EXECUTIVE SUMMARY 

TABLE OF CONTENTS 

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES .......................................... 1
 

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSIS AND THE TECHNICAL
 

SUPPORT DOCUMENT..................................................................................................... 3
 

ES.3 KEY RESULTS OF THE ANALYSIS................................................................................ 4
 

ES.3.1 Market and Technology Assessment ...................................................................... 4
 

ES.3.2 Screening Analysis.................................................................................................. 6
 

ES.3.3 Engineering Analysis.............................................................................................. 6
 

ES.3.3.1 Equipment Classes Analyzed................................................................... 6
 

ES.3.3.2 Manufacturing Cost Assessment.............................................................. 7
 

ES.3.4 Markups to Determine Equipment Price ................................................................. 9
 

ES.3.5 Energy Use Characterization ................................................................................ 10
 

ES.3.6 Life-Cycle Cost and Payback Period Analyses .................................................... 13
 

ES.3.7 Shipments Analysis ............................................................................................... 17
 

ES.3.8 National Impact Analysis...................................................................................... 19
 

ES.3.8.1 National Energy Savings........................................................................ 20
 

ES.3.8.2 Net Present Value .................................................................................. 22
 

ES.3.9 Preliminary Manufacturer Impact Analysis.......................................................... 24
 

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT .............................................. 24
 

ES.4.1 Separate Standards................................................................................................ 24
 

ES.4.2 Responsibility for Compliance ............................................................................. 25
 

ES.4.3 Equipment Classes................................................................................................ 25
 

ES.4.4 Markups Analysis ................................................................................................. 25
 

ES.4.5 Maintenance and Repair Costs.............................................................................. 25
 

ES.4.6 Manufacturer Impact ............................................................................................. 26
 

ES.4.7 General Analytical Assumptions .......................................................................... 26
 

LIST OF TABLES 

Table ES.3.1 Equipment Classes for Walk-in Coolers and Walk-in Freezers (Envelope)........... 5
 

Table ES.3.2 Equipment Classes for Walk-in Coolers and Walk-in Freezers (Refrigeration 

Table ES.3.6 Manufacturer Cost Estimates for a Large Dedicated Medium-Temperature 

Table ES.3.7 MPC and MSP per Capacity Estimates for a Large Dedicated MediumTable ES.3.9 Baseline Markups by Distribution Channel and Overall Weighted Average 

Markup, Including the Weighted Average Sales Tax Multiplier for Supermarkets
 

System) ................................................................................................................... 5
 

Table ES.3.3 Sizes Analyzed: Envelope ....................................................................................... 7
 

Table ES.3.4 Sizes Analyzed: Refrigeration System .................................................................... 7
 

Table ES.1.1 MPC and MSP Estimates for a Medium Non-Display Cooler ............................... 8
 

Outdoor Refrigeration System ................................................................................ 8
 

Temperature Outdoor Refrigeration System........................................................... 9
 

Table ES.3.8. Distribution Channel Shares ................................................................................... 9
 

............................................................................................................................... 10
 

ES-i 
 

Table ES.3.10 Incremental Markups by Distribution Channel and Overall Weighted Average 

Markup, Including the Weighted Average Sales Tax Multiplier .......................... 10
 

Table ES.3.11 Annual Energy Consumption Estimates for a Medium Non-Display Cooler
 

Table ES.3.12 Annual Energy Consumption Estimates for a Medium Storage Cooler Matched 

(kWh) .................................................................................................................... 12
 

with a Dedicated Medium-Temperature Outdoor System (kWh)......................... 13
 

Table ES.3.13 Lifetimes for WICF Equipment ............................................................................ 14
 

Table ES.3.14 Summary of Maximum LCC Savings for All Matched Pairs of WICF Envelopes 

and Refrigeration Systems ................................................................................... 15
 

Table ES.3.15 LCC Savings for a Medium Non-Display Cooler with a Large Dedicated, 

Table ES.3.16 PBP for a Medium Non-Display Cooler with a Large Dedicated, MediumMedium-Temperature Outdoor Refrigeration System ($) .................................... 16
 

Temperature Outdoor Refrigeration System......................................................... 17
 

Table ES.3.17 Projected Shipments of WICF Envelopes ............................................................. 19
 

Table ES.3.18 Projected Shipments of WICF Refrigeration Systems ......................................... 19
 

Table ES.3.19 Maximum Energy Savings for Which Net Present Value of Savings >0 at a 7­

Percent Discount Rate and Corresponding WICF Envelope and Refrigeration 

Efficiency Levels .................................................................................................. 21
 

Table ES.3.20 National Energy Savings by Efficiency Level for Example Product Class 

Combination: A Medium Non-Display Cooler with a Large Dedicated, MediumTemperature Outdoor Refrigeration System (quads) ............................................ 22
 

Table ES.3.21 Net Present Value of Energy Savings at Maximum Level of Energy Savings for 

Which Net Present Value of Savings > 0 at a 7-Percent Discount Rate and 

Corresponding WICF Envelope and Refrigeration Efficiency Levels ............... 23
 

LIST OF FIGURES 

Figure ES.1.1 Flow Diagram of Analyses for the Walk-in Coolers and Walk-in Freezers 

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

Figure ES.3.1 Projected Shipments of WICF Envelope Systems................................................ 18
 

Figure ES.3.2 Projected Shipments of WICF Refrigeration Systems ......................................... 18
 

ES-ii 
 

EXECUTIVE SUMMARY 

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES 

Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to 

establish energy conservation standards that achieve the maximum improvement in energy 

efficiency that is technologically feasible and economically justified. This executive summary 

provides an overview of the activities associated with the preliminary analysis that DOE 

conducted in consideration of new energy conservation standards for walk-in coolers and 

freezers. The executive summary describes the preliminary analysis activities and summarizes 

key results from DOE’s analyses. Additionally, the executive summary delineates issues 

identified during the analyses about which DOE seeks comments from interested parties. These 

issues are highlighted in the public meeting presentation and are further discussed in chapter 2 of 

the preliminary technical support document (TSD). 

Figure ES.1.1 presents a summary of the analytical components of the standards-setting 

process and illustrates how key results are generated. The focal point of the figure is the center 

column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how 

the analyses fit into the process and how they relate to each other. Key inputs are the types of 

data and other information that the analyses require. Some key information is obtained from 

public databases; DOE collects other inputs from interested parties or persons having special 

knowledge and expertise. Key outputs are analytical results that feed directly into the standardssetting process. The issues on which DOE seeks comment from interested parties derive from the 

key results that are generated by the preliminary analysis. Arrows connecting analyses show the 

types of information that feed from one analysis to another. 

ES-1 
 

ES-2 

Analysis 

Notice of Proposed Rulemaking (NOPR) 

Market and Technology 

Assessment 

Screening Analysis 

Engineering Analysis 

Markups for 

Product Price 

Determination Life-Cycle Cost and 

Payback Period

Analysis 

National Impact 

Analysis 

Energy Use 

Revise Preliminary 

Analysis 

Life-Cycle Cost 

Sub-Group Analysis 

Manufacturer Impact 

Analysis 

Shipments 

Analysis 

Employment Impact 

Analysis 

Revise Analyses 

• Product Classes 

• Technology Options 

• Industry Cash Flow 

• Sub-Group Cash-Flow 

• Direct Employment Impacts 

• Competitive Impacts 

• Cumulative Regulatory Burden 

• Cost-Efficiency Relationship 

• Life-Cycle Costs

• Payback Periods 

• National Energy Savings 

• Net Present Values 

• National Employment Impacts 

• Revised Results 

• Market Segmentation 

• Non-Regulatory Programs 

Framework Document 

• Energy Prices

• Installation Costs 

• Maintenance & Repair Costs 

• Backcast and Forecast 

• Market Saturation 

• Stakeholder Comments 

• Demographics 

• Emission Rates 

• National Energy Savings 

• Stakeholder Comments 

• Identify Firms/Products 

• Historical Shipments 

• Manufacturer Prices 

• Average Costs 

• Manufacturer Financial Data 

Design Options 

Product Classes 

Retail Prices 

Design Energy 

Preliminary Analysis 

• Efficiency/Performance 

• Manufacturing Cost 

Candidate 

Standard 

Levels 

Environmental 

Assessment 

Regulatory Impact 

Analysis 

Technology Options 

• Emission Estimates 

• Utility Load Factors 

• National Energy Savings 

• Non-Regulatory

Alternatives 

• Design Options 

• Energy Price Forecasts

• Site-to-Source Factors 

• Energy-Efficiency Levels 

Direct Employment 

Impacts 

• National Energy Savings 

• National Product Costs 

• National Operating Costs 

• Utility Impacts 

• Life-Cycle Costs 

• Payback Periods 

• Installation 

Costs 

• Maint Costs 

• Repair Costs 

• UEC 

• Energy 

Prices 

• Annual Energy Use (UEC) 

