CHAPTER 2. ANALYTICAL FRAMEWORK 

TABLE OF CONTENTS 

2.1 INTRODUCTION ........................................................................................................... 2-1 

2.2 BACKGROUND ............................................................................................................. 2-4 

2.3 MARKET AND TECHNOLOGY ASSESSMENT........................................................2-4 

2.3.1 Market Assessment .............................................................................................. 2-4 

2.3.2 Technology Assessment....................................................................................... 2-5 

2.3.3 Test Procedure .....................................................................................................2-5 

2.4 SCREENING ANALYSIS .............................................................................................. 2-6 

2.4.1 Technology Screening ......................................................................................... 2-6 

2.5 ENGINEERING ANALYSIS.......................................................................................... 2-6 

2.5.1 Equipment Classes Analyzed............................................................................... 2-6 

2.5.2 Manufacturing Cost Assessment.......................................................................... 2-7 

2.5.3 Energy Consumption Model................................................................................ 2-7 

2.6 ENERGY USE CHARACTERIZATION .......................................................................2-7 

2.7 MARKUPS TO DETERMINE EQUIPMENT PRICE ................................................... 2-8 

2.8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES .................................... 2-9 

2.9 SHIPMENTS ANALYSIS............................................................................................. 2-11 

2.10 NATIONAL IMPACT ANALYSIS..............................................................................2-11 

2.10.1 National Energy Savings Analysis..................................................................... 2-11 

2.10.2 Net Present Value Analysis ............................................................................... 2-12 

2.10.3 Efficiency Scenarios and Trends .......................................................................2-12 

2.11 LIFE-CYCLE COST SUB-GROUP ANALYSIS......................................................... 2-13 

2.12 MANUFACTURER IMPACT ANALYSIS..................................................................2-14 

2.13 UTILITY IMPACT ANALYSIS...................................................................................2-14 

2.14 ENVIRONMENTAL ASSESSMENT ..........................................................................2-15 

2.15 EMPLOYMENT IMPACT ANALYSIS.......................................................................2-15 

2.16 REGULATORY IMPACT ANALYSIS........................................................................2-16 

2.17 DEPARTMENT OF JUSTICE REVIEW ..................................................................... 2-16 

LIST OF FIGURES 

Figure 2.1.1 Flow Diagram of Analyses for the Commercial Refrigeration Equipment 

Rulemaking Process............................................................................................... 2-2 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
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EERE-2006-BT-STD-0126 COMMENT 52.2 
CHAPTER 2. ANALYTICAL FRAMEWORK 

2.1 INTRODUCTION 

Section 6295(o)(3)(B) of Title 42 United States Code (42 U.S.C.), as directed by 42 

U.S.C. 6316(a) (1)-(3)), requires the U.S. Department of Energy (DOE) to set forth energy 

conservation standards that are technologically feasible and economically justified, and would 

achieve the maximum improvement in energy efficiency. This chapter provides a description of 

the general analytical framework that DOE uses in developing such standards, and in particular, 

standards for commercial refrigeration equipment (CRE). The analytical framework is a 

description of the methodology, the analytical tools, and relationships among the various 

analyses that are part of this rulemaking. For example, the methodology that addresses the 

statutory requirement for economic justification includes analyses of life-cycle cost (LCC); 

economic impact on manufacturers and users; national benefits; impacts on utility companies; 

and impacts from lessening competition among manufacturers. DOE also solicited the views of 

the U.S. Department of Justice (DOJ) on any lessening of competition likely to result from the 

imposition of a proposed standard. 

Figure 2.1.1 summarizes the analytical components of the standards-setting process. The 

focus of this figure is the center column, identified as “Analyses.” The columns labeled “Key 

Inputs” and “Key Outputs” show how the analyses fit into the rulemaking process, and how the 

analyses relate to each other. Key inputs are the types of data and information that the analyses 

require. Some key inputs exist in public databases; DOE collects other inputs from stakeholders 

or persons with special knowledge. Key outputs are analytical results that feed directly into the 

standards-setting process. Arrows connecting analyses show types of information that feed from 

one analysis to another. 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
Figure 2.1.1 Flow Diagram of Analyses for the Commercial Refrigeration Equipment 

Rulemaking Process 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
The analyses performed in the final rule stage and reported in this technical support 

document (TSD) are listed below. 

•	 A market and technology assessment characterizes the relevant equipment markets and 

existing technologies, including prototype designs. 

•	 A screening analysis is conducted to review each technology and determine if it is 

technologically feasible; is practical to manufacture, install, and service; would adversely 

affect equipment utility or equipment availability; or would have adverse impacts on 

health and safety. 

•	 An engineering analysis develops the cost-efficiency relationship, which is the increased 

manufacturer production cost (material, labor, and factory overhead) of more-efficient 

equipment. The increased cost to the customer is determined through an analysis of 

engineering markups, which convert manufacturer production cost to manufacturer 

selling price (MSP). 

