After a regulatory action has been completed, Executive Order 12866 requires agencies 

to identify the substantive changes between the draft submitted to Office of Information 

and Regulatory Affairs (OIRA) for review and the action subsequently announced, and to 

identify those changes made at the suggestion or recommendation of OIRA. The 

document below provides more information.
[6450-01-P]

DEPARTMENT OF ENERGY

10 CFR Part 431

[Docket Number EERE-2010-BT-STD-0037]

RIN: 1904-AC39

Energy Conservation Program: Energy Conservation Standards for Automatic 

Commercial Ice Makers

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION: Notice of proposed rulemaking and public meeting.

SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as amended,

prescribes energy conservation standards for various consumer products and certain 

commercial and industrial equipment, including automatic commercial ice makers

(ACIM). EPCA also requires the U.S. Department of Energy (DOE) to determine 

whether more-stringent, amended standards would be technologically feasible and 

economically justified, and would save a significant amount of energy. In this notice, 

DOE proposes amended energy conservation standards for automatic commercial ice 

makers. The notice of proposed rulemaking also announces a public meeting to receive 

comment on these proposed standards and associated analyses and results.

1
DATES: DOE will hold a public meeting on [Day of week, Month, Day, Year], from 9 

a.m. to 4 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See 

section VII, “Public Participation,” for webinar registration information, participant 

instructions, and information about the capabilities available to webinar participants. 

DOE will accept comments, data, and information regarding this notice of 

proposed rulemaking (NOPR) before and after the public meeting, but no later than 

[INSERT DATE 60 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL 

REGISTER]. See section VII, “Public Participation,” for details.

ADDRESSES: The public meeting will be held at the U.S. Department of Energy, 

Forrestal Building, Room [NUMBER], 1000 Independence Avenue, SW., Washington, 

DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586-2945. Persons can 

attend the public meeting via webinar. For more information, refer to section VII, “Public 

Participation.”

Any comments submitted must identify the NOPR for Energy Conservation 

Standards for Automatic Commercial Ice Makers and provide docket number EERE2010-BT-STD-0037 and/or regulatory information number (RIN) 1904-AC39. 

Comments may be submitted using any of the following methods: 

1. Federal eRulemaking Portal: www.regulations.gov. Follow the instructions for 

submitting comments. 

2
2. Email: ACIM-2010-STD-0037@ee.doe.gov. Include the docket number and/or 

RIN in the subject line of the message.

3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies 

Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC

20585-0121. If possible, please submit all items on a CD. It is not necessary to 

include printed copies.

4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, 

Building Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, 

Washington, DC 20024. Telephone: (202) 586-2945. If possible, please submit all 

items on a CD, in which case it is not necessary to include printed copies.

Written comments regarding the burden-hour estimates or other aspects of the 

collection-of-information requirements contained in this proposed rule may be submitted 

to Office of Energy Efficiency and Renewable Energy through the methods listed above 

and by email to Chad_S_Whiteman@omb.eop.gov.

For detailed instructions on submitting comments and additional information on 

the rulemaking process, see section VII of this document (Public Participation).

Docket: The docket, which includes Federal Register notices, public meeting 

attendee lists and transcripts, comments, and other supporting documents/materials, is 

available for review at regulations.gov. All documents in the docket are listed in the 

regulations.gov index. However, some documents listed in the index, such as those 

3
containing information that is exempt from public disclosure, may not be publicly 

available.

The link to the docket webpage is the following: 

www.regulations.gov/#!docketBrowser;rpp=25;po=0;D=EERE-2010-BT-STD-0037.

This webpage will contain a link to the docket for this proposed rule on the 

regulations.gov site. The regulations.gov webpage will contain simple instructions on 

how to access all documents, including public comments, in the docket. See section VII

for further information on how to submit comments through www.regulations.gov.

For further information on how to submit a comment, review other public 

comments and the docket, or participate in the public meeting, contact Ms. Brenda 

Edwards at (202) 586-2945 or by email: Brenda.Edwards@ee.doe.gov.

FOR FURTHER INFORMATION CONTACT: 

Mr. Charles Llenza, U.S. Department of Energy, Office of Energy Efficiency and 

Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, 

SW., Washington, DC 20585-0121. Telephone: (202) 586-2192. Email:

automatic_commercial_ice_makers@ee.doe.gov.

Mr. Ari Altman, U.S. Department of Energy, Office of the General Counsel, 

GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: 

(202) 287-6307. Email: Ari.Altman@hq.doe.gov.

4
SUPPLEMENTARY INFORMATION:

Table of Contents

I. Summary of the Proposed Rule

A. Benefits and Costs to Customers

B. Impact on Manufacturers

C. National Benefits

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Automatic Commercial Ice Makers