Preliminary 

Manufacturer Impact 

Analysis 

• Manufacturer Prices 

• Average Costs 

• Conversion Capital Expenditures 

• Direct Employment Impacts 

• National Energy Savings 

• Net Present Values 

• Trial Standard Levels (TSLs) 

TSLs 

• Product Prototypes 

Energy-Efficiency 

Levels 

• Department of Justice Review 

Figure ES.1.1 Flow Diagram of Analyses for the Walk-in Coolers and Walk-in 

Freezers Rulemaking Process 
 

 

 

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSIS AND THE TECHNICAL 

SUPPORT DOCUMENT 

For the preliminary analysis, DOE publishes a notice of public meeting (NOPM) in the 

Federal Register, which announces the availability of the preliminary TSD, the date and place of 

the public meeting, and presentation materials interested parties may review before the public 

meeting. In addition, the NOPM highlights the major analyses DOE developed in the preliminary 

analysis. 

The preliminary TSD describes each preliminary analysis in detail, providing detailed 

descriptions of inputs, sources, methodologies, and results. Chapter 2 of the preliminary TSD 

provides an overview of each preliminary analysis, the comments received in response to the 

analytical approaches DOE described in the framework document, and DOE’s responses to those 

comments. The following chapters of the preliminary TSD address the preliminary analysis 

performed by DOE. 

A market and technology assessment (MTA) characterizes the relevant equipment 

markets and technology options, including prototype designs (chapter 3 of the preliminary TSD). 

A screening analysis reviews each technology option to determine whether it is 

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

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

safety (chapter 4 of the preliminary TSD). 

An engineering analysis develops cost-efficiency relationships that show a 

manufacturer’s cost of achieving increased efficiency. DOE uses manufacturer markups to 

convert manufacturer production cost (MPC) to manufacturer selling price (MSP) (chapter 5 of 

the preliminary TSD). 

A markups analysis converts the manufacturer costs derived from the engineering 

analysis to consumer equipment prices (chapter 6 of the preliminary TSD). 

An energy use analysis determines the annual energy use in the field of the considered 

equipment (chapter 7 of the preliminary TSD). 

Life-cycle cost (LCC) and payback period (PBP) analyses calculate, at the consumer 

level, the discounted savings in operating costs throughout the estimated average life of the 

covered equipment, compared to any increase in the equipment’s installed cost likely to result 

directly from the imposition of a given standard (chapter 8 of the preliminary TSD). 

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

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

consumer costs and savings, and future manufacturer cash flows (chapter 9 of the preliminary 

TSD). 

ES-3 
 

 

 

A national impact analysis (NIA) assesses the cumulative national energy savings (NES) 

from standards and the NPV of consumer costs and savings associated with standards at different 

efficiency levels (chapter 10 of the preliminary TSD). 

A preliminary manufacturer impact analysis (MIA) assesses the potential impacts of 

energy conservation standards on manufacturers, such as effects on expenditures for capital 

conversion, marketing costs, shipments, and research and development costs (chapter 12 of the 

preliminary TSD). 

The remaining chapters of the preliminary TSD address the analyses to be performed for 

the NOPR stage: 

A life-cycle cost analysis for subgroups evaluates the effects of energy conservation 

standards on various national subgroups of the population (chapter 11 of the preliminary 

TSD). 

A utility impact analysis examines impacts of energy conservation standards on the
 

generation capacity of electric utilities (chapter 13 of the preliminary TSD). 

An employment impact analysis examines the effects of energy conservation standards on 

national employment (chapter 14 of the preliminary TSD). 

An environmental assessment examines the effects of energy conservation standards on 

various airborne emissions (chapter 15 of the preliminary TSD). 

A regulatory impact analysis examines the national impacts of non-regulatory alternatives to 

mandatory energy conservation standards (chapter 16 of the preliminary TSD). 

ES.3 KEY RESULTS OF THE ANALYSIS 

The following sections describe in detail the key analyses DOE performed in support of 

the preliminary TSD. 

ES.3.1 Market and Technology Assessment 

When initiating an analysis of potential energy efficiency standards for commercial 

equipment, DOE develops information for the equipment concerned based on the present and 

past industry structure and market characteristics. This activity assesses industries and equipment 

both quantitatively and qualitatively, based on publicly available information. 

When evaluating and establishing energy conservation standards, DOE generally divides 

covered equipment into equipment classes by the type of energy used or by capacity or other 

performance-related features that affect efficiency, considering such factors as utility to the 

consumer. Different energy conservation standards may apply to different equipment classes. (42 

ES-4 
 

U.S.C. 6295(q)) Table ES.3.1 and Table ES.3.2 list the equipment classes being considered in 

this rulemaking. 

Table ES.3.1 Equipment Classes for Walk-in Coolers and Walk-in Freezers (Envelope) 

Equipment Class 

Non-Display Cooler 

Non-Display Freezer 

Display Cooler 

Display Freezer 

Table ES.3.2 Equipment Classes for Walk-in Coolers and Walk-in Freezers (Refrigeration 

System) 

Equipment Class 

Dedicated Medium-Temperature Indoors 

Dedicated Low-Temperature Indoors 

Dedicated Medium-Temperature Outdoors 

Dedicated Low-Temperature Outdoors 

Unit Cooler for Multiplex System Medium Temperature 

Unit Cooler for Multiplex System Low Temperature 

For the walk-in coolers and freezers addressed by this rulemaking, DOE examined (1) 

manufacturer market share and characteristics, (2) existing regulatory and non-regulatory 

initiatives for improving equipment efficiency, and (3) trends in equipment characteristics and 

retail markets. This information provided data and resource material throughout the analysis. 

DOE reviewed literature and interviewed manufacturers to develop an overall 

understanding of the walk-in cooler and freezer industry in the United States. Chapter 3 of the 

preliminary TSD describes the market analysis and resulting information. 

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

designs to determine which technologies and combinations of technologies manufacturers use to 

attain higher performance levels. In consultation with interested parties, DOE develops a list of 

technologies to be considered. 

DOE developed its list of technologies for walk-in coolers and freezers after examining 

various documents (e.g., trade publications, technical papers, and manufacturer literature) and 

consulting with manufacturers of components and systems. Because existing equipment contains 

many technologies for improving equipment efficiency, equipment literature and direct 

examination provided additional information. 

ES-5 
 

 

 

ES.3.2 Screening Analysis 

In the screening analysis, DOE, in consultation with interested parties, examined the 

technologies identified in the market and technology assessment. First, DOE removed from the 

list those technologies for which the energy consumption could not be adequately measured 

using the relevant DOE test procedure. Second, DOE evaluated the technologies using the four 

screening criteria: Technologies are removed from further consideration if they (1) are not 

technologically feasible; (2) are not practicable to manufacture, install, and service; (3) have an 

adverse impact on equipment utility or availability; and/or (4) have adverse impacts on health 

and safety. In the subsequent engineering analysis, DOE further examines the technology options 

that it did not remove from consideration in the screening analysis. 