•	 An equipment price markup analysis to determine equipment price converts the MSP 

estimates from the engineering analysis to customer prices, which are then used in the 

LCC and payback period (PBP) analyses and the manufacturer impact analysis. 

•	 An energy use analysis is conducted to determine the annual energy use and hourly 

power consumption characteristics of commercial refrigeration equipment in commercial 

buildings. 

•	 LCC and PBP analyses calculate, at the customer level, the discounted savings in 

operating costs (less maintenance and repair costs) throughout the estimated average life 

of the covered equipment, compared to any increase in the installed cost for the 

equipment likely to result directly from imposition of the standard. 

•	 A shipments analysis forecasts equipment shipments, which are then used to calculate the 

national impacts of standards on energy consumption and costs, net present value (NPV), 

and future manufacturer cash flows. 

•	 A national impact analysis (NIA) assesses the aggregate impacts at the national level of 

the NPV of total consumer LCC and national energy savings (NES). 

•	 A life-cycle cost sub-group analysis evaluates variations in commercial business type 

characteristics (e.g., energy prices, equipment use patterns, installation and maintenance 

costs) that might cause a standard to affect particular customer sub-populations, such as 

specific building owners or other customers who purchase and use commercial 

refrigeration equipment differently than the overall population. 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
•	 A manufacturer impact analysis estimates the financial impact of standards on 

manufacturers and calculates impacts on competition, employment, and manufacturing 

capacity. 

•	 A utility impact analysis estimates the effects of proposed standards on electric utilities. 

•	 An employment impact analysis assesses the aggregate impacts on national employment. 

•	 An environmental assessment provides estimates of changes in emissions of pollutants 

from electricity generation (carbon dioxide (CO2), oxides of nitrogen (NOx), and sulfur 

dioxide (SO2)). 

•	 A regulatory impact analysis presents major alternatives to proposed standards that could 

achieve substantially the same regulatory goal at a lower cost. 

2.2 BACKGROUND 

Chapter 1 of this TSD outlines procedural requirements of the standards rulemaking 

process, which includs a review of the following elements: (1) economic models, (2) analytical 

tools, (3) methodologies, (4) non-regulatory approaches, and (5) prioritization of future rules. 

DOE documented its analytical framework in the Rulemaking Framework for 

Commercial Refrigeration Equipment Including Ice-Cream Freezers; Self-Contained 

Commercial Refrigerators, Freezers, and Refrigerator-Freezers without doors; and Remote 

Condensing Commercial Refrigerators, Freezers, and Refrigerator-Freezers, and presented the 

analytical approach to stakeholders during a public meeting held on May 16, 2006. This 

document is available at 

http://www.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/comml_refrig_fram 

ework.pdf. The following sections provide a general description of the different analytical 

components of the rulemaking framework. 

2.3 MARKET AND TECHNOLOGY ASSESSMENT 

The market and technology assessment characterizes the relevant equipment markets and 

existing technology options, including prototype designs. 

2.3.1 Market Assessment 

When initiating a standards rulemaking, DOE develops information on the present and 

past industry structure and market characteristics for the equipment concerned. This activity 

assesses the industry and equipment both quantitatively and qualitatively, based on publicly 

available information, and encompasses the following: (1) manufacturer market share and 

characteristics, (2) existing regulatory and non-regulatory equipment efficiency improvement 

initiatives, and (3) trends in equipment characteristics and retail markets. This information 

serves as resource material throughout the rulemaking. 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
 

DOE reviewed existing literature and interviewed manufacturers to get an overall picture 

of the CRE market in the United States. Industry publications and trade journals, government 

agencies, and trade organizations provided the bulk of the information, including (1) 

manufacturers and their market share, (2) shipments by capacity, and (3) market saturation. 

DOE uses the most reliable and accurate data available at the time of analysis. . 

2.3.2 Technology Assessment 

DOE typically uses information about existing and past technology options and prototype 

designs to determine which technologies manufacturers use to attain higher energy performance 

levels. In consultation with stakeholders, DOE develops a list of technologies for consideration. 

Initially, these technologies encompass all those DOE believes are technologically feasible. 

DOE developed its list of technologically feasible design options after consultation with 

manufacturers of components and systems, and from trade publications and technical papers. 

Since many options for improving efficiency are available in existing equipment, product 

literature and direct examination of commercial refrigeration equipment provided additional 

information, described in Chapter 3 of the TSD. 

2.3.3 Test Procedure 

A test procedure outlines the method by which manufacturers will determine the 

efficiency of their commercial refrigeration equipment, and thereby assess compliance with an 

energy conservation standard. 