III. General Discussion

A. List of Equipment Class Abbreviations

B. Test Procedures

C. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

D. Energy and Water Savings

1. Determination of Savings

2. Significance of Savings

E. Economic Justification

1. Specific Criteria

a. Economic Impact on Manufacturers and Commercial Customers

b. Life-Cycle Costs

c. Energy Savings

d. Lessening of Utility or Performance of Equipment

e. Impact of Any Lessening of Competition

f. Need of the Nation to Conserve Energy

g. Other Factors

2. Rebuttable Presumption

IV. Methodology and Discussion of Comments

A. General Rulemaking Issues

1. Statutory Authority

2. Test Procedures

3. Need for and Scope of Rulemaking

B. Market and Technology Assessment

1. Equipment Classes

a. Cabinet Size

b. Large-Capacity Batch Ice Makers

c. Efficiency/Harvest Capacity Relationship

d. Continuous Ice Maker Equipment Classes

e. Remote Condensing Unit Classes for Equipment with and without Remote 

Compressors

f. Remote to Rack Equipment

5
g. Ice Makers Covered by the Energy Policy Act of 2005

h. Regulation of Potable Water Use

2. Technology Assessment

a. Reduced Potable Water Flow for Continuous Type Ice Makers

b. Alternative Refrigerants

C. Screening Analysis

a. Tube Evaporator Design

b. Low Thermal Mass Evaporator Design

c. Drain Water Heat Exchanger

d. Design Options that Necessitate Increased Cabinet Size

e. Microchannel Heat Exchangers

f. Smart Technologies

g. Screening Analysis: General Comments

D. Engineering Analysis

1. Representative Equipment for Analysis

2. Efficiency Levels

a. Baseline Efficiency Levels

b. Incremental Efficiency Levels

c. IMH-A-Large-B Treatment

d. Maximum Available Efficiency Equipment

e. Maximum Technologically Feasible Efficiency Levels

f. Comment Discussion

3. Design Options

a. Improved Condenser Performance in Batch Equipment

b. Harvest Capacity Oversizing

c. Open-Loop Condensing Water Designs

d. Condenser Water Flow

e. Compressors

4. Development of the Cost-Efficiency Relationship

a. Manufacturing Cost

b. Energy Consumption Model

c. Retail Cost Review

d. Design, Development, and Testing Costs

e. Empirical-Based Analysis

f. Revision of Preliminary Engineering Analysis

E. Markups Analysis

F. Energy Use Analysis

G. Life-Cycle Cost and Payback Period Analysis

1. Equipment Cost

2. Installation, Maintenance, and Repair Costs

a. Installation Costs

b. Repair and Maintenance Costs

3. Annual Energy and Water Consumption

4. Energy Prices

5. Energy Price Projections

6. Water Prices

6
7. Discount Rates

8. Lifetime

9. Compliance Date of Standards

10. Base-Case and Standards-Case Efficiency Distributions

11. Inputs to Payback Period Analysis

12. Rebuttable Presumption Payback Period

H. National Impact Analysis – National Energy Savings and Net Present Value

1. Shipments

2. Forecasted Efficiency in the Base Case and Standards Cases

3. National Energy Savings

4. Net Present Value of Customer Benefit

I. Customer Subgroup Analysis

J. Manufacturer Impact Analysis

1. Overview

2. Government Regulatory Impact Model

a. Government Regulatory Impact Model Key Inputs

b. Government Regulatory Impact Model Scenarios

3. Discussion of Comments

a. Impact to Suppliers, Distributors, Dealers, and Contractors

b. ENERGY STAR

c. Cumulative Regulatory Burden

d. Small Manufacturers

4. Manufacturer Interviews

a. Price Sensitivity

b. Enforcement

c. Reliability Impacts

d. Impact on Innovation

K. Emissions Analysis

L. Monetizing Carbon Dioxide and Other Emissions Impacts

1. Social Cost of Carbon

a. Monetizing Carbon Dioxide Emissions

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

c. Current Approach and Key Assumptions

2. Valuation of Other Emissions Reductions

M. Utility Impact Analysis

N. Employment Impact Analysis

O. Regulatory Impact Analysis

V. Analytical Results

A. Trial Standard Levels

1. Trial Standard Level Formulation Process and Criteria

2. Trial Standard Level Equations

B. Economic Justification and Energy Savings

1. Economic Impacts on Commercial Customers

a. Life-Cycle Cost and Payback Period

b. Life-Cycle Cost Subgroup Analysis

2. Economic Impacts on Manufacturers

7
a. Industry Cash Flow Analysis Results

b. Impacts on Direct Employment

c. Impacts on Manufacturing Capacity

d. Impacts on Subgroups of Manufacturers

e. Cumulative Regulatory Burden

3. National Impact Analysis

a. Amount and Significance of Energy Savings

b. Net Present Value of Customer Costs and Benefits

c. Water Savings

d. Employment Impacts

4. Impact on Utility or Performance of Equipment

5. Impact of Any Lessening of Competition

6. Need of the Nation to Conserve Energy

7. Other Factors

C. Proposed Standard

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

1. Description and Estimated Number of Small Entities Regulated

2. Description and Estimate of Compliance Requirements

3. Duplication, Overlap, and Conflict with Other Rules and Regulations

4. Significant Alternatives to the Rule

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under the Information Quality Bulletin for Peer Review

VII. Public Participation

A. Attendance at the Public Meeting

B. Procedure for Submitting Prepared General Statements for Distribution

C. Conduct of the Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

1. Standards Compliance Dates

2. Utilization Factors

3. Baseline Efficiency

4. Screening Analysis

5. Maximum Technologically Feasible Levels

6. Markups to Determine Price

7. Equipment Life

8. Installation Costs

8
9. Open- Versus Closed-Loop Installations

10. Ice Maker Shipments by Type of Equipment

11. Intermittency of Manufacturer R&D and Impact of Standards

12. INPV Results and Impact of Standards

13. Small Businesses

VIII. Approval of the Office of the Secretary

I. Summary of the Proposed Rule

Title III, Part C1 of the Energy Policy and Conservation Act of 1975 (EPCA or 

the Act), Pub. L. 94-163 (42 U.S.C. 6311-6317, as codified), established the Energy 

Conservation Program for Certain Industrial Equipment, a program covering certain 

industrial equipment,

2 which includes the focus of this proposed rule: automatic 

commercial ice makers.

Pursuant to EPCA, any new or amended energy conservation standard that DOE 

prescribes for the covered equipment, such as automatic commercial ice makers, shall be 

designed to achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified and would result in significant 

conservation of energy. (42 U.S.C. 6295(o)(2)(A) and (3)(B); 6313(d)(4)) 

In accordance with these and other statutory criteria discussed in this proposed 

rule, DOE proposes amended conservation standards for automatic commercial ice 

1 For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1. 2 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).

9

 
makers,

3 and new standards for covered equipment not yet subject to energy conservation 

standards. The proposed standards, which consist of maximum allowable energy usage

values per 100 lb of ice production, are shown in Table I.1Table I.1 and Table I.2Table 

I.2. Standards shown on Table I.1Table I.1 for batch type ice makers represent an 

amendment to existing standards set for cube type ice makers by EPCA in 42 U.S.C. 

6313(d)(1), and). Table I.1also shows new standards for cube type ice makers with 

expanded harvest capacities up to 4,000 pounds of ice per 24 hour period (lb ice/24 

hours) and an explicit coverage of other types of batch machines, such as tube type ice 

makers. Table I.2Table I.2 provides proposed standards for continuous type ice-making 

machines, which are not currently covered by DOE’s existing standards. The proposed 

standards include, for applicable equipment classes, maximum condenser water usage 

values in gallons per 100 lb of ice production. If adopted, the proposed standards would 

apply to all equipment manufactured in, or imported into, the United States, beginning 3 

years after the publication date of the final rule. (42 U.S.C. 6313(d)(2)(B)(i) and 

(3)(C)(i))

3 EPCA as amended by the Energy Policy Act of 2005 (EPACT 2005) established maximum energy use 

and maximum condenser water use standards for cube type automatic commercial ice makers with harvest 

capacities between 50 and 2,500 lb/24 hours. In this rulemaking, DOE proposes amending the legislated 

energy use standards for these automatic commercial ice maker types. DOE did not, however, consider 

amendment to the existing condenser water use standards for equipment with existing condenser water 

standards. In the preliminary TSD, DOE indicated that the ice maker standards primarily focus on energy 

use, and that DOE is not bound by EPCA to evaluate reductions in the condenser water use in automatic 

commercial ice makers, and may in fact consider increases in condenser water use, if this is a cost-effective 

way to improve energy efficiency. Section IV.D.3.d of today’s NOPR contains more information on 

DOE’s analysis of condenser water use.