ES.3.3 Engineering Analysis 

The engineering analysis (chapter 5 of the preliminary TSD) establishes the relationship 

between the cost of manufacturing walk-in coolers and freezers and their efficiency. This 

relationship serves as the basis for calculating costs and benefits of modified equipment designs 

for consumers, manufacturers, and the Nation. Chapter 5 of the preliminary TSD describes the 

equipment classes that DOE analyzed, the representative baseline units, the efficiency levels 

DOE considered, the methodology that DOE used to develop the manufacturing production cost 

model, and the cost-efficiency results. 

ES.3.3.1 Equipment Classes Analyzed 

The engineering analysis for walk-in envelopes directly analyzed the four primary walkin envelope classes: (1) non-display coolers; (2) non-display freezers; (3) display coolers; and (4) 

display freezers. For all envelope equipment classes, DOE used three different class sizes (small, 

medium, and large) in its engineering analysis. 

The engineering analysis for walk-in refrigeration systems analyzed the six primary 

walk-in refrigeration classes: (1) dedicated system medium-temperature indoor systems; (2) 

dedicated system low-temperature indoor systems; (3) dedicated system medium-temperature 

outdoor systems; (4) dedicated system low-temperature outdoor systems; (5) mediumtemperature unit coolers connected to a Multiplex System; and (6) low-temperature unit coolers 

connected to a Multiplex System. Two sizes were analyzed for each refrigeration equipment 

class. 

Table ES.3.3 and Table ES.3.4 show the class sizes for envelope and refrigeration 

system, respectively. Chapter 5 of the preliminary TSD includes additional details on the 

representative equipment classes and the cost-efficiency curves developed as part of the 

engineering analysis. 

ES-6 
 

 

 

Table ES.3.3 Sizes Analyzed: Envelope 

Dimensions [length x width x height, ft] 

Class Small Medium Large 

Non-Display Cooler 10’ × 8’ × 7.6’ 12’ × 20’ × 9.5’ 25’ × 30’ × 12’ 

Non-Display Freezer 8’ × 6’ × 7.6’ 9’ × 20’ × 9.5’ 25’ × 20’ × 12’ 

Display Cooler 6’ × 6’ × 6.6’ 10.2’ × 7’ × 7.6’ 80’ × 15’ × 7.6’ 

Display Freezer 6’ × 6’ × 6.6’ 10.2’ × 7’ × 7.6’ 80’ × 15’ × 7.6’ 

Table ES.3.4 Sizes Analyzed: Refrigeration System 

Nominal Capacity [Btu/hour] 

Class Small Large 

Dedicated Condensing Medium Temperature Indoor System 12,000 24,000 

Dedicated Condensing Low Temperature Indoor System 6,000 12,000 

Dedicated Condensing Medium Temperature Indoor System 15,000 24,000 

Dedicated Condensing Low Temperature Indoor System 6,000 12,000 

Multiplex Condensing Medium Temperature System 9,000 30,000 

Multiplex Condensing Low Temperature System 6,000 30,000 

ES.3.3.2 Manufacturing Cost Assessment 

DOE estimated the manufacturing costs associated with a decrease in energy 

consumption for all of the equipment classes analyzed. The assessment method involved 

information gained during manufacturer site visits, manufacturer interviews, previous experience 

with similar equipment manufacturing methods and a detailed cost model that utilizes Design 

For Manufacture/Design For Assembly (DFM/DFA) methodology to evaluate labor costs. Using 

aggregated manufacturer data, DOE developed a detailed model to estimate the manufacturer 

production cost (MPC) at various efficiency levels. DOE obtained additional input from 

interested parties on the manufacturing cost model inputs. DOE also estimated the manufacturer 

markup and the manufacturer selling price (MSP), which includes the outbound shipping cost 

(the cost of shipping the equipment from the manufacturer to the distributor). DOE calculated the 

MSP as the product of the MPC and the manufacturer markup, plus the outbound shipping cost. 

Chapter 5 of the preliminary TSD includes information on the inputs used to determine the 

manufacturing cost, including material, labor, and overhead costs. Chapter 5 also includes 

information on the various components and features incorporated into designs for walk-in 

coolers and walk-in freezers. 

DOE’s engineering analysis produced cost-energy consumption curves for the four walkin envelope equipment classes and the six walk-in refrigeration system equipment classes. The 

cost-energy consumption curves are described by the energy consumption levels that DOE 

analyzed, and the increase in MPC and MSP required to improve baseline-energy consumption 

equipment to each of the considered levels. Table ES.3.5 and Table ES.3.6 present the MPC and 

MSP results for one example envelope and refrigeration system, respectively. Results for the 

remaining units analyzed can be found in Chapter 5 of the preliminary TSD. 

In the remainder of this document, DOE presents complete results for these example 

units only. Complete results for all other units are contained in the relevant chapters of the 

preliminary TSD. 

ES-7 
 

 

Table ES.3.5 MPC and MSP Estimates for a Medium Non-Display Cooler 

Efficiency Levels Manufacturer 

Production Cost ($) 

Manufacturer Selling 

Price ($) 

0 $ 4,164 $ 6,476 

1 $ 4,527 $ 6,981 

2 $ 4,561 $ 7,028 

3 $ 4,576 $ 7,049 

4 $ 5,330 $ 8,291 

5 $ 5,498 $ 8,551 

6 $ 5,750 $ 8,941 

7 $ 5,896 $ 9,159 

8 $ 6,339 $ 9,841 

9 $ 6,782 $ 10,523 

10 $ 8,782 $ 13,303 

11 $ 13,381 $ 19,361 

12 $ 15,961 $ 22,947 

13† $ 17,285 $ 24,788 

14 $ 17,285 $ 24,788 

15* $ 17,285 $ 24,788 

† The results for levels 13, 14, and 15 are identical for this and other analyses because for this analysis point, only 

13 levels were analyzed. For another size in the class, there were 15 efficiency levels, so DOE maintained the data in 

this format for consistency. 

* Max-tech efficiency level 

Table ES.3.6 Manufacturer Cost Estimates for a Large Dedicated Medium-Temperature 

Outdoor Refrigeration System 

Efficiency Levels Manufacturer 

Production Cost ($) 

Manufacturer Selling 

Price ($) 

0 $ 2,689 $ 3,801 

1 $ 2,725 $ 3,856 

2 $ 2,999 $ 4,237 

3 $ 3,190 $ 4,530 

4 $ 3,390 $ 4,808 

5 $ 3,690 $ 5,225 

6 $ 3,833 $ 5,423 

7 $ 3,869 $ 5,474 

8* $ 4,009 $ 5,669 

* Max-tech efficiency level 

For refrigeration systems, certain efficiency levels incorporate design options that 

increase the capacity of the system. Thus, an increase in the manufacturer price could be 

attributed to either a gain in efficiency or a gain in capacity. To distinguish the two effects, DOE 

divided the price by the net capacity as determined from the proposed test procedure at each 

efficiency level. The results for this example refrigeration system are shown in Table ES.3.7. 

One notable observation is that for a few efficiency levels above the baseline, the estimated costs 

appear to decrease. This indicates that for these efficiency levels, although the absolute price of 

the unit increases as shown in Table ES.3.6, the capacity also increases at a faster rate, so the 

price per capacity decreases. To capture this effect, DOE used the price per capacity values in the 

downstream analyses. 

ES-8 
 

 

 

 

 

 

Table ES.3.7 MPC and MSP per Capacity Estimates for a Large Dedicated MediumTemperature Outdoor Refrigeration System 

Efficiency Levels MPC per Capacity 

($/(kBtu/h)) 

MSP per Capacity 

($/(kBtu/h)) 

0 $ 128 $ 181 

1 $ 124 $ 175 

2 $ 117 $ 165 

3 $ 113 $ 160 

4 $ 120 $ 170 

5 $ 130 $ 185 

6 $ 135 $ 192 

7 $ 137 $ 193 

8* $ 141 $ 199 

*Max-tech efficiency level 

ES.3.4 Markups to Determine Equipment Price 

The markups analysis (chapter 6 of the preliminary TSD) develops appropriate markups 

in the distribution chain to convert the estimates of manufacturer cost derived in the engineering 

analysis to consumer prices. In developing markups, DOE determined the distribution channels 

for walk-in coolers and walk-in freezers (WICF) equipment and the markup associated with each 

party in the distribution channel. 