Section 136(f)(1)(B) of EPACT 2005 amended section 343 of EPCA (42 U.S.C. 6314) by 

adding new subsections 343(a)(6)(A)-(D) (42 U.S.C. 6314(a)(6)(A)-(D)), which direct the 

Secretary to develop test procedures for commercial refrigeration equipment. On December 8, 

2006, DOE published a final rule (the December 2006 final rule) in which DOE adopted 

American National Standards Institute (ANSI)/Air-Conditioning and Refrigeration Institute 

(ARI) Standard 1200-2006, Performance Rating of Commercial Refrigerated Display 

Merchandisers and Storage Cabinets, with one modification, as the DOE test procedure for this 

equipment. 71 FR 71340, 71369-70.a

 Standard 1200-2006 contains equipment rating 

temperature specifications of 38°F (±2°F) for commercial refrigerators and refrigerator 

compartments, 0°F (±2°F) for commercial freezers and freezer compartments, and -5°F (±2°F) 

for ice-cream freezers. The standard requires performance tests to be conducted according to the 

American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) 

Standard 72-2005, Method of Testing Commercial Refrigerators and Freezers. DOE made only 

one modification to ANSI/ARI Standard 1200-2006: DOE selected -15°F (±2°F) as the rating 

temperature for ice-cream freezers, instead of -5°F (±2°F). 71 FR 71370. In addition, DOE 

adopted ANSI/Association of Home Appliance Manufacturers (AHAM) Standard HRF-1-2004, 

Energy, Performance and Capacity of Household Refrigerators, Refrigerator-Freezers and 

Freezers, for determining compartment volumes. 71 FR 71369-70. 

a

 Test procedures are found at 10 CFR section 431.64. 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
2.4 SCREENING ANALYSIS 

The screening analysis examines whether various technologies (1) are technologically 

feasible; (2) are practicable to manufacture, install, and service; (3) have an adverse impact on 

equipment utility or availability; and (4) have adverse impacts on health and safety. In the 

engineering analysis, DOE further considered design options that remained after the screening 

process. 

2.4.1 Technology Screening 

As described in Chapter 4 of this TSD, DOE grouped technologies into the following 

categories: (1) emerging technologies, which are currently not available on the commercial 

market but are being examined in the laboratory as possible means to enhance efficiency; and (2) 

commercially available technologies that are used to improve energy consumption under DOE’s 

test procedure. 

Because the energy descriptor for commercial refrigeration equipment is daily energy 

consumption and the test procedure uses a steady-state approach, DOE did not include 

technologies or designs that improve energy consumption under varying ambient conditions 

(e.g., expansion valves or variable-speed compressors). Therefore, only those technologies that 

improve the daily energy consumption rating were considered viable for review. 

2.5 ENGINEERING ANALYSIS 

As discussed in Chapter 5 of the TSD, the engineering analysis establishes the 

relationship between the cost and efficiency of commercial refrigeration equipment. This 

relationship serves as the basis for cost/benefit calculations in terms of individual customers, 

manufacturers, and the Nation. The engineering analysis discusses the industry-supplied costefficiency curves, the equipment classes analyzed, the representative baseline units, the 

methodology used to develop manufacturing costs, the methodology used to develop the energy 

consumption model, the analytically-derived cost-efficiency curves, the methodology used to 

extend the analysis to low-shipment volume equipment classes, and the use of alternative 

refrigerants. 

2.5.1 Equipment Classes Analyzed 

Because of the large number of equipment classes in this rulemaking, the engineering 

analysis did not assess all covered equipment classes. DOE used the shipment data in the market 

and technology assessment (Chapter 3) to prioritize equipment classes to analyze. Equipment 

classes with fewer than 100 annual units shipped were not considered for the analysis, leaving 14 

“high-shipment” equipment classes for analysis. According to the equipment shipments, these 

14 equipment classes represent 98 percent of the total industry shipments. One additional 

equipment class, the vertical open remote condensing unit equipment class (VOP.RC.L), was 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
 

 

added after discussions with manufacturers.b Thus, 15 covered equipment classes were analyzed 

and 15 cost-efficiency curves were generated in the engineering analysis. 

2.5.2 Manufacturing Cost Assessment 

DOE conducted a manufacturing cost assessment to estimate the manufacturing costs 

associated with a decrease in energy consumption for commercial refrigeration equipment. This 

approach involved disassembling a vertical closed transparent self-contained medium 

temperature (VCT.SC.M) refrigerator, analysis of the materials and manufacturing processes, 

and development of a spreadsheet cost model. Using the manufacturing cost assessment, DOE 

developed a clear and consistent manufacturing cost assessment methodology, built a detailed 

manufacturing cost assessment model that accurately predicts manufacturing cost, reported the 

manufacturing costs in aggregated form to maintain confidentiality of the data, and obtained 

input from stakeholders on the manufacturing cost estimates and assumptions to confirm 

accuracy. 