Comment [fp1]: Change requested by OIRA in 

footnote 3.

Comment [fp2]: Change requested by OIRA.

Comment [fp3]: Change requested by OIRA.

10

 
Table I.1 Proposed Energy Conservation Standards for Batch Type Automatic 

Commercial Ice Makers

Equipment Type Type of 

Cooling

Rated Harvest Rate

lb ice/24 hours

Maximum 

Energy Use

kilowatt-hours 

(kWh)/100 lb 

ice*

Maximum 

Condenser 

Water Use

gal/100 lb ice**

Ice-Making Head Water

<500 5.84 – 0.0041H 200-0.022H

≥500 and <1,436 3.88 – 0.0002H 200-0.022H

≥1,436 and <2,500 3.6 200-0.022H

≥2,500 and <4,000 3.6 145

Ice-Making Head Air

<450 7.70 – 0.0065H NA

≥450 and <875 5.17 – 0.0008H NA

≥875 and <2,210 4.5

≥2,210 and <2,500 6.89 – 0.0011H NA

≥ 2,500 and <4,000 4.1

Remote Condensing (but 

not remote compressor)

Air <1,000 7.52 – 0.0032H NA

Air ≥1,000 and <4,000 4.3 NA

Remote Condensing and 

Remote Compressor

Air <934 7.52 – 0.0032H NA

Air ≥934 and <4,000 4.5 NA

Self-Contained Water

<200 8.55 – 0.0143H 191-0.0315H

≥200 and <2,500 5.7 191-0.0315H

≥2,500 and <4,000 5.7 112

Self-Contained Air <175 12.6 – 0.0328H NA

≥175 and <4,000 6.9 NA

* H = rated harvest rate in pounds per 24 hours, indicating the water or energy use for a given rated harvest rate.

Source: 42 U.S.C. 6313(d).

** Water use is for the condenser only and does not include potable water used to make ice.

Table I.2 Proposed Energy Conservation Standards for Continuous Type Automatic 

Commercial Ice Makers

Equipment Type Type of 

Cooling

Rated Harvest Rate

lb ice/24 hours

Maximum 

Energy Use

kWh/100 lb 

ice*

Maximum 

Condenser 

Water Use

gal/100 lb ice**

Ice-Making Head Water

<900 6.08 – 0.0025H 160-0.0176H

≥900 and <2,500 3.8 160-0.0176H

≥2,500 and <4,000 3.8 116

Ice-Making Head Air <700 9.24 – 0.0061H NA

≥700 and <4,000 5.0 NA

Remote Condensing (but 

not remote compressor) Air <850 7.5 – 0.0034H NA

≥850 and <4,000 4.6 NA

Remote Condensing and 

Remote Compressor Air <850 7.65 – 0.0034H NA

≥850 and <4,000 4.8 NA

Self-Contained Water

<900 7.28 – 0.0027H 153-0.0252H

≥900 and <2,500 4.9 153-0.0252H

≥2,500 and <4,000 4.9 90

Self-Contained Air <700 9.2 – 0.0050H NA

≥700 and <4,000 5.7 NA

* H = rated harvest rate in pounds per 24 hours, indicating the water or energy use for a given rated harvest rate.

Source: 42 U.S.C. 6313(d).

** Water use is for the condenser only and does not include potable water used to make ice.

11
A. Benefits and Costs to Customers

Table I.3Table I.3 presents DOE’s evaluation of the economic impacts of the 

proposed standards on customers of automatic commercial ice makers, as measured by 

the average life-cycle cost (LCC) savings4 and the median payback period (PBP).

5 The 

average LCC savings are positive for all equipment classes under the standards proposed 

by DOE.

Table I.3 Impacts of Proposed Standards on Customers of Automatic Commercial 

Ice Makers

Equipment Class*

Average LCC 

Savings

2012$

Median PBP

years

IMH-W-Small-B 328 2.27

IMH-W-Med-B 587 0.85

IMH-W-Large-B ** 833 0.69

 IMH-W-Large-B-1 701 0.72

 IMH-W-Large-B-2 1,260 0.58

IMH-A-Small-B 396 1.42

IMH-A-Large-B ** 1,127 0.84

 IMH-A-Large-B-1 1,168 0.82

 IMH-A-Large-B-2 908 0.94

RCU-Large-B ** 983 0.65

 RCU-Large-B-1 963 0.62

 RCU-Large-B-2 1,277 1.00

SCU-W-Large-B 694 1.00

SCU-A-Small-B 396 1.56

SCU-A-Large-B 502 1.49

IMH-A-Small-C 391 0.97

IMH-A-Large-C 1,026 0.69

SCU-A-Small-C 146 1.85

*Abbreviations are: IMH is ice-making head; RCU is remote condensing unit; 

SCU is self-contained unit; W is water-cooled; A is air-cooled; Small refers to 

the lowest harvest category; Med refers to the Medium category (water-cooled 

IMH only); RCU with and without remote compressor were modeled as one 

group. For three large batch categories, a machine at the low end of the harvest 

range (B-1) and a machine at the higher end (B-2) were modeled. Values are 

shown only for equipment classes that have significant volume of shipments 

and, therefore, were directly analyzed. See chapter 5 of the NOPR technical 

support document, “Engineering Analysis,” for a detailed discussion of 

4 Life-cycle cost of automatic commercial ice makers is the cost to customers of owning and operating the 

equipment over the entire life of the equipment. Life-cycle cost savings are the reductions in the life-cycle 

costs due to the amended energy conservation standards when compared to the life-cycle costs of the 

equipment in the absence of the amended energy conservation standards.

5 Payback period refers to the amount of time (in years) it takes customers to recover the increased installed 

cost of equipment associated with new or amended standards through savings in operating costs.

12

 
equipment classes analyzed. 

** LCC savings and PBP results for these classes are weighted averages of the 

typical units modeled for the large classes, using weights provided in TSD 

chapter 7.

B. Impact on Manufacturers

The industry net present value (INPV) is the sum of the discounted cash flows to 

the industry from the present year (2013) through the end of the analysis period (2047). 

Using a real discount rate of 9.2 percent, DOE estimates that the INPV for manufacturers 

of automatic commercial ice makers is $101.8 million in 2012$. Under the proposed

standards, DOE expects that manufacturers may lose up to 23.5 percent of their INPV, or

approximately $23.9 million. Based on DOE’s interviews with the manufacturers of 

automatic commercial ice makers, DOE does not expect any plant closings or significant 

loss of employment.

C. National Benefits

DOE’s analyses indicate that the proposed standards for automatic commercial ice 

makers would save a significant amount of energy. The lifetime savings for equipment

purchased in the 30-year period that begins in the year of compliance with amended and 

new standards (2018–2047)6 amount to 0.286 quadrillion British thermal units (quads) of 

cumulative energy. This is equivalent to 23 percent of total U.S. commercial sector 

energy (source energy) used for commercial refrigeration in 2010.