The cost to the customer depends on how the customer purchases the equipment. In the 

framework document, DOE defined three distribution channels described below: 

Manufacturer Æ Customer (National Account) (Channel 1) 

Manufacturer Æ Distributor Æ Customer (Channel 2) 

Manufacturer Æ Distributor Æ Mechanical Contractor Æ Customer (Channel 3) 

DOE estimated markups taken by wholesalers and mechanical contractors, or 

alternatively, by national firms selling direct to ultimate consumer/users, along with sales taxes. 

Based on industry comments, the proportions of sales in each customer class were different for 

food sales customers (grocery and convenience stores) than for food service (restaurants). These 

proportions are shown in Table ES.3.8. 

Table ES.3.8. Distribution Channel Shares 

Dominant Market Segment Multiplex system 

All National Account Distributor Contractor 

85% 10% 5% 

Dedicated Equipment 

Convenience Stores (15%) National Account Distributor Contractor 

30% 35% 35% 

Commercial and E-Commerce Reseller Distributor Contractor 

Institutional Food Service 

(85%) 5% 80% 15% 

ES-9 
 

 

 

 

 

DOE calculated separate markups for baseline products (baseline markups) and for the 

cost increase associated with improvements required to produce more efficient products 

(incremental markups). 

Table ES.3.9 and Table ES.3.10 summarize the baseline markups and incremental markups 

developed for WICF equipment. The markups shown in this table reflect national average values 

for the given markup. In their inclusion in the subsequent LCC analysis, regional markup 

multipliers were also developed and were used to capture regional variation in mechanical 

contractor markups as well as state-to-state differences in sales taxes. Also in the LCC analysis, 

the relative shipments to new construction and to the replacement market vary by equipment 

class resulting in some slight differences between sales-weighted average baseline and average 

incremental markups by product class. For additional information, see chapter 2 of the 

preliminary TSD. 

Table ES.3.9 Baseline Markups by Distribution Channel and Overall Weighted Average 

Markup, Including the Weighted Average Sales Tax Multiplier for Supermarkets 

Wholesale 

Distributor 

Mechanical 

Contractor 

(Includes Wholesale 

Distributor) 

National Account 

(Mfg Direct) 

Overall Weighted Average 

Markup 

Multiplex 

Equipment 

Dedicated 

Equipment 

Distributor(s) 

Markup 1.453 2.209 1.226 1.408 1.828 

Sales Tax 

Multiplier 1.070 1.070 1.070 1.070 1.070 

Overall 

Markup 1.555 2.364 1.311 1.506 1.955 

Table ES.3.10 Incremental Markups by Distribution Channel and Overall Weighted 

Average Markup, Including the Weighted Average Sales Tax Multiplier 

Wholesale 

Distributor 

Mechanical 

Contractor 

(Includes 

Wholesale 

Distributor) 

National Account 

(Mfg Direct) 

Overall Weighted Average 

Markup 

Multiplex 

Equipment 

Dedicated 

Equipment 

Distributor(s) 

Markup 1.118 1.375 1.059 1.115 1.252 

Sales Tax 

Multiplier 1.070 1.070 1.070 1.070 1.070 

Overall 

Markup 1.196 1.471 1.133 1.193 1.340 

ES.3.5 Energy Use Characterization 

The energy use characterization provides the basis for developing the energy savings 

from using higher-efficiency WICF equipment. The energy savings results are incorporated in 

the LCC and other subsequent analyses. The proposed DOE test procedure for the walk-in 

system provides separate testing methodologies for the envelope and the refrigeration system. 

ES-10 
 

 

 

 

For the envelope, the proposed test procedure determines the daily energy consumption of the 

envelope under indoor conditions using a nominal EER. For the refrigeration system, the 

proposed DOE test procedure provides for multiple measurements of the refrigeration capacity 

and energy consumption under specified test conditions. The two separate test procedures 

provide standardized energy efficiency metrics for the envelope and the refrigeration system 

which, when combined, serve as the basis for comparing the energy consumptions of different 

combinations of the envelope and the refrigeration system. The proposed test procedure 

methodology has been used to provide standardized estimates of the energy consumptions for all 

possible combinations of the analyzed WICF envelope design options for a given envelope 

product class matched with each considered design option of a given refrigeration system class. 

For both the envelopes and the refrigeration systems, DOE considered multiple analysis points at 

different equipment capacity levels in each product class. DOE uses the kWh/day rating to 

establish an estimate of efficiency for different combinations of equipment designs considered. 

Downstream analyses consider all design options of the same combinations of the envelope and 

the refrigeration system. 

Chapter 7 of the preliminary TSD provides more details on the methods, data, and 

assumptions used for developing the energy consumptions of the combined systems. 

Table ES.3.11 presents the average annual energy use for the example envelope class 

(i.e., a medium non-display cooler) at each considered energy efficiency level operating with all 

three refrigeration system classes at the baseline efficiency level. Table ES.3.12 presents the 

average annual energy usage of a cooler system consisting of the combination of the two 

example classes previously discussed: a medium non-display cooler and a dedicated outdoor 

condensing system at all efficiency levels of each. The highest energy savings potential can be 

observed for this system at the max-tech efficiency level. 

Annual energy consumption data for all other equipment classes are provided in chapter 7 

of the preliminary TSD. 

ES-11 
 

 

 

 

Table ES.3.11 Annual Energy Consumption Estimates for a Medium Non-Display Cooler 

(kWh) 

Type Non-Display Coolers (Medium) 

Length × Width × 

Height (ft) 12′ × 20′ × 9.5′

Refrigeration 

System 

Dedicated Indoor 

(Medium Temperature) 

Dedicated Outdoor 

(Medium Temperature) 

Multiplex 

(Medium Temperature) 

Envelope Efficiency 

Levels 

0 17,112 15,547 9,598 

1 10,796 9,813 6,077 

2 10,664 9,687 5,972 

3 10,627 9,654 5,952 

4 8,896 8,082 4,987 

5 8,620 7,832 4,833 

6 8,287 7,529 4,647 

7 8,141 7,396 4,566 

8 7,729 7,022 4,336 

9 7,432 6,753 4,171 

10 6,745 6,129 3,787 

11 6,218 5,650 3,494 

12 5,948 5,406 3,343 

13 5,819 5,289 3,272 

14 5,819 5,289 3,272 

15* 5,819 5,289 3,272 

* Max-tech efficiency level 

ES-12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table ES.3.12 Annual Energy Consumption Estimates for a Medium Storage Cooler 

Matched with a Dedicated Medium-Temperature Outdoor System (kWh) 

Type Non-Display Cooler (Medium)/Dedicated Medium-Temperature Outdoor Systems 

Length × Width × 

Height (ft) 12′ × 20′ × 9.5′

Refrigeration System 

Efficiency Levels 0 1 2 3 4 5 6 7 8* 

Envelope Efficiency 

Levels 

0 15,547 14,887 13,341 11,173 8,146 5,979 5,200 5,108 4,882 

1 9,813 9,398 8,428 7,066 5,165 3,804 3,315 3,257 3,115 

2 9,687 9,274 8,309 6,956 5,066 3,713 3,226 3,169 3,028 

3 9,654 9,243 8,281 6,932 5,049 3,700 3,215 3,158 3,017 

4 8,082 7,738 6,934 5,806 4,231 3,104 2,698 2,651 2,533 

5 7,832 7,499 6,719 5,627 4,101 3,009 2,616 2,570 2,456 

6 7,529 7,209 6,460 5,410 3,944 2,894 2,516 2,472 2,363 

7 7,396 7,082 6,346 5,315 3,875 2,844 2,473 2,429 2,322 

8 7,022 6,724 6,026 5,047 3,681 2,702 2,350 2,309 2,207 

9 6,753 6,466 5,795 4,855 3,541 2,600 2,261 2,222 2,124 

10 6,129 5,869 5,260 4,407 3,216 2,363 2,056 2,020 1,931 

11 5,650 5,411 4,850 4,065 2,967 2,181 1,899 1,866 1,784 

12 5,406 5,177 4,641 3,889 2,840 2,089 1,818 1,787 1,708 

13 5,289 5,065 4,541 3,806 2,779 2,044 1,780 1,749 1,672 

14 5,289 5,065 4,541 3,806 2,779 2,044 1,780 1,749 1,672 

15* 5,289 5,065 4,541 3,806 2,779 2,044 1,780 1,749 1,672 

* Max-tech efficiency level 

ES.3.6 Life-Cycle Cost and Payback Period Analyses 

New energy conservation standards for WICF equipment would result in changes in 

consumer operating expenses—usually a decrease—and changes in consumer price—usually an 

increase. DOE analyzed the net effect of revised standards on consumers by evaluating the LCC 