2.5.3 Energy Consumption Model 

DOE developed an energy consumption model to calculate energy consumption of the 

equipment at various performance levels within each equipment class. The model is based on 

ANSI/ARI Standard 1200, Performance Rating of Commercial Refrigerated Display 

Merchandisers and Storage Cabinets, but calculates the total refrigeration load as a summation of 

electric and non-electric heat loads. Electric heat loads include the internal loads from fan 

motors, lighting, defrost heaters, and anti-sweat heaters. DOE assumed that all electrical energy 

ends up as heat inside the case (except for lighting outside of the air curtain on open cases and 

the defrost power that is consumed condensing the ice on the coils to water). Non-electric loads 

include heat loads from radiation through glass, seals, and openings; conduction through walls 

and solid doors; and infiltration of warm, moist air into the case. DOE used a thermal 

conductivity, or U-factor, to calculate a combined conduction/convection/radiation load for 

glass. DOE used a simple conduction/convection model to calculate conduction through walls 

and solid doors, and empirical data to calculate infiltration loads. 

2.6 ENERGY USE CHARACTERIZATION 

The energy use characterization assesses the energy savings impacts from higher 

efficiency standards and provides the basis for the energy savings used in the LCC and 

subsequent analyses. The energy use characterization validated the use of the engineering 

analysis energy estimates for assessing energy savings for higher equipment efficiencies. DOE 

assessed the energy savings impacts for seven different classes of remote condensing commercial 

b

 Equipment class designations consist of a combination (in sequential order separated by periods) of an equipment 

family code (VOP=vertical open, SVO=semivertical open, HZO=horizontal open, VCT=vertical transparent doors, 

VCS=vertical solid doors, HCT=horizontal transparent doors, HCS=horizontal solid doors, or SOC=service over 

counter), an operating mode code (RC=remote condensing or SC=self-contained), and a rating temperature code 

(M=medium temperature (38°F), L=low temperature (0°F), or I=ice-cream temperature (-15°F)). For example, 

"VOP.RC.M refers to the "vertical open, remote condensing, medium temperature" equipment class. See Chapter 3, 

Market and Technology Assessment, for a more detailed explanation of the equipment class terminology. 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
refrigeration equipment across a range of U.S. climates. Various design options corresponded to 

different energy efficiency levels. DOE assessed the energy impacts at the level of the 

refrigeration equipment case (display case) alone, the case and associated refrigeration system, 

and the whole building. As part of the energy use characterization, DOE made certain 

engineering assumptions regarding equipment application, including how the equipment is 

operated and under what conditions and has documented these assumptions in the TSD. 

Studies conducted by Arthur D. Little, Inc., Southern California Edison, Lawrence 

Berkeley National Laboratory, and Caneta Research assisted in characterizing the annual energy 

consumption of commercial refrigeration equipment. These studies primarily focused on 

refrigerated display cases packaged with remote condensing units. 

For buildings using commercial refrigeration equipment, the primary energy consumption 

and demand impact are from the energy and power use of the equipment itself and from the 

associated refrigeration loads and remote condensing equipment, both of which can vary with 

climate. The impact on building heating and cooling energy is a secondary impact that also 

relates to climate. Characterizing the energy savings from more-efficient commercial 

refrigeration equipment and the associated energy impacts from the remote condensing system 

and the building heating and cooling load is a critical part of the standards rulemaking analysis 

because it assesses the relative importance of these secondary impacts and validates the 

engineering energy use estimates. 

In the energy use characterization, DOE defined a single building prototype―a mediumsized supermarket—for modeling energy impacts. DOE characterized combinations of design 

options representing four efficiency levels for each class of remote condensing equipment. DOE 

used whole building energy analysis software with the capability to model refrigeration 

equipment and the building prototypes in different climate regions in order to capture the energy 

impacts at the CRE case, for the refrigeration system and case combined, and for the entire 

building. 

2.7 MARKUPS TO DETERMINE EQUIPMENT PRICE 

DOE used manufacturer-to-customer markups to convert the MSP estimates from the 

engineering analysis to customer prices, which were then used in the LCC, PBP, and 

manufacturer impact analyses. Because retail prices are required for all the performance levels 

under consideration, DOE obtained these retail prices by applying manufacturer-to-customer 

markups to the MSP estimates. 

Before it can develop markups, DOE must identify distribution channels (i.e., how the 

equipment is distributed from the manufacturer to the customer). Once it established proper 

distribution channels for each of the equipment classes, DOE relied on economic data from the 

U.S. Census Bureau and input from the trade organization representing distributors of 

refrigeration equipment to define how equipment are marked up as they pass from the 

manufacturer to the customer (see Chapter 6 of the TSD). 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
DOE has estimated manufacturer-to-customer markups for residential air-conditioning 

products and commercial air-conditioning equipment. In the recent commercial unitary airconditioners and heat pumps (CUAC) rulemaking, analysis of distribution channel markups 

focused on three distribution channel paths and calculated markups for individual points along 

these paths. Two of these paths involved sales of equipment through a mechanical contractor 

and then through a general contractor before reaching the final customer. A third “national 

account” path involved sales directly from manufacturer to the end customer. The CUAC 

analysis noted that in the case of replacement equipment (approximately 70 percent of the CUAC 

market), a general contractor typically was not involved and therefore no general contractor 

markups were incurred for replacement equipment. 