6 The standards analysis period for national benefits covers the 30-year period, plus the life of equipment 

purchased during the period. In the past DOE presented energy savings results for only the 30-year period 

that begins in the year of compliance. In the calculation of economic impacts, however, DOE considered 

operating cost savings measured over the entire lifetime of products purchased in the 30-year period. DOE 

has chosen to modify its presentation of national energy savings to be consistent with the approach used for 

its national economic analysis.

Comment [fp4]: Change requested by OIRA.

13

 
The cumulative national net present value (NPV) of total customer savings of the 

proposed standards for automatic commercial ice makers in 2012$ ranges from $0.791

billion (at a 7-percent discount rate) to $1.751 billion (at a 3-percent discount rate7). This 

NPV expresses the estimated total value of future operating cost savings minus the 

estimated increased installed costs for equipment purchased in the period from 2018–

2047, discounted to 2013. 

In addition, the proposed standards are expected to have significant environmental 

benefits. The energy savings would result in cumulative emission reductions of 14.6

million metric tons (MMt)8 of carbon dioxide (CO2), 8.7 thousand tons of nitrogen oxides 

(NOx), 0.3 thousand tons of nitrous oxide (N2O), 75.8 thousand tons of methane (CH4) 

and 0.02 tons of mercury (Hg)9

, and 21 thousand tons of sulfur dioxide (SO2) based on 

energy savings from equipment purchased over the period from 2018–204710. 

The value of the CO2 reductions is calculated using a range of values per metric 

ton of CO2 (otherwise known as the Social Cost of Carbon, or SCC) developed and 

recently updated by a recentan interagency process11. The derivation of the SCC value is 

7 These discount rates are used in accordance with the Office of Management and Budget (OMB) guidance 

to Federal agencies on the development of regulatory analysis (OMB Circular A-4, September 17, 2003), 

and section E, “Identifying and Measuring Benefits and Costs,” therein. Further details are provided in 

section V.B.2. 8 A metric ton is equivalent to 1.1 U.S. short tons. Results for NOx, Hg, and SO2 are presented in short tons. 9 DOE calculates emissions reductions relative to the Annual Energy Outlook 2013 (AEO2013) Reference 

Case, which generally represents current legislation and environmental regulations for which implementing 

regulations were available as of December 31, 2012. 10 DOE also estimated CO2 and CO2 equivalent (CO2eq) emissions that occur through 2030 (CO2eq 

includes greenhouse gases such as CH4 and N2O). The estimated emissions reductions through 2030 are 5.8

million metric tons CO2, 576 thousand tons CO2eq for CH4, and 25 thousand tons CO2eq for N2O. 11 http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbonfor-regulator-impact-analysis.pdf

Comment [fp5]: OIRA requested that this text 

contained in footnote 7, be deleted. The deleted text 

is as follows: Total U.S. commercial sector energy 

(source energy) used for refrigeration in 2010 was 

1.21 quads. Ice maker energy alone is not a large 

enough end use to be broken out separately, and 

instead is a subset of the refrigeration end use. 

Source: U.S. Department of Energy – Office of 

Energy Efficiency and Renewable Energy. Building 

Energy Data Book. Table 3.14, 2010 Commercial 

Energy End-Use Splits, by Fuel Type (Quadrillion 

Btu). 2012. (Last accessed February 14, 2013.) 

<http://buildingsdatabook.eren.doe.gov/TableView.a

spx?table=3.1.4>

Comment [fp6]: Change requested by OIRA.

14

 
discussed in section IV.L. DOE estimates the net present monetary value of the CO2 

emissions reduction is between $0.102 and $1.426 billion, expressed in 2012$ and 

discounted to 2013. DOE also estimates the net present monetary value of the NOx

emissions reduction, expressed in 2012$ and discounted to 2013, is between $0.54 and 

$5.53 million at a 7-percent discount rate, and between $1.71 and $17.56 million at a 3-

percent discount rate.12

Table I.4Table I.4 summarizes the national economic costs and benefits expected 

to result from today’s proposed standards for automatic commercial ice makers.

Table I.4 Summary of National Economic Benefits and Costs of Proposed Automatic 

Commercial Ice Maker Conservation Standards

Category Present Value

million 2012$ Discount Rate

Benefits

Operating Cost Savings 982 7%

2,114 3%

CO2 at 5% dr, averageCO2 Reduction Monetized Value 

($11.8/t case)* 102 5%

CO2 at 3% dr, averageCO2 Reduction Monetized Value 

($39.7/t case)* 463 3%

CO2 at 2.5% dr, averageCO2 Reduction Monetized Value 

($61.2/t case)* 733 2.5%

CO2 at 3% dr, 95th percCO2 Reduction Monetized Value 

($117/t case)* 1,426 3%

NOx Reduction Monetized Value (at $($2,639/Tont case)** 3 7%

10 3%

Total Benefits††,†† 1,448 7%

2,587 3%

Costs

Incremental Installed Costs 191 7%

364 3%

Net Benefits

Including CO2 and NOx Reduction Monetized Value 1,257 7%

2,223 3%

* The CO2 values represent global monetized values of the SCC, in 2012$$, in year 2015 under several 

scenarios of the updated SCC values. The values of $11.8, $39.7, and $61.2 per metric ton (t) are the averages 

of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The 

value of $117.0/t represents the 95th percentile of the SCC distribution calculated using a 3-percent discount 

rate. The SCC time series used by DOE incorporate an escalation factor.

12 DOE is currently investigating valuation of avoided Hg and SO2 emissions.

Comment [fp7]: Changes requested by OIRA.

Comment [fp8]: Change requested by OIRA.

15

 
** The value represents the average of the low and high NOx values used in DOE’s analysis.

† Total Benefits for both the 3-percent and the 7-percent cases are derived using the series corresponding to 

SCC value of $39.7/t.

†† DOE estimates reductions in sulfur dioxide, mercury, methane and nitrous oxide emissions, but is not 

currently monetizing these reductions. Thus, these impacts are excluded from the total benefits.

The benefits and costs of today’s proposed standards, for automatic commercial 

ice makers sold in 2018–2047, can also be expressed in terms of annualized values. The 

annualized monetary values are the sum of (1) the annualized national economic value of 

the benefits from the operation of equipment that meets the proposed standards

(consisting primarily of operating cost savings from using less energy and water, minus 

increases in equipment installed cost, which is another way of representing customer

NPV); and (2) the annualized monetary value of the benefits of emission reductions, 

including CO2 emission reductions.13

Although combining the values of operating savings and CO2 emission reductions 

provides a useful perspective, two issues should be considered. First, the national 

operating savings are domestic U.S. customer monetary savings that occur as a result of

market transactions, while the value of CO2 reductions is based on a global value. 