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

costs derived from the energy use characterization. Inputs to the LCC calculation included the 

installed cost to the consumer (purchase price plus installation cost), operating costs (energy 

expenses, repair, and maintenance), the lifetime of the equipment, and a discount rate. 

Because the installed cost of a product typically increases while operating cost typically 

decreases in response to new standards, there is a point in the life of products having higherthan-baseline efficiency when the cumulative net operating-cost benefit (in dollars) since the 

time of purchase is equal to the incremental first cost of purchasing the higher-efficiency 

product. The length of time required for products to reach this cost-equivalence point is known 

as the payback period (PBP). 

DOE conducted the LCC and PBP analyses using values that reflect energy consumption 

in the field. DOE identified several input values for estimating the LCC, including: retail prices; 

energy prices; discount rates; and equipment lifetimes. DOE used EIA’s energy price data to 

determine prices for electricity in 2009, and used projections of these energy prices from the 

preliminary December 2009 release of EIA’s Annual Energy Outlook 2010 to estimate future 

ES-13 
 

energy prices. DOE developed discount rates from estimates of the finance cost for consumers 

and commercial businesses that purchase walk-ins. 

Because the basis for the lifetime estimates in the literature for WICF equipment is 

uncertain, DOE used data sources to estimate the distribution of WICF lifetimes in the field. The 

resulting survival function, which DOE assumed has the form of a cumulative Weibull 

distribution, provides an average and median appliance lifetime. Table ES.3.13 shows the 

average and maximum lifetimes for WICF envelopes and refrigeration systems. 

Table ES.3.13 Lifetimes for WICF Equipment 

Equipment Lifetimes (years) 

Parameter WICF Envelope Refrigeration Equipment 

Average Lifetime 16 7 

Maximum Lifetime 26 12 

Estimating future LCC for more efficient WICF equipment is complicated because 

virtually no data are available on the distribution of efficiencies for current shipments of WICF 

envelopes and refrigeration systems. DOE’s LCC analysis for this Preliminary Analysis 

considered the projected distribution of product efficiencies that consumers purchase under a 

base case (i.e., the case without new energy efficiency standards) to be the least efficient units 

for which engineering analysis was performed. DOE refers to this distribution of product of 

efficiencies as a base-case efficiency distribution. 

Table ES.3.14 summarizes the levels of efficiency for envelopes and dedicated 

refrigeration systems that result in maximum LCC savings. For each envelope and refrigeration 

system pair, the cell shows the maximum LCC savings and the efficiency level of envelope and 

refrigeration. For example, the first cell shows that LCC savings for a small non-display cooler 

are $7,335 per year and that this is achieved with a level 5 non-display cooler using a level 6 

medium-temperature dedicated condensing indoor refrigeration system. The highest LCC 

savings typically occur when the efficiency levels of the envelope and refrigeration systems are 

nearly the same: for example, a very efficient envelope and a very inefficient refrigeration 

system may not pair as an LCC-maximizing system. However, in many cases, LCC is 

maximized at the highest possible efficiency level for the refrigeration system, but not for the 

envelope. 

ES-14 
 

Table ES.3.14 Summary of Maximum LCC Savings for All Matched Pairs of WICF 

Envelopes and Refrigeration Systems 

Envelope 

Maximum LCC Savings ($) and Matched Efficiency Levels for Envelope and Refrigeration 

Unit (a,b) 

Refrigeration System* 

Dedicated 

Indoor 

Small 

Dedicated 

Indoor 

Large 

Dedicated 

Outdoor 

Small 

Dedicated 

Outdoor 

Large 

Multiplex 

System 

Small 

Multiplex 

system 

Large 

NonDisplay 

Cooler 

Small 

$7,335 - $6,411 - $2,702 -

5,6 3,7 3,2 

NonDisplay 

Cooler 

Medium 

- $13,720 - $14,019 - $5,288 

5,6 4,6 1,3 

NonDisplay 

Cooler 

Large 

- $28,369 - $30,808 - $10,393 

1,6 1,7 1,3 

Display 

Cooler 

Small 

- $41,865 - $41,130 - $18,486 

5,6 5,7 4,3 

Display 

Cooler 

Medium 

- $98,912 - $96,740 - $44,749 

6,6 6,7 5,3 

Display 

Cooler 

Large 

- $552,429 - $546,793 - $242,378 

6,6 6,8 6,3 

NonDisplay 

Freezer 

Small 

$27,867 - $26,124 - $11,071 -

10,6 10,7 7,2 

NonDisplay 

Freezer 

Medium 

- $54,842 - $50,572 - $20,718 

10,8 10,9 6,2 

NonDisplay 

Freezer 

Large 

- $102,693 - $95,557 - $39,312 

10,8 10,9 5,2 

Display 

Freezer 

Small 

- $53,548 - $50,779 - $19,658 

10,6 3,7 3,2 

Display 

Freezer 

Medium 

- $108,341 - $104,054 - $40,191 

11,7 4,7 4,2 

Display 

Freezer 

Large 

- $479,751 - $469,115 - $146,800

 10,7 4,9 4,2 

*Refrigeration system is matched to the envelope temperature regime. For example, a small non-display cooler will 

have a medium-temperature refrigeration system while a small non-display freezer will have a low-temperature 

refrigeration system. 

ES-15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table ES.3.15 and Table ES.3.16 show the results of the LCC and PBP analyses, 

respectively, at all considered levels for the example cooler system; that is, a medium nondisplay cooler with a dedicated outdoor refrigeration system. Analysis results for all other 

systems are presented in Chapter 8 of the preliminary TSD. The results from the analysis are also 

graphically presented in Chapter 8 to show the range of LCC savings and PBPs for all the 

efficiency levels considered for each equipment class. Chapter 8 provides further details on the 

methods, data, and assumptions used for the LCC and PBP analyses. 

In this equipment class, as for many others, the maximum LCC savings occur at a 

relatively high refrigeration system efficiency level (in this case 6) and a somewhat lower 

envelope efficiency level (in this case 4). The numbers in parentheses indicate negative LCC 

savings, i.e. efficiency levels that would not reduce life cycle costs. 