DOE’s review of information for CRE distribution suggested a similar set of three 

distribution channels would be appropriate: 

Manufacturer → Distributor → Mechanical Contractor → Customer (7 percent of sales) 

Manufacturer → Distributor → Customer (7 percent of sales) 

Manufacturer → Customer (National Account) (86 percent of sales) 

The data suggests that a general contractor was not involved in the purchase of 

commercial refrigeration equipment at either the new construction or replacement levels, and 

that the fraction of sales through each distribution channel would be the same for both new and 

replacement equipment. 

2.8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES 

The effects of new energy conservation standards on equipment result in changes in 

operating expenses (usually a decrease) and changes in customer price (usually an increase). 

DOE analyzed the net effect of new standards on customers by evaluating the net LCC using the 

cost-efficiency relationship derived in the engineering analysis, as well as the energy costs 

derived from the energy use characterization analysis. Inputs to the LCC calculation include the 

installed cost to the customer (customer price plus installation cost), operating expenses (energy 

expenses and maintenance costs), the lifetime of the appliance, and a discount rate. Chapter 8 

discusses these inputs in detail. 

The installed and operating costs of equipment typically change in response to new 

standards (installed cost usually increases while operating cost usually decreases). Thus, there is 

a specific time in the life of higher-than-baseline efficiency equipment when the net operatingcost benefit (in dollars) from the time of purchase is equal to the incremental first cost of 

purchasing the more-efficient equipment. The length of time required for equipment to reach 

this cost-equivalence point is known as the payback period. 

DOE conducted the LCC and PBP analyses using typical values to reflect the conditions 

in the field for equipment life and energy consumption. Distributions of values were used to 

develop equipment retail price and national or regional energy costs. Discount rates varied by 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
business type. DOE conducted the life-cycle cost sub-group analysis for the final rule and 

included an assessment of impacts on sub-groups of customers. 

For commercial refrigeration equipment, it was necessary to determine several of the 

input values for the LCC estimation, including retail prices; electricity prices; discount rate; 

maintenance, service, and installation costs; and equipment lifetimes. 

DOE reviewed energy price data from the Energy Information Administration (EIA) for 

commercial refrigeration equipment to establish electricity and natural gas prices. DOE relied on 

State average energy price data for the commercial sector scaled to reflect average prices paid by 

businesses using commercial refrigeration equipment relative to the entire commercial sector. 

DOE used projections of these energy prices for commercial customers to estimate future energy 

prices in its LCC and PBP analyses. DOE used EIA’s Annual Energy Outlook (AEO) as the 

default source of projections for future energy prices. 

DOE developed discount rates by estimating the cost of capital to businesses that 

purchase commercial refrigeration equipment covered under this rulemaking. DOE commonly 

uses the cost of capital to estimate the present value of cash flows to be derived from a typical 

company project or investment. Most companies use both debt and equity capital to fund 

investments, so the cost of capital is the weighted-average cost to the firm of equity and debt 

financing. This corporate finance approach is referred to as the weighted-average cost of capital. 

DOE considered expected changes to maintenance, repair, and installation costs for the 

equipment covered in this rulemaking. Typically, small incremental changes in equipment 

efficiency incur no, or only very small, changes in repair and maintenance costs over baseline 

efficiency equipment. Equipment with efficiencies significantly greater than the baseline can 

incur increased repair and maintenance costs, since such equipment is more likely to incorporate 

technologies that are new to the industry and not widely available. DOE relied on facilities’ 

planning literature and industry data to develop appropriate repair and maintenance costs. 

DOE divided maintenance costs into preventive maintenance and lighting maintenance 

activities. Reliable performance is a market prerequisite for commercial refrigeration equipment. 

Since no data were available to suggest increased preventive maintenance costs for the design 

options considered, DOE assumed that maintenance costs did not increase with efficiency level. 

When lighting changes were considered as design options, DOE separately assessed 

regular lighting maintenance costs (primarily bulb, ballast, or fixture replacement). Because no 

data was available to suggest repair costs increase with more-efficient equipment, DOE held 

repair costs fixed, but made a provision for repair costs that vary in proportion to equipment 

costs. Unless the efficiency increases considered for this rulemaking result in significantly larger 

or heavier equipment, DOE determined that more-efficient commercial refrigeration equipment 

would not increase installation costs. 

DOE used information from various published sources and input from the equipment 

distributors and the food retail industry to establish average equipment lifetimes for use in the 

LCC and subsequent analyses. 

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2.9 SHIPMENTS ANALYSIS 

Shipment forecasts are required to calculate the national impacts of standards on energy, 

NPV, and future manufacturer cash flows. DOE developed shipment forecasts based on an 

analysis of key market drivers for commercial refrigeration equipment. 