Second, the assessments of operating cost savings and CO2 savings are performed with 

different methods that use different time frames for analysis. The national operating cost 

savings is measured over the lifetimes of automatic commercial ice makers shipped from 

13 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized 

values. First, DOE calculated a present value in 2013, the year used for discounting the NPV of total 

consumer costs and savings, for the time-series of costs and benefits using discount rates of 3 and 7 percent 

for all costs and benefits except for the value of CO2 reductions. For the latter, DOE used a range of 

discount rates, as shown in Table I.5Table I.5. From the present value, DOE then calculated the fixed 

annual payment over a 30-year period (2018 through 2047) that yields the same present value. The fixed 

annual payment is the annualized value. Although DOE calculated annualized values, this does not imply 

that the time-series of cost and benefits from which the annualized values were determined is a steady 

stream of payments.

Comment [fp9]: Change requested by OIRA.

16

 
2018 to 2047. The SCC values, on the other hand, reflect the present value of some future 

climate-related impacts resulting from the emission of 1 ton of CO2 in each year. These 

impacts continue well beyond 2100.

Estimates of annualized benefits and costs of the proposed standards are shown in 

Table I.5Table I.5. (All monetary values below are expressed in 2012$.) Table I.5Table 

I.5 shows the primary, low net benefits, and high net benefits scenarios. The primary 

estimate is the estimate in which the operating cost savings were calculated using the 

Annual Energy Outlook 2013 (AEO2013) Reference Case forecast of future electricity 

prices. The low net benefits estimate and the high net benefits estimate are based on the 

low and high electricity price scenarios from the AEO2013 forecast, respectively.

14

Using a 7-percent discount rate for benefits and costs, the cost in the primary estimate of 

the standards proposed in this rule is $20 million per year in increased equipment costs. 

(Note that DOE used a 3-percent discount rate along with the corresponding SCC series 

value of $39.7/ton in 2012$ to calculate the monetized value of CO2 emissions 

reductions.) The annualized benefits are $104 million per year in reduced equipment 

operating costs, $27 million in CO2 reductions, and $0.32 million in reduced NOx

emissions. In this case, the annualized net benefit amounts to $110 million. At a 3-

percent discount rate for all benefits and costs, the cost in the primary estimate of the 

amended standards proposed in this notice is $21 million per year in increased equipment 

costs. The benefits are $121 million per year in reduced operating costs, $27 million in 

14 The AEO2013 scenarios used are the “High Economics” and “Low Economics” scenarios.

17

 
CO2 reductions, and $0.55 million in reduced NOx emissions. In this case, the net benefit 

amounts to $128 million per year.

DOE also calculated the low net benefits and high net benefits estimates by 

calculating the operating cost savings and shipments at the AEO2013 low economic 

growth case and high economic growth case scenarios, respectively. The low and high 

benefits for incremental installed costs were derived using the low and high price 

learning scenarios. The net benefits and costs for low and high net benefits estimates 

were calculated in the same manner as the primary estimate by using the corresponding 

values of operating cost savings and incremental installed costs.

Table I.5 Annualized Benefits and Costs of Proposed Standards for Automatic 

Commercial Ice Makers

Discount 

Rate

Primary 

Estimate*

million 2012$

Low Net Benefits 

Estimate*

million 2012$

High Net 

Benefits 

Estimate*

million 2012$

Benefits

Operating Cost Savings 7% 104 98 112

3% 121 113 132

CO2 at 5% dr, average**CO2

Reduction Monetized Value 

($11.8/t case) **

5% 8 8 8

CO2 at 3% dr, average**CO2

Reduction Monetized Value 

($39.7/t case)**

3% 27 26 27

CO2 at 2.5% dr, average**CO2

Reduction Monetized Value 

($61.2/t case)**

2.5% 39 38 40

CO2 at 3% dr, 95th perc**CO2

Reduction Monetized Value 

($117/t case)**

3% 82 80 84

NOx Reduction Monetized Value 

(at $2,639/Tont case)**

7% 0.32 0.31 0.33

3% 0.55 0.53 0.58

Total Benefits (Operating Cost 

Savings, CO2 Reduction and 

NOx Reduction)†

7% 131 124 139

3% 149 139 160

Costs

Total Incremental Installed Costs 7% 20 21 20

3% 21 22 20

Net Benefits Less Costs

Comment [fp10]: Changes in Table requested by 

OIRA.

18
Total Benefits Less Incremental 

Costs 

7% 110 103 120

3% 128 118 140

* The primary, low, and high estimates utilize forecasts of energy prices from the AEO2013 Reference Case, Low 

Economic Growth Case, and High Economic Growth Case, respectively.

** TheseThe CO2 values represent global monetized values (of the SCC, in 2012$) of the social cost of CO2

emissions$, in 2015 under several scenarios. of the updated SCC values. The values of $11.98, $39.7, and $61.2 per 

ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, 

respectively. The value of $117.0 per ton represents the 95th percentile of the SCC distribution calculated using a 3-

percent discount rate. See section IV.L for details. For NOx, an average value ($2,639) of the low ($468) and high 

($4,809) values was used.

† Total monetary benefits for both the 3-percent and 7-percent cases utilize the central estimate of social cost of NOx

and CO2 emissions calculated at a 3-percent discount rate (averaged across three integrated assessment models) , 

which is equal to $40.839.7/ton (in 2012$).

DOE has tentatively concluded that the proposed standards represent the

maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in significant conservation of energy (42 U.S.C. 

6295(o)(2)(B) and 6313(d)(4)) DOE further notes that technologies used to achieve these 

standard levels are already commercially available for the equipment classes covered by 

this notice. Based on the analyses described above, DOE has tentatively concluded that 

the benefits of the proposed standards to the Nation (energy savings, positive NPV of 

customer benefits, customer LCC savings, and emission reductions) would outweigh the 

burdens (loss of INPV for manufacturers and LCC increases for some customers). 

DOE also considered more-stringent energy use levels as trial standard levels

(TSLs), and is still considering them in this rulemaking. However, DOE has tentatively 

concluded that the potential burdens of the more-stringent energy use levels would 

outweigh the projected benefits. Based on consideration of the public comments DOE 

receives in response to this proposed rule and related information collected and analyzed 

during the course of this rulemaking effort, DOE may adopt energy use levels presented 

19
in this notice that are either higher or lower than the proposed standards, or some 

combination of level(s) that incorporate the proposed standards in part. 

II. Introduction

The following section briefly discusses the statutory authority underlying this 

proposal, as well as some of the relevant historical background related to the 

establishment of standards for automatic commercial ice makers.

