for three equipment 

sizes: small (S), medium (M), and large (L). TSL 6 is the maximum efficiency level with a 

positive NPV at the 7-percent discount rate, achieved through incorporation of a condenser fan 

motor that is an electronically commutated motor (ECM). TSL 5 is the efficiency level with the 

maximum NPV and maximum LCC savings, achieved through the use of an advanced refrigerant 

condenser design. TSL 4 is the level that first incorporated light-emitting diode (LED) lighting 

for products as a design feature in the engineering analysis. TSL 3 and TSL 2 were intermediate 

efficiency levels chosen to bridge the gap between TSL 4, and the ENERGY STAR Tier 2 

equivalent level, TSL 1. 

For Class B equipment TSL 6 is the max-tech level. TSL 5 is the level that first 

incorporated LED lighting for the machine as a design option in the engineering analysis. TSL 4 

is the next highest efficiency level including incorporation of an ECM condenser fan motor. TSL 

3 was achieved through the use of an advanced refrigerant condenser design and provided 

essentially an NPV of essentially $0, with total capital expenditures for new equipment balanced 

by total operating cost savings over the NIA period, based on a 7-percent discount rate. TSL 2 is 

the ENERGY STAR Tier 2 level for Class B equipment, and provided the maximum LCC 

savings and maximum NPV savings at a 7-percent discount rate. TSL 1, which provided an 

energy consumption level approximately 4 percent higher than TSL 2, was also included in the 

analysis, and represented the first level incorporating an evaporator fan driven by an ECM in the 

engineering analysis. 

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Table 9.2.1 Trial Standard Levels for Class A Equipment Expressed in Terms of Daily 

Energy Consumption 

Size TSL TSL in Order of Efficiency 

Baseline 1 2 3 4 5 6 7 

LCC Efficiency 

Level 1 2 3 4 5 6 7 8 

Small Engr. Level 1 5 N/A* N/A 6 7 9 11 

kWh/day 6.10 5.27 4.75 4.25 3.95 3.73 3.58 3.25 

Medium Engr. Level 1 5 N/A N/A 6 7 9 11 

kWh/day 6.53 5.51 5.25 4.75 4.19 3.95 3.79 3.43 

Large Engr. Level 1 4 N/A N/A 5 6 8 10 

kWh/day 6.75 6.21 5.75 5.25 4.89 4.60 4.41 3.94 *

 N/A means not available. These levels established as intermediate points along the engineering cost curves 

Table 9.2.2 Trial Standard Levels for Class B Equipment Expressed in Terms of Daily 

Energy Consumption 

Size TSL TSL in Order of Efficiency 

Baseline 1 2 3 4 5 6 

LCC Efficiency 

Level 1 2 3 4 5 6 7 

Small Engr. Level 

kWh/day 

1 

4.96

2 

 4.62

4 

 4.31 

4 

4.31 

5 

4.28 

6 

3.78 

7 

3.69 

Medium Engr. Level 

kWh/day 

1 

5.56

2 

 5.20

4 

 4.99 

5 

4.76 

6 

4.72 

7 

4.22 

8 

4.12 

Large Engr. Level 

kWh/day 

1 

5.85

2 

 5.48

3 

 5.33 

4 

5.07 

5 

5.03 

6 

4.52 

7 

4.41 

As determined in the ANOPR, DOE chose to characterize the proposed TSL levels in 

terms of proposed equations that establish a maximum daily energy consumption (MDEC) limit 

through a linear equation of the form: 

MDEC = A × V + B Eq. 9.1 

Where: 

A = expressed in terms of kWh/day/ft3 of measured volume, 

V = the measured refrigerated volume (ft3) calculated for the equipment, and 

B = an offset factor expressed in kWh/day. 

Coefficients A and B are uniquely derived for each equipment class based on a linear 

equation passing between the daily energy consumption values for equipment of different 

refrigerated volumes. For the development of the A and B coefficients, DOE used the energy 

consumption values shown in Table 9.2.1 and Table 9.2.2 for the medium and large equipment 

sizes respectively (two-point weighting strategy) within each class of beverage vending machine. 

Also, the equations corresponding to each of the TSLs and for the two equipment classes are 

listed in Table 9.2.3. 

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Table 9.2.3 Trial Standard Levels Expressed in Terms of Equations and Coefficients for 

Each Equipment Class 

TSL Test Metric Class A Class B 

Baseline kWh/day MDEC = 0.019 x V + 6.09 

1 kWh/day MDEC = 0.062 x V + 4.12 

2 kWh/day MDEC = 0.044 x V + 4.26 

3 kWh/day MDEC = 0.044 x V + 3.76 

4 kWh/day MDEC = 0.062 x V + 2.80 

5 kWh/day MDEC = 0.058 x V + 2.66 

6 kWh/day MDEC = 0.055 x V + 2.56 

7 kWh/day MDEC = 0.045 x V + 2.42 

MDEC = 0.068 x V + 4.07 

MDEC = 0.066 x V + 3.76 

MDEC = 0.080 x V + 3.24 

MDEC = 0.073 x V + 3.16 

MDEC = 0.073 x V + 3.12 

MDEC = 0.070 x V + 2.68 

MDEC = 0.068 x V + 2.63 

N/A* 

*

 N/A means not available. There is no TSL 7 for Class B machines. 

DOE did not use the small equipment sizes for either Class A or Class B, as information 

from the ANOPR indicated that there are no significant shipments of the small equipment sizes. 

At and after the NOPR public meeting, DOE received comments for using the two-point 

versus a three-point weighting strategy (including the small-sized equipment market share) in 

developing final TSL correlations. Using this three-point strategy, the correlation for TSL 3 

(proposed standard level in the NOPR) for Class B equipment was compared to the curve 

obtained using the two-point strategy as reported in the NOPR. Because the difference between 

the two curves is small (1.5 percent for small-sized equipment (17 ft3

) and less than 1 percent for 

large-sized equipment (27 ft3 of refrigerated volume) as seen in Figure 9.2.1, DOE used the same 

correlations for all TSLs as developed in the NOPR for Class B equipment for the final rule (FR) 

analysis (Table 9.2.3). 

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0 

1 

2 

3 

4 

5 

6 

7 

8 

24 26 

Energy Consumption (kWh/day)

NOPR - Solid 

FR - Dashed 

16 18 20 22
 

Refrigerated Volume (ft^3)
 

Figure 9.2.1 Comparison of Trial Standard Level 3 Correlations Between NOPR and Final 

Rule for Class B Equipment 

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