Table ES.3.15 LCC Savings for a Medium Non-Display Cooler with a Large Dedicated, 

Medium-Temperature Outdoor Refrigeration System ($) 

Refrigeration System Efficiency Level 

Envelope 

Efficiency 

Level 

0 1 2 3 4 5 6 7 8* 

0 - 922 2,871 5,215 7,659 9,037 9,450 9,452 9,403 

1 8,047 8,632 9,867 11,345 12,869 13,718 13,969 13,968 13,931 

2 8,013 8,596 9,823 11,293 12,808 13,651 13,901 13,900 13,864 

3 8,041 8,622 9,845 11,309 12,819 13,660 13,909 13,908 13,871 

4 9,117 9,605 10,631 11,857 13,116 13,814 14,019 14,018 13,985 

5 9,225 9,697 10,692 11,880 13,099 13,774 13,973 13,972 13,940 

6 9,276 9,731 10,688 11,830 13,001 13,648 13,839 13,837 13,806 

7 9,250 9,696 10,637 11,759 12,908 13,544 13,731 13,729 13,699 

8 9,104 9,529 10,422 11,487 12,578 13,179 13,356 13,355 13,325 

9 8,801 9,210 10,069 11,093 12,141 12,718 12,888 12,886 12,857 

10 6,846 7,217 7,998 8,927 9,876 10,397 10,550 10,548 10,521 

11 1,241 1,584 2,304 3,161 4,033 4,512 4,652 4,650 4,625 

12 (2,134) (1,805) (1,117) (297) 537 994 1,127 1,125 1,100 

13 (3,880) (3,559) (2,885) (2,083) (1,268) (821) (691) (693) (717) 

14 (3,880) (3,559) (2,885) (2,083) (1,268) (821) (691) (693) (717) 

15* (3,880) (3,559) (2,885) (2,083) (1,268) (821) (691) (693) (717) 

* Max-tech efficiency level 

As in all equipment classes for all appliance rulemakings, the PBP in Table ES.3.16 is 

lower at lower efficiency levels. This is simply by design, in that DOE arranged the efficiency 

levels in order of ascending net costs. However, because the WICF rulemaking simultaneously 

examines the separate questions of envelope efficiency and refrigeration system efficiency, there 

are complex interactions between the two types of efficiency increases. This implies that the 

payback periods are not necessarily highest at the highest possible efficiency level for both types 

of equipment. For example, in Table ES.3.16, the highest possible payback period occurs at 

envelope efficiency level 15 and refrigeration efficiency level 0, rather than at envelope 

efficiency level 15 and refrigeration system efficiency level 8. 

The PBP is calculated relative to the baseline. Therefore, the lowest possible PBP is not 

necessarily the most financially attractive option. This is because each level also includes the 

ES-16 
 

 

 

 

 

 

 

 

 

 

 

 

 

efficiency improvements of the levels below it, e.g. all technologies that are implemented in 

efficiency level 5 are also inclusive of technologies considered in level 2. 

In this rulemaking, many of the lower efficiency levels exhibit negative payback periods. 

This reflects an efficiency-increasing option which simultaneously lowers operating costs and 

first costs. This is financially more attractive than the typical situation with efficiency 

improvements, which typically combine lower operating costs with increased first costs. 

Table ES.3.16 PBP for a Medium Non-Display Cooler with a Large Dedicated, MediumTemperature Outdoor Refrigeration System 

Envelope 

Efficiency 

Level 

PBP by Refrigeration Efficiency Level (years)

0 1 2 3 4 5 6 7 8* 

0 - (2.4) (1.9) (1.3) (0.4) 0.1 0.3 0.4 0.5 

1 (2.0) (2.0) (2.0) (1.8) (1.4) (1.0) (0.9) (0.9) (0.8) 

2 (2.0) (2.0) (2.0) (1.8) (1.4) (1.0) (0.9) (0.8) (0.7) 

3 (1.9) (2.0) (1.9) (1.8) (1.3) (1.0) (0.9) (0.8) (0.7) 

4 (0.6) (0.7) (0.8) (0.8) (0.6) (0.3) (0.3) (0.2) (0.2) 

5 (0.4) (0.5) (0.6) (0.6) (0.4) (0.2) (0.1) (0.1) (0.0) 

6 (0.0) (0.1) (0.3) (0.3) (0.1) 0.0 0.1 0.1 0.2 

7 0.2 0.1 (0.1) (0.1) (0.0) 0.2 0.2 0.2 0.3 

8 0.8 0.7 0.5 0.4 0.5 0.6 0.6 0.7 0.7 

9 1.4 1.2 1.0 0.9 0.9 1.0 1.1 1.1 1.1 

10 3.8 3.6 3.3 3.0 2.9 2.9 2.9 2.9 2.9 

11 9.0 8.8 8.3 7.7 7.2 7.0 7.0 7.0 7.0 

12 12.0 11.7 11.0 10.4 9.8 9.5 9.4 9.4 9.4 

13 13.5 13.1 12.4 11.7 11.0 10.7 10.6 10.6 10.6 

14 13.5 13.1 12.4 11.7 11.0 10.7 10.6 10.6 10.6 

15* 13.5 13.1 12.4 11.7 11.0 10.7 10.6 10.6 10.6 

* Max-tech efficiency level 

ES.3.7 Shipments Analysis 

For each equipment class being considered, shipment forecasts are needed to calculate 

the national impacts of standards on energy use, NPV, and future manufacturer cash flows. 

DOE’s shipments model considers shipments based on sector, market, and region. Equipment 

shipments to five sectors are considered: Food Sales, Convenience Stores, Commercial Food 

Service, Institutional Food service, and Industry (primarily Dairy). For units shipped to new 

construction, annual equipment shipments are equal to the number of new building units built 

multiplied by the equipment purchase rate, which is determined by the market share of the 

equipment under consideration. To estimate shipments due to replacements, the model uses sales 

in previous years and assumptions about the equipment lifetime, which determine how long an 

appliance is likely to remain in use. Shipments to “new owners” are based on historical rates of 

adoption. Chapter 9 of the preliminary TSD provides additional detail on the shipments analysis. 

Figure ES.3.1 and Figure ES.3.2 and Table ES.3.17 and Table ES.3.18 illustrate the 

forecasted base-case shipments for all equipment classes included in this rulemaking. 

ES-17 
   

   

   

   

   

   

   

   

   

   

   

 

       

       

       

       

     

     

       

       

       

       

     

     

 

As noted in Table ES.3.13, refrigeration systems have shorter average lifetimes than 

envelopes. For this reason, DOE forecasts more shipments of refrigeration systems than of 

envelopes, even though the installed stock of the two should be equal at any given point in time. 

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

2015 2020 2025 2030 2035 2040 2045

Non‐Display Cooler Small

Non‐Display Cooler Medium

Non‐Display Cooler Large

Display Cooler Small

Display Cooler Medium

Display Cooler Large

Non‐Display Freezer Small

Non‐Display Freezer Medium

Non‐Display Freezer Large

Display Freezer Small

Display Freezer Medium

Figure ES.3.1 Projected Shipments of WICF Envelope Systems 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

2015 2020 2025 2030 2035 2040 2045

Dedicated Medium Temperature Indoor Small

Dedicated Medium Temperature Indoor Large

Dedicated Medium Temperature Outoor Small

Dedicated Medium Temperature Outoor Large

Multiplex system Medium Temperature Small

Multiplex system Medium Temperature Large

Dedicated Low Temperature Indoor Small

Dedicated Low Temperature Indoor Large

Dedicated Low Temperature Outoor Small

Dedicated Low Temperature Outoor Large

Multiplex system Low Temperature Small

Multiplex system Low Temperature Large

Figure ES.3.2 Projected Shipments of WICF Refrigeration Systems 

ES-18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table ES.3.17 Projected Shipments of WICF Envelopes 

WICF Envelopes Year and Number Shipped 

2015 2020 2025 2030 2035 2040 2045 

Non-Display Cooler Small 12,823 13,796 14,583 15,565 16,737 17,950 19,168 

Non-Display Cooler Medium 47,790 51,417 54,350 58,009 62,379 66,898 71,440 

Non-Display Cooler Large 21,430 23,056 24,371 26,012 27,971 29,998 32,035 

Display Cooler Small 542 585 619 663 713 767 821 

Display Cooler Medium 9,909 10,688 11,319 12,126 13,039 14,013 14,996 

Display Cooler Large 813 877 929 995 1,070 1,150 1,231 

Non-Display Freezer Small 8,434 9,104 9,638 10,279 10,982 11,780 12,561 

Non-Display Freezer Medium 27,155 29,311 31,032 33,096 35,358 37,929 40,443 

Non-Display Freezer Large 10,761 11,616 12,298 13,116 14,012 15,031 16,027 

Display Freezer Small 1,144 1,233 1,306 1,410 1,533 1,652 1,779 

Display Freezer Medium 7,298 7,861 8,330 8,990 9,775 10,537 11,344 

Display Freezer Large 572 616 653 705 766 826 889 

Total 148,673 160,160 169,428 180,966 194,336 208,533 222,735 

Table ES.3.18 Projected Shipments of WICF Refrigeration Systems 

WICF Refrigeration Systems Year and Number Shipped 

2015 2020 2025 2030 2035 2040 2045 

Dedicated MediumTemperature Indoor Small 4,986 5,292 5,654 6,061 6,499 6,951 7,442 