A. Authority

Title III, Part C of EPCA,

15 Pub. L. 94-163 (42 U.S.C. 6311-6317, as codified), 

established the Energy Conservation Program for Certain Industrial Equipment, a 

program covering certain industrial equipment, which includes the subject of this 

rulemaking: automatic commercial ice makers.

16

EPCA prescribed energy conservation standards for automatic commercial ice 

makers that produce cube type ice with capacities between 50 and 2,500 lb ice/24 hours. 

(42 U.S.C. 6313(d)(1)) EPCA requires DOE to review these standards and determine, by 

January 1, 2015, whether amending the applicable standards is technically feasible and

economically justified. (42 U.S.C. 6313(d)(3)(A)) If amended standards are technically 

feasible and economically justified, DOE must issue a final rule by the same date. (42 

15 For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1 16 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).

20

 
U.S.C. 6313(d)(3)(B)) Additionally, EPCA granted DOE the authority to conduct 

rulemakings to establish new standards for automatic commercial ice makers not covered 

by 42 U.S.C. 6313(d)(1)).)), and DOE is using that authority in this rulemaking. (42 

U.S.C. 6313(d)(2)(A)) 

Pursuant to EPCA, DOE’s energy conservation program for covered equipment 

generally consists of four parts: (1) testing; (2) labeling; (3) the establishment of Federal 

energy conservation standards; and (4) certification and enforcement procedures. Subject 

to certain criteria and conditions, DOE is required to develop test procedures to measure 

the energy efficiency, energy use, or estimated annual operating cost of each type or class 

of covered equipment. (42 U.S.C. 6314) Manufacturers of covered equipment must use 

the prescribed DOE test procedure as the basis for certifying to DOE that their equipment 

complies with the applicable energy conservation standards adopted under EPCA.

Similarly, DOE must use these test procedures to determine whether that equipment 

complies with standards adopted pursuant to EPCA. (42 U.S.C. 6295(s)) Manufacturers, 

when making representations to the public regarding the energy use or efficiency of that 

equipment, must use the prescribed DOE test procedure as the basis for such 

representations. (42 U.S.C. 6314(d)) The DOE test procedures for automatic commercial 

ice makers currently appear at title 10 of the Code of Federal Regulations (CFR) part 431, 

subpart H.

DOE must follow specific statutory criteria for prescribing amended standards for 

covered equipment. As indicated above, any amended standard for covered equipment 

Comment [fp11]: Change requested by OIRA.

21
must be designed to achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and 

6313(d)(4)) Furthermore, DOE may not adopt any standard that would not result in the 

significant conservation of energy. (42 U.S.C. 6295(o)(3) and 6313(d)(4)) DOE also may 

not prescribe a standard: (1) for certain industrial equipment, including automatic 

commercial ice makers, if no test procedure has been established for the product; or (2) if 

DOE determines by rule that the proposed standard is not technologically feasible or 

economically justified. (42 U.S.C. 6295(o)(3)(A)–(B) and 6313(d)(4)) In deciding 

whether a proposed standard is economically justified, DOE must determine whether the 

benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i) and 6313(d)(4)) 

DOE must make this determination after receiving comments on the proposed standard, 

and by considering, to the greatest extent practicable, the following seven factors:

1. The economic impact of the standard on manufacturers and consumers of the 

equipment subject to the standard;

2. The savings in operating costs throughout the estimated average life of the 

covered equipment in the type (or class) compared to any increase in the price, 

initial charges, or maintenance expenses for the covered equipment that are 

likely to result from the imposition of the standard; 

3. The total projected amount of energy, or as applicable, water, savings likely to 

result directly from the imposition of the standard;

4. Any lessening of the utility or the performance of the covered equipment 

likely to result from the imposition of the standard;

22
5. The impact of any lessening of competition, as determined in writing by the 

U.S. Attorney General (Attorney General), that is likely to result from the 

imposition of the standard;

6. The need for national energy and water conservation; and

7. Other factors the Secretary of Energy (Secretary) considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII) and 6313(d)(4))

EPCA, as codified, also contains what is known as an “anti-backsliding” 

provision, which prevents the Secretary from prescribing any amended standard that 

either increases the maximum allowable energy use or decreases the minimum required 

energy efficiency of covered equipment. (42 U.S.C. 6295(o)(1) and 6313(d)(4)) Also, the 

Secretary may not prescribe an amended or new standard if interested persons have 

established by a preponderance of the evidence that the standard is likely to result in the 

unavailability in the United States of any covered product type (or class) of performance 

characteristics (including reliability), features, sizes, capacities, and volumes that are 

substantially the same as those generally available in the United States. (42 U.S.C. 

6295(o)(4) and 6313(d)(4))

Further, EPCA, as codified, establishes a rebuttable presumption that a standard is 

economically justified if the Secretary finds that the additional cost to the consumer of 

purchasing a product complying with an energy conservation standard level will be less 

than three times the value of the energy savings during the first year that the consumer 

will receive as a result of the standard, as calculated under the applicable test procedure.

23
(See 42 U.S.C. 6295(o)(2)(B)(iii) and 6313(d)(4)) Section III.E.2 presents additional 

discussion about rebuttable presumption payback period (RPBP).

Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating a 

standard for a type or class of covered equipment. DOE must specify a different standard 

level than that which applies generally to such type or class of equipment for any group 

of covered products that has the same function or intended use if DOE determines that 

products within such group (A) consume a different kind of energy from that consumed 

by other covered equipment within such type (or class); or (B) have a capacity or other 

performance-related feature that other equipment within such type (or class) do not have 

and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In 

determining whether a performance-related feature justifies a different standard for a 

group of equipment, DOE must consider such factors as the utility to the consumer of the 

feature and other factors DOE deems appropriate. Id. Any rule prescribing such a 

standard must include an explanation of the basis on which such higher or lower level 

was established. (42 U.S.C. 6295(q)(2))

Federal energy conservation requirements generally supersede State laws or 

regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 

6297(a)-(c) and 6316(f)) DOE may, however, grant waivers of Federal preemption for 

particular State laws or regulations, in accordance with the procedures and other 

provisions set forth under 42 U.S.C. 6297(d) and 6316(f).