DOE developed a set of shipment forecasts for each equipment class for each set of 

standards analyzed. These standards case forecasts were used to evaluate the impacts of 

standards on equipment shipments. Standards case forecasts were derived using the same data 

sets as base case forecasts. However, because the standards case forecasts account for the 

increase in customer price and the decrease in operating costs caused by standards, forecasted 

shipments can deviate from the base case. The magnitude of the difference between the 

standards case and base case shipment forecasts depends on the estimated customer price 

increase as well as the operating cost savings due to the standard. Because the customer price 

tends to have a larger impact than operating cost on equipment purchase decisions, standards 

case forecasts typically show a drop in equipment shipments relative to the base case. 

The data required to develop sensitivities of shipments to customer price and operatingcost-savings were limited. Therefore, DOE modeled total standards case shipments forecasts as 

identical to base case shipments, but provided the option of defining scenarios (i.e., specified 

impacts to equipment shipments) rather than developing sensitivities to customer price or 

operating-cost-savings. 

2.10 NATIONAL IMPACT ANALYSIS 

The national impact analysis assesses the NPV of total customer LCC and NES. DOE 

determined both the NPV and NES for the performance levels considered for the equipment 

classes analyzed. To make the analysis more accessible and transparent to all stakeholders, DOE 

prepared an NES Spreadsheet Model in Microsoft Excel to forecast energy savings and the 

national economic costs and savings resulting from new standards. The NES Spreadsheet Model 

uses typical values for inputs or outputs (as opposed to probability distributions). To assess the 

impact of input uncertainty on the NES and NPV results, DOE can conduct sensitivity analyses 

for future analyses by running scenarios on input variables of interest to stakeholders. Chapter 

10 of the TSD describes DOE’s assessment of the aggregate economic impacts at the National 

level. 

2.10.1 National Energy Savings Analysis 

The inputs for the determination of NES for each class of commercial refrigeration 

equipment analyzed are (1) annual energy consumption per unit, (2) shipments, (3) equipment 

stock, (4) national energy consumption, and (5) site-to-source conversion factors. DOE 

calculated the national energy consumption by multiplying the number of units, or stock, of 

commercial refrigeration equipment (by vintage) by the unit energy consumption (also by 

vintage).c

 Then, DOE calculated national annual energy savings from the difference between 

c

 Vintage represents the age of the equipment. 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
national energy consumption in the base case (without new efficiency standards) and in each 

higher efficiency standard case. DOE estimated energy consumption and savings based on site 

energy, and converted the electricity consumption and savings to source energy. Cumulative 

energy savings are the sum of the annual NES, which DOE determined over specified time 

periods. 

The stock of commercial refrigeration equipment depends on annual shipments and the 

lifetime of the equipment. DOE conducted shipments projections under the base efficiency case 

and higher efficiency standards cases for a variety of possible equipment efficiency scenarios 

and equipment efficiency trends. DOE’s shipments model presumed that growth in commercial 

floor space for building types using commercial refrigeration equipment as well as necessary 

stock replacements drove shipments of new commercial refrigeration equipment. DOE’s 

shipments model did not assess changes in total CRE shipments as a function of standard level, 

either due to increases in first costs or decreases in energy consumption. 

2.10.2 Net Present Value Analysis 

The inputs for the determination of NPV are (1) total annual installed cost, (2) total 

annual operating cost savings, (3) discount factor, (4) present value of costs, and (5) present 

value of savings. DOE calculated net savings each year as the difference between total operating 

cost savings (including electricity, repair, and maintenance cost savings) and increases in total 

installed costs (including equipment price and installation cost). DOE calculated savings over 

the life of the equipment, accounting for differences in yearly energy rates. DOE calculated 

NPV as the difference between the present value of operating cost savings and the present value 

of increased total installed costs. DOE discounted future costs and savings to the present with a 

discount factor. 

DOE calculated increases in total installed costs as the product of the difference in the 

total installed cost between the base case and standards case (i.e., once the standards take effect) 

and the annual shipments in the standards case. Because costs of the more-efficient equipment 

bought in the standards case are higher than those of equipment bought in the base case, price 

increases appear as negative values in the NPV. 

DOE expressed operating cost savings as decreases in operating costs associated with the 

lower energy consumption of equipment bought in the standards case compared to the base 

efficiency case. Total operating cost savings are the product of savings per unit and the number 

of units of each vintage surviving in a particular year. 

2.10.3 Efficiency Scenarios and Trends 

Several of the inputs for determining NES (e.g., the annual energy consumption per unit) 

and NPV (e.g., the total annual installed cost and the total annual operating cost savings) depend 

on the efficiency of the equipment. Thus, DOE developed base case and standards case 

efficiency trends. The efficiency trends specify the annual historical and forecasted shipmentweighted average equipment efficiencies. 