Dedicated MediumTemperature Indoor Large 9,023 9,579 10,233 10,972 11,765 12,584 13,472 

Dedicated MediumTemperature Outdoor Small 22,712 24,109 25,756 27,613 29,608 31,667 33,901 

Dedicated MediumTemperature Outdoor Large 72,187 76,631 81,873 87,786 94,134 100,685 107,798 

Multiplex system MediumTemperature Small 1,458 1,547 1,653 1,772 1,900 2,033 2,176 

Multiplex system MediumTemperature Large 101,742 108,035 115,480 123,879 132,865 142,163 152,262 

Dedicated Low- Temperature 

Indoor Small 3,293 3,498 3,733 4,002 4,280 4,571 4,884 

Dedicated Low-Temperature 

Indoor Large 5,022 5,335 5,693 6,103 6,527 6,971 7,449 

Dedicated Low-Temperature 

Outdoor Small 15,002 15,937 17,005 18,230 19,497 20,821 22,251 

Dedicated Low-Temperature 

Outdoor Large 41,476 44,070 47,069 50,495 54,056 57,778 61,805 

Multiplex system LowTemperature Small 963 1,023 1,091 1,170 1,251 1,336 1,428 

Multiplex system LowTemperature Large 60,318 64,112 68,600 73,689 79,035 84,617 90,684 

Total 338,182 359,170 383,841 411,774 441,419 472,176 505,552 

ES.3.8 National Impact Analysis 

The NIA estimates the following national impacts from possible candidate standard 

levels for WICF equipment: (1) national energy savings (NES); (2) monetary value of energy 

ES-19 
 

savings to consumers of the considered equipment classes due to standards; (3) increased total 

installed costs to consumers of the considered equipment classes due to standards; and (4) the net 

present value (NPV) of energy savings (difference between value of energy savings and 

increased total installed costs). DOE prepared an NES spreadsheet model to forecast energy 

savings and national consumer economic costs and savings resulting from new standards. The 

model uses typical national values for inputs. 

A key component of DOE’s estimates of NES and NPV is the trend in energy efficiency 

forecasted for the base case (without new standards) and each of the standards cases (with new 

standards). To forecast the base-case efficiency for each equipment class, DOE assumed that the 

least efficient level analyzed in the engineering analysis currently prevails in the marketplace. 

For its determination of standards-case efficiency distributions, DOE used a “roll-up” scenario to 

establish the distribution of efficiencies for the year that revised standards are assumed to 

become effective and subsequent years. DOE assumed that product efficiencies in the base case 

that did not meet the standard level under consideration would “roll up” to meet the new standard 

level in 2015. For all product classes, Chapter 10 provides additional details on this and other 

aspects of the NIA analysis. 

ES.3.8.1 National Energy Savings 

DOE calculated annual NES as the difference between 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 using the marginal heat rates associated 

with displaced power plants. DOE used the National Energy Modeling System (NEMS) to 

estimate the marginal heat rates. Cumulative energy savings are the sum of the annual NES, 

which DOE determined from 2015 through 2045. 

Table ES.3.19 shows summary NES results for selected matched combinations of WICF 

envelopes and refrigeration systems. The selected efficiency levels in the table are those for the 

highest primary energy savings for which the net present value is a positive number (at a 7­

percent discount rate). In many cases this corresponds to the highest efficiency levels considered 

for both the envelope and the refrigeration system. This is because most of the efficiency levels 

analyzed in this rulemaking are associated with positive net present values. 

ES-20 
 

 

 

 

 

 

 

 

 

 

 

Table ES.3.19 Maximum Energy Savings for Which Net Present Value of Savings >0 at a 7­

Percent Discount Rate and Corresponding WICF Envelope and Refrigeration Efficiency 

Levels 

Envelope 

Energy Savings (Quads) and Corresponding Efficiency Levels for Envelope and Refrigeration 

Unit (a,b) 

Refrigeration System 

Dedicated 

Indoor 

Small 

Dedicated 

Indoor Large 

Dedicated 

Outdoor 

Small 

Dedicated 

Outdoor 

Large 

Multiplex 

System Small 

Multiplex 

System 

Large 

NonDisplay 

Cooler 

Small 

0.021 - 0.086 - 0.003 -

13,7 13,8 10,3 

NonDisplay 

Cooler 

Medium 

- 0.077 - 0.359 - 0.234 

13,7 13,8 9,3 

NonDisplay 

Cooler 

Large 

- - - 0.618 - 0.165

 15,8 11,3 

Display 

Cooler 

Small 

- 0.004 - 0.018 - -

15,7 15,8 

Display 

Cooler 

Medium 

- - - - - 0.556 

15,3 

Display 

Cooler 

Large 

- - - 0.421 - -

15,8 

NonDisplay 

Freezer 

Small 

0.045 - 0.192 - 0.006 -

15,8 15,9 15,4 

NonDisplay 

Freezer 

Medium 

- 0.152 - 0.642 - 0.440 

15,8 15,9 15,4 

NonDisplay 

Freezer 

Large 

- - - 0.781 - 0.234

 15,9 15,4 

Display 

Freezer 

Small 

- - - 0.100 - -

15,9 

Display 

Freezer 

Medium 

- - - - - 0.462 

4,3 

Display 

Freezer 

Large 

- - - 0.514 - -

10,8 

Table ES.3.20 shows the national energy savings by efficiency level for the example 

combination of product classes, a medium non-display cooler with a large dedicated, mediumES-21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

temperature outdoor refrigeration system. For other product classes, see chapter 10 of the 

preliminary TSD, the National Impact Analysis. The energy savings increase monotonically with 

efficiency level. 

Table ES.3.20 National Energy Savings by Efficiency Level for Example Product Class 

Combination: A Medium Non-Display Cooler with a Large Dedicated, MediumTemperature Outdoor Refrigeration System (quads) 

Refrigeration System Efficiency Level 

Envelope 

Efficiency 

Level 

0 1 2 3 4 5 6 7 8 

0 - 0.02 0.06 0.12 0.20 0.26 0.28 0.28 0.29 

1 0.12 0.13 0.16 0.20 0.26 0.30 0.32 0.32 0.32 

2 0.12 0.14 0.16 0.21 0.26 0.30 0.32 0.32 0.33 

3 0.12 0.14 0.17 0.21 0.26 0.30 0.32 0.32 0.33 

4 0.16 0.17 0.19 0.23 0.28 0.32 0.33 0.33 0.34 

5 0.16 0.17 0.20 0.23 0.28 0.32 0.33 0.33 0.34 

6 0.17 0.18 0.20 0.24 0.29 0.32 0.33 0.34 0.34 

7 0.17 0.18 0.21 0.24 0.29 0.32 0.34 0.34 0.34 

8 0.18 0.19 0.21 0.25 0.29 0.33 0.34 0.34 0.34 

9 0.18 0.19 0.22 0.25 0.30 0.33 0.34 0.34 0.34 

10 0.20 0.21 0.23 0.26 0.30 0.33 0.34 0.35 0.35 

11 0.21 0.22 0.24 0.27 0.31 0.34 0.35 0.35 0.35 

12 0.21 0.22 0.24 0.27 0.31 0.34 0.35 0.35 0.35 

13 0.21 0.22 0.24 0.27 0.31 0.34 0.35 0.35 0.35 

14 0.21 0.22 0.24 0.27 0.31 0.34 0.35 0.35 0.35 

15 0.21 0.22 0.24 0.27 0.31 0.34 0.35 0.35 0.35 

ES.3.8.2 Net Present Value 

DOE calculated net monetary savings each year as the difference between total savings in 

operating costs and increases in total equipment costs in the base case and standards cases. DOE 

calculated savings over the life of the product. DOE used discount rates of 7 percent and 3 

percent to discount future costs and savings to the present. DOE calculated NPV as the 

difference between the present value of operating cost savings and the present value of increased 

total installed costs. Selected NPV results for the example combination of product classes are 

shown in Table ES.3.21 for a 7 percent discount rate as the discounted value of the net savings in 

dollar terms. Note that these results are for the maximum level of energy savings for which net 

present value of savings is positive at a 7 percent discount rate, i.e. at the same efficiency levels 

that were presented in Table ES.3.19. 