24
DOE has also reviewed this regulation pursuant to Executive Order 13563, issued 

on January 18, 2011. 76 FR 3821 (Jan. 21, 2011). Executive Order 13563 is supplemental 

to and explicitly reaffirms the principles, structures, and definitions governing regulatory 

review established in Executive Order 12866. 58 FR 51735 (Oct. 4, 1993). To the extent 

permitted by law, agencies are required by Executive Order 13563 to: (1) propose or 

adopt a regulation only upon a reasoned determination that its benefits justify its costs 

(recognizing that some benefits and costs are difficult to quantify); (2) tailor regulations 

to impose the least burden on society, consistent with obtaining regulatory objectives, 

taking into account, among other things, and to the extent practicable, the costs of 

cumulative regulations; (3) select, in choosing among alternative regulatory approaches, 

those approaches that maximize net benefits (including potential economic, 

environmental, public health and safety, and other advantages; distributive impacts; and 

equity); (4) to the extent feasible, specify performance objectives, rather than specifying 

the behavior or manner of compliance that regulated entities must adopt; and (5) identify 

and assess available alternatives to direct regulation, including providing economic 

incentives to encourage the desired behavior, such as user fees or marketable permits, or 

providing information upon which choices can be made by the public. 76 FR 3821 (Jan. 

21, 2011).

DOE emphasizes as well that Executive Order 13563 requires agencies to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, the Office of Information and Regulatory Affairs

(OIRA) has emphasized that such techniques may include identifying changing future 

25
compliance costs that might result from technological innovation or anticipated 

behavioral changes. 76 FR 3821 (Jan. 21, 2011). For the reasons stated in the preamble, 

DOE believes that this NOPR is consistent with these principles, including the 

requirement that, to the extent permitted by law, benefits justify costs and that net 

benefits are maximized. 

Consistent with Executive Order 13563, and the range of impacts analyzed in this 

rulemaking, the standards proposed herein by DOE achieves maximum net benefits.

B. Background

1. Current Standards

In a final rule published on October 18, 2005, DOE adopted the energy 

conservation standards and water conservation standards prescribed by EPCA in 42 

U.S.C. 6313(d)(1) for certain automatic commercial ice makers manufactured on or after 

January 1, 2010. 70 FR at 60407, 60415-16. These standards consist of maximum energy 

use and maximum condenser water use to produce 100 pounds of ice for automatic 

commercial ice makers with harvest rates between 50 and 2,500 lb ice/24 hours. These 

standards appear at 10 CFR part 431, subpart H, Automatic Commercial Ice Makers.

Table II.1Table II.1 presents DOE’s current energy conservation standards for automatic 

commercial ice makers.

26
Table II.1 Automatic Commercial Ice Makers Standards Prescribed by EPCA –

Compliance Required Beginning on January 1, 2010

Equipment Type Type of 

Cooling

Harvest Rate

lb ice/24 hours

Maximum 

Energy Use

kWh/100 lb ice

Maximum Condenser 

Water Use*

gal/100 lb ice

Ice-Making Head

Water

<500 7.8-0.0055H** 200-0.022H**

≥500 and <1,436 5.58-0.0011H 200-0.022H

≥1,436 4.0 200-0.022H

Air <450 10.26-0.0086H Not Applicable

≥450 6.89-0.0011H Not Applicable

Remote Condensing (but not 

remote compressor) Air <1,000 8.85-0.0038H Not Applicable

≥1,000 5.10 Not Applicable

Remote Condensing and 

Remote Compressor Air <934 8.85-0.0038H Not Applicable

≥934 5.30 Not Applicable

Self-Contained

Water <200 11.4-0.019H 191-0.0315H

≥200 7.60 191-0.0315H

Air <175 18.0-0.0469H Not Applicable

≥175 9.80 Not Applicable

Source: 42 U.S.C. 6313(d).

* Water use is for the condenser only and does not include potable water used to make ice.

** H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate.

2. History of Standards Rulemaking for Automatic Commercial Ice Makers

As stated above, EPCA prescribes energy conservation standards and water 

conservation standards for certain cube type automatic commercial ice makers with 

harvest rates between 50 and 2,500 lb ice/24 hours: self-contained ice makers and icemaking heads (IMHs) using air or water for cooling and ice makers with remote

condensing with or without a remote compressor. Compliance with these standards was 

required as of January 1, 2010. (42 U.S.C. 6313(d)(1)) DOE adopted these standards and 

placed them under 10 CFR part 431, subpart H, Automatic Commercial Ice Makers.

In addition, EPCA requires DOE to conduct a rulemaking to determine whether to 

amend the standards established under 42 U.S.C. 6313(d)(1), and if DOE determines that 

amendment is warranted, DOE must also issue a final rule establishing such amended 

standards by January 1, 2015. (42 U.S.C. 6313(d)(3)(A))

27
Furthermore, EPCA granted DOE authority to set standards for additional types of 

automatic commercial ice makers that are not covered in 42 U.S.C. 6313(d)(1). (42 

U.S.C. 6313(d)(2)(A)) While not enumerated in EPCA, additional types of automatic 

commercial ice makers DOE identified as candidates for standards to be established in 

this rulemaking include flake and nugget, as well as batch type ice makers that are not 

included in the EPCA definition of cube type ice makers.

To satisfy its requirement to conduct a rulemaking, DOE initiated the current 

rulemaking on November 4, 2010 by publishing on its website its “Rulemaking 

Framework for Automatic Commercial Ice Makers.” (The Framework document is 

available at: www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0037-

0024.)

DOE also published a notice in the Federal Register announcing the availability of 

the Framework document, as well as a public meeting to discuss the document. The 

notice also solicited comment on the matters raised in the document. 75 FR 70852 (Nov. 

19, 2010). The Framework document described the procedural and analytical approaches 

that DOE anticipated using to evaluate amended standards for automatic commercial ice 

makers, and identified various issues to be resolved in the rulemaking.

DOE held the Framework public meeting on December 16, 2010, at which it: (1) 

presented the contents of the Framework document; (2) described the analyses it planned 

28
to conduct during the rulemaking; (3) sought comments from interested parties on these 

subjects; and (4) in general, sought to inform interested parties about, and facilitate their 

involvement in, the rulemaking. Major issues discussed at the public meeting included: 

(1) the scope of coverage for the rulemaking; (2) equipment classes; (3) analytical 

approaches and methods used in the rulemaking; (4) impacts of standards and burden on 

manufacturers; (5) technology options; (6) distribution channels, shipments, and end 

users; (7) impacts of outside regulations; and (8) environmental issues. At the meeting 

and during the comment period on the Framework document, DOE received many 

comments that helped it identify and resolve issues pertaining to automatic commercial 

ice makers relevant to this rulemaking. These comments are discussed in subsequent 

sections of this notice.

DOE then gathered additional information and performed preliminary analyses to 

help review standards for this equipment. This process culminated in DOE publishing a

notice of another public meeting (the January 2012 notice) to discuss and receive 

comments regarding the tools and methods DOE used in performing its preliminary 

analysis, as well as the analyses results. 77 FR 3404 (Jan. 24, 2012). DOE also invited 

written comments on these subjects and announced the availability on its website of a 

preliminary analysis technical support document (preliminary analysis TSD). Id. (The 

preliminary analysis TSD is available at:

www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0037-0026. Finally, 

DOE sought comments concerning other relevant issues that could affect amended

29
standards for automatic commercial ice makers, or that DOE should address in this 

NOPR. Id.