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EERE-2006-BT-STD-0126 COMMENT 52.2 
DOE based historical shipment-weighted average efficiency trends for commercial 

refrigeration equipment on limited efficiency data. Once DOE established historical efficiency 

trends, it could determine future trends of equipment efficiency, and in turn, annual energy 

consumption by extrapolating from the historical trend. 

DOE based its standards case forecasts (i.e., forecasts of efficiency trends after standards 

take effect) on the use of a roll-up efficiency scenario and parallel growth trend. Under a roll-up 

scenario, all equipment at performance levels below a prospective standard are moved or rolled 

up to the minimum performance level allowed under the new standard. The distribution of 

equipment at higher efficiency standard levels is unaffected (i.e., this equipment remains at its 

pre-standard performance levels). The roll-up efficiency scenario dictates how DOE determined 

efficiency distributions in the first year a new standard takes effect, but does not define how 

equipment efficiency will be distributed in the future. Under the parallel growth trend, DOE 

assumes that the standards case efficiency trend parallels the base case efficiency trend. In other 

words, the initial jump in shipment-weighted efficiency that occurs when the standard first 

becomes effective is maintained throughout the forecast. 

2.11 LIFE-CYCLE COST SUB-GROUP ANALYSIS 

The LCC sub-group analysis evaluates economic impacts on virtually any group of 

customers. For the final rule, DOE evaluated the impacts on particular sub-groups in part by 

analyzing the LCC and PBP for these customers. 

DOE evaluated variations both in regional energy prices and use that might affect the 

NPV of an energy-efficiency standard to customer sub-groups. DOE sought estimates of the 

variability of each input parameter and consider this variability when calculating customer 

impacts. Variations in energy use for a particular equipment type or equipment class depend on 

factors such as climate, building type, and type of business. DOE performed sensitivity analyses 

to consider how differences in energy use will affect various sub-groups of customers. 

DOE determined the impact on customer sub-groups using the LCC spreadsheet model. 

The spreadsheet model for the LCC analysis can be used with different data inputs. The standard 

LCC analysis includes various commercial building types that use commercial refrigeration 

equipment. Moreover, DOE can analyze the LCC for any sub-group by using the LCC 

spreadsheet model and only sampling that sub-group. Details of this model are explained in the 

section describing the LCC and PBP analyses. 

DOE is particularly sensitive to increases in the customer price of more-efficient 

commercial refrigeration equipment. Such sub-groups as small businesses (i.e., those with low 

annual revenues) might not be able to afford a significant increase in the price of commercial 

refrigeration equipment. For these types of customers, increases in first costs for equipment 

could preclude the purchase of a new CRE unit. As a result, some customers might keep 

refrigeration equipment beyond its useful life. These older pieces of equipment are generally 

less efficient, and their efficiency may decline if kept beyond their useful life. Also, increases in 

first cost could preclude the purchase and use of equipment altogether, resulting in a potentially 

large loss of utility. 

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For this rulemaking, DOE identified independent small grocery and convenience stores as 

a commercial refrigeration equipment customer sub-group that could be disproportionately 

affected, and examined the impact of proposed standards on this group. DOE determined the 

impact on this commercial refrigeration equipment customer sub-group using the LCC 

spreadsheet model. DOE conducted the LCC and PBP analyses for commercial refrigeration 

equipment customers represented by the subgroup. 

2.12 MANUFACTURER IMPACT ANALYSIS 

The manufacturer impact analysis focuses on manufacturers of commercial refrigeration 

equipment. Potential impacts would include quantitative and qualitative financial effects that 

might result from new energy efficiency standards, and consequently lead to changes in 

manufacturing practices. DOE identified these potential impacts through interviews with 

manufacturers and other stakeholders. 

Previously, DOE did not report manufacturer impact analysis results during the advanced 

notice of proposed rulemaking (ANOPR) phase. However, DOE recently announced changes to 

the manufacturer impact analysis format through a report issued to Congress on January 31, 2006 

(as required by section 141 of the Energy Policy Act of 2005 (EPACT 2005)).d Under this new 

format, DOE collects, evaluates, and reports preliminary information and data in the ANOPR. 

Such preliminary information includes the anticipated conversion capital expenditures by 

efficiency level and the corresponding anticipated impacts on jobs. DOE solicits this 

information during the ANOPR engineering analysis manufacturer interviews. 

DOE conducts the manufacturer impact analysis in three phases. Phase one consists of 

preparing an industry characterization and identifying issues. Phase two addresses the broader 

industry where DOE would use the Government Regulatory Impact Model to perform an 

industry cash-flow analysis. Phase three involves interviewing manufacturers. DOE develops 

the questionnaire for Phase three in Phase two. At the beginning of Phase three, DOE 

interviewed manufacturers and adjusted the industry cash-flow analysis as appropriate. 

Thereafter, Phase three entailed additional cash-flow analyses of the different sub-groups that the 

rulemaking could affect. During Phase three, DOE also examined any additional impacts on 

competition, manufacturing capacity, direct employment, and the cumulative burden of other 

regulations affecting manufacturers. 