ES-22 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table ES.3.21 Net Present Value of Energy Savings at Maximum Level of Energy Savings 

for Which Net Present Value of Savings > 0 at a 7-Percent Discount Rate and 

Corresponding WICF Envelope and Refrigeration Efficiency Levels 

Envelope 

NPV (Billion 2009$) and Corresponding Efficiency Levels for Envelope and Refrigeration Unit 

(a,b) 

Refrigeration System 

Dedicated 

Indoor 

Small 

Dedicated 

Indoor Large 

Dedicated 

Outdoor 

Small 

Dedicated 

Outdoor 

Large 

Multiplex 

System 

Small 

Multiplex 

System 

Large 

NonDisplay 

Cooler 

Small 

0.08 ­ 0.29 ­ 0.01 ­

13,7 13,8 10,3 

NonDisplay 

Cooler 

Medium

 ­ 0.15 ­ 0.90 ­ 0.21 

13,7 13,8 10,3 

NonDisplay 

Cooler 

Large 

­ ­ ­ 0.52 ­ 0.29 

15,8 11,3 

Display 

Cooler 

Small 

­ 0.05 ­ 0.24 ­ ­

15,7 15,8 

Display 

Cooler 

Medium

 - - - - - 3.05 

15,3 

Display 

Cooler 

Large 

- - - 6.56 - -

15,8 

NonDisplay 

Freezer 

Small 

0.53 ­ 2.29 ­ 0.03 ­

15,8 15,9 15,4 

NonDisplay 

Freezer 

Medium

 ­ 1.52 ­ 6.44 ­ 1.22 

15,8 15,9 15,4 

NonDisplay 

Freezer 

Large 

­ ­ ­ 7.90 ­ 0.75 

15,9 15,4 

Display 

Freezer 

Small 

- - - 0.05 - -

15,9 

Display 

Freezer 

Medium

 - - - - - 0.08 

4,3 

Display 

Freezer 

Large 

- - - 0.09 - -

10,8 

ES-23 
 

ES.3.9 Preliminary Manufacturer Impact Analysis 

The preliminary MIA focuses on manufacturers of walk-in cooler and freezer equipment. 

Potential impacts include financial effects, both quantitative and qualitative, that might result 

from new energy conservation standards and consequently lead to changes in manufacturing 

practices for walk-in equipment. DOE identified potential impacts through interviews with 

manufacturers and other interested parties. Chapter 12 of the preliminary TSD includes details on 

the key issues DOE identified during the preliminary MIA. 

Key issues relevant to the MIA for walk-in equipment include the following: 

• Increased conversion costs; 

• Impact to U.S. production and jobs; 

• Cumulative regulatory burden; 

• Impact to equipment utility; 

• Current economic conditions; 

• Equipment substitution; 

• Impacts of regional standards; and 

• Technical difficulty to achieve new standards 

DOE conducted the preliminary MIA by first identifying equipment, methods, and 

practices used in the walk-in cooler and freezer industry. Next, DOE determined how energy 

efficiency improvements affect cost, production, and various other manufacturing metrics. 

Finally, DOE interviewed manufacturers for feedback. 

DOE developed and distributed a questionnaire for use during the interviews. At the 

beginning of the interview process, DOE interviewed manufacturers and adjusted the analysis as 

appropriate, based on the feedback. In the interviews, DOE also examined any additional effects 

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

regulations affecting manufacturers, as well as several issues raised by individual manufacturers. 

Chapter 12 of the preliminary TSD provides additional details on this and other aspects of the 

preliminary MIA. 

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT 

DOE is particularly interested in receiving comments and views of interested parties 

concerning the following issues: 

ES.4.1 Separate Standards 

DOE intends to create two separate standards for one walk-in: one standard for the 

refrigeration system and another standard for the envelope. The standard for the refrigeration 

system would be in terms of kWh/day or kWh/year, while the standard for the envelope would 

be in terms of energy consumption per square foot of surface area (kWh/ft2

). The refrigeration 

ES-24 
system manufacturer would be responsible for complying with the standard applicable to that 

system and the envelope manufacturer would be responsible for complying with the standard for 

the envelope. DOE has tentatively concluded that setting energy conservation standards for subsystems or components beyond the division of the envelope and refrigeration system is 

unwarranted. DOE requests comment on this approach. See chapter 2, section 2.1.2.1 of the 

preliminary TSD. 

ES.4.2 Responsibility for Compliance 

DOE intends to hold the manufacturer of the envelope responsible for complying with the 

envelope standard, and the manufacturer of the refrigeration system responsible for complying 

with the refrigeration system standard. DOE believes that because of the structure of the walk-in 

market, it makes more sense to consider the envelope and refrigeration as separately 

manufactured components, rather than depart from its precedent and hold the installer or 

contractor responsible. However, DOE does not intend to consider sub-systems or components 

beyond the division of the envelope and refrigeration system. DOE requests comment on this 

approach. See chapter 2, section 2.1.2.2 of the preliminary TSD. 

ES.4.3 Equipment Classes 

Regarding WICF envelope equipment classes, DOE did not consider outdoor units as a 

separate envelope equipment class because the test procedure for measuring the energy 

performance of walk-in envelopes does not consider outdoor weather conditions. Further, typical 

walk-in designs for outdoor units include no additional design features that impact the energy 

consumption. Walk-ins are typically only modified to endure precipitation events such as rain, 

snow, and ice. DOE seeks comment on this assumption. DOE also seeks comment on other 

assumptions about both envelope and refrigeration equipment classes. See chapter 2, section 

2.2.1.1, section 2.2.1.2, and section 2.2.1.3 of the preliminary TSD. 

ES.4.4 Markups Analysis 

DOE intends to model the WICF market and the markups analysis using multiple 

distribution channels. DOE requests comment on its approach and results of the markups 

analysis. See chapter 2, section 2.5 and chapter 6 of the preliminary TSD. 

ES.4.5 Maintenance and Repair Costs 

WICF refrigeration equipment is usually maintained by contractors who specialize in 

maintenance of both refrigeration and HVAC products. Consequently, DOE did not consider any 

“learning curve” related maintenance cost for the refrigeration system. For the improved 

technologies being proposed by DOE for the envelope (e.g., higher insulation thickness, door 

and sealant enhancement, active and passive infiltration reduction devices, high efficacy lighting, 

etc.), DOE did not find any consensus of opinion regarding “learning curve” related maintenance 

cost. DOE requests comment on this issue. See chapter 2, section 2.7.3 of the preliminary TSD. 

ES-25 
ES.4.6 Manufacturer Impact 

As part of the NOPR, DOE will seek further comments from manufacturers about their 

potential loss of market share, changes in the efficiency distribution within each industry, and the 

total reduction in equipment shipments at each new energy conservation standard level. DOE 

will then estimate the impacts on the industry quantitatively and qualitatively. DOE seeks further 

comment from interested parties about the impact of new standards on domestic manufacturers. 

See chapter 2, section 2.9 of the preliminary TSD. 

ES.4.7 General Analytical Assumptions 

During each stage of the preliminary analysis, DOE made one or more assumptions related to 

some key parameters of the analytical process on the premises that the assumed parameters 

reflect the actual conditions that walk-ins experience. These assumptions are described in the 

respective TSD chapters. DOE welcomes comments on these assumptions. 

ES-26