2.13 UTILITY IMPACT ANALYSIS 

The utility impact analysis will include an analysis of the impact of higher efficiency 

standards on electric and gas utilities. DOE adapted the National Energy Modeling System 

(NEMS) produced by the EIA for this analysis. NEMS (EIA 2005) is a large multi-sectoral, 

partial-equilibrium model of the U.S. energy sector that EIA has developed over the past decade, 

primarily for the purpose of preparing DOE’s AEO. In prior rulemakings, a variant of NEMS 

d

 This report, entitled “Energy Conservation Standards Activities,” is available on the DOE website at 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/congressional_report_013106.pdf. 

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(currently termed NEMS-BT, BT referring to the DOE’s Building Technologies Program) was 

developed to better address the specific impacts of an equipment efficiency standard. 

The NEMS produces a widely recognized baseline energy forecast for the United States 

through 2030, and is available to the public. The typical NEMS outputs include forecasts of 

electricity sales, price, and avoided electric generating capacity. The energy savings impacts 

from amended energy conservation standards will be modeled using NEMS-BT to generate 

forecasts that deviate from the AEO reference case. 

2.14 ENVIRONMENTAL ASSESSMENT 

The primary environmental effects of energy conservation standards for the commercial 

refrigeration equipment covered under this rulemaking will be reduced emissions resulting from 

reduced electrical energy consumption. The environmental assessment tracks the impact of 

possible standards on three energy-related emissions: CO2, NOx, and SO2. DOE based these 

calculations on the NEMS-BT modeling work used for the utility impact analysis. This approach 

has the advantage of examining the marginal impact of higher efficiency standards for the 

covered equipment on the utility generation mix and the subsequent environmental emissions. 

NEMS-BT tracks CO2 emissions with a detailed module that produces robust results 

because of its broad coverage of all sectors and inclusion of interactive effects. NEMS-BT also 

includes a module for SO2 allowance trading and forecasts SO2 allowance prices. The simulation 

of SO2 trading tends to imply that physical emissions effects will be zero. However, there is an 

SO2 benefit from conservation in the form of a lower allowance price and, if large enough to be 

calculable by NEMS, this value can be reported. NEMS-BT also has an algorithm for estimating 

NOx emissions from power generation. 

2.15 EMPLOYMENT IMPACT ANALYSIS 

The imposition of standards can affect employment both directly and indirectly. Direct 

employment impacts are changes in the number of employees at the plants that produce the 

covered equipment and at affiliated distribution and service companies resulting from the 

imposition of new standards. DOE evaluated direct employment impacts in the manufacturer 

impact analysis. 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 because of the imposition of standards. The combined direct and indirect 

employment impacts were investigated in the employment impact analysis using the Pacific 

Northwest National Laboratory’s “Impact of Sector Energy Technologies” (ImSET) model. The 

ImSET model was developed for DOE’s Office of Planning, Budget, and Analysis, and estimates 

the employment and income effects of energy-saving technologies in buildings, industry, and 

transportation. In comparison with simple economic multiplier approaches, ImSET allows for 

more complete and automated analysis of the economic impacts of energy conservation 

investments. 

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2.16 REGULATORY IMPACT ANALYSIS 

In the final rule stage, DOE prepared a regulatory impact analysis (RIA) pursuant to 

Executive Order 12866, “Regulatory Planning and Review,” 58 FR 51735, October 4, 1993, 

which is subject to review under the Executive Order by the Office of Information and 

Regulatory Affairs at the Office of Management and Budget. The RIA addressed the potential 

for non-regulatory approaches to supplant or augment energy conservation standards to improve 

the energy efficiency or reduce the energy consumption of the commercial refrigeration 

equipment covered under this rulemaking. 

DOE recognizes that voluntary or other non-regulatory efforts by manufacturers, utilities, 

and other interested parties can result in substantial improvements to energy efficiency or 

reductions in energy consumption. DOE considered the likely effects of non-regulatory 

initiatives on equipment energy use, consumer utility, and LCC. DOE based its assessment on 

the actual impacts of any such initiatives to date, but also considered potential impacts that any 

existing initiative might have in the future. 

2.17 DEPARTMENT OF JUSTICE REVIEW 

Section 325(o)(2)(B)(i)(V) of the Energy Policy and Conservation Act (EPCA) states that 

before the Secretary of Energy may prescribe a new or amended energy conservation standard, 

the Secretary shall ask the U.S. Attorney General to make a determination of “the impact of any 

lessening of competition...that is likely to result from the imposition of the standard.” (42 

U.S.C. 6295) Pursuant to this requirement, DOE solicited the views of the DOJ on any lessening 

of competition likely to result from the imposition of a proposed standard. DOE gave the views 

provided full consideration in assessing economic justification of a proposed standard. In 

addition, DOE consulted with DOJ at earlier stages in the standards development process to 

obtain preliminary views on competitive impacts. 

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