The preliminary analysis TSD provided an overview of DOE’s review of the

standards for automatic commercial ice makers, discussed the comments DOE received 

in response to the Framework document, and addressed issues including the scope of 

coverage of the rulemaking. The document also described the analytical framework that 

DOE used (and continues to use) in considering amended standards for automatic 

commercial ice makers, including a description of the methodology, the analytical tools, 

and the relationships between the various analyses that are part of this rulemaking. 

Additionally, the preliminary analysis TSD presented in detail each analysis that DOE 

had performed for this equipment up to that point, including descriptions of inputs, 

sources, methodologies, and results. These analyses were as follows:

• A market and technology assessment addressed the scope of this rulemaking, 

identified existing and potential new equipment classes for automatic 

commercial ice makers, characterized the markets for this equipment, and 

reviewed techniques and approaches for improving its efficiency;

• A screening analysis reviewed technology options to improve the efficiency of 

automatic commercial ice makers, and weighed these options against DOE’s 

four prescribed screening criteria;

• An engineering analysis estimated the manufacturer selling prices (MSPs) 

associated with more energy-efficient automatic commercial ice makers; 

30
• An energy and water use analysis developed the annual energy and water

usage values for economic analysis of automatic commercial ice makers;

• A markups analysis converted estimated MSPs derived from the engineering 

analysis to customer purchase prices;

• A life-cycle cost analysis calculated, for individual customers, the discounted 

savings in operating costs throughout the estimated average life of automatic 

commercial ice makers, compared to any increase in installed costs likely to 

result directly from the imposition of a given standard;

• A payback period analysis estimated the amount of time it would take 

customers to recover the higher purchase price of more energy-efficient 

equipment through lower operating costs;

• A shipments analysis estimated shipments of automatic commercial ice 

makers over the time period examined in the analysis; 

• A national impact analysis (NIA) assessed the national energy savings (NES), 

and the national NPV of total customer costs and savings, expected to result 

from specific, potential energy conservation standards for automatic 

commercial ice makers; and

• A preliminary manufacturer impact analysis (MIA) took the initial steps in 

evaluating the potential effects on manufacturers of amended efficiency 

standards. 

The public meeting announced in the January 2012 notice took place on February 

16, 2012 (February 2012 preliminary analysis public meeting). At the February 2012 

31
preliminary analysis public meeting, DOE presented the methodologies and results of the 

analyses set forth in the preliminary analysis TSD. Interested parties provided comments

on the following issues: (1) equipment classes; (2) technology options; (3) energy 

modeling and validation of engineering models; (4) cost modeling; (5) market 

information, including distribution channels and distribution markups; (6) efficiency 

levels; (7) life-cycle costs to customers, including installation, repair and maintenance 

costs, and water and wastewater prices; and (8) historical shipments. The comments 

received since publication of the January 2012 notice, including those received at the 

February 2012 preliminary analysis public meeting, have contributed to DOE’s proposed 

resolution of the issues in this rulemaking as they pertain to automatic commercial ice 

makers. This NOPR responds to the issues raised by the comments. (A parenthetical 

reference at the end of a quotation or paraphrase provides the location of the item in the 

public record.)

III. General Discussion

A. List of Equipment Class Abbreviations

In this notice, equipment class names are frequently abbreviated. The 

abbreviations are shown on Table III.1Table III.1.

Table III.1 List of Equipment Class Abbreviations

Abbreviation Equipment Type Condenser 

Type

Rated Harvest 

Rate

lb ice / 24 hours

Ice Type

IMH-W-Small-B Ice-Making Head Water <500 Batch

IMH-W-Med-B Ice-Making Head Water ≥500 and <1,436 Batch

IMH-W-Large-B* Ice-Making Head Water ≥1,436 and <4,000 Batch

IMH-A-Small-B Ice-Making Head Air <450 Batch

IMH-A-Large-B*,**

(also IMH-A-Large-B-1) Ice-Making Head Air ≥450 and <875 Batch

IMH-A-Extended-B*,** Ice-Making Head Air ≥875 and <4,000 Batch

32
(also IMH-A-Large-B-2)

RCU-NRC-Small-B Remote Condensing, not 

Remote Compressor Air <1,000 Batch

RCU-NRC-Large-B* Remote Condensing, not 

Remote Compressor Air ≥1,000 and <4,000 Batch

RCU-RC-Small-B Remote Condensing, and 

Remote Compressor Air <934 Batch

RCU-RC-Large-B Remote Condensing, and 

Remote Compressor Air ≥934 and <4,000 Batch

SCU-W-Small-B Self-Contained Unit Water <200 Batch

SCU-W-Large-B Self-Contained Unit Water ≥200 and <4,000 Batch

SCU-A-Small-B Self-Contained Unit Air <175 Batch

SCU-A-Large-B Self-Contained Unit Air ≥175 and <4,000 Batch

IMH-W-Small-C Ice-Making Head Water <900 Continuous

IMH-W-Large-C Ice-Making Head Water ≥900 and <4,000 Continuous

IMH-A-Small-C Ice-Making Head Air <700 Continuous

IMH-A-Large-C Ice-Making Head Air ≥700 and <4,000 Continuous

RCU-NRC-Small-C Remote Condensing, not 

Remote Compressor Air <850 Continuous

RCU-NRC-Large-C Remote Condensing, not 

Remote Compressor Air ≥850 and <4,000 Continuous

RCU-RC-Small-C Remote Condensing, and 

Remote Compressor Air <850 Continuous

RCU-RC-Large-C Remote Condensing, and 

Remote Compressor Air ≥850 and <4,000 Continuous

SCU-W-Small-C Self-Contained Unit Water <900 Continuous

SCU-W-Large-C Self-Contained Unit Water ≥900 and <4,000 Continuous

SCU-A-Small-C Self-Contained Unit Air <700 Continuous

SCU-A-Large-C Self-Contained Unit Air ≥700 and <4,000 Continuous

*IMH-W-Large-B, IMH-A-Large-B, and RCU-NRC-Large-B were modeled in some NOPR analyses as two different 

units, one at the lower end of the rated harvest range and one near the high end of the rated harvest range in which a 

significant number of units are available. In the LCC and NIA models, the low and high harvest rate models were 

denoted simply as B-1 and B-2. Where appropriate, the analyses add or perform weighted averages of the two typical 

sizes to present class level results.

**IMH-A-Large-B was established by EPACT-2005 as a class between 450 and 2,500 lb ice/24 hours. In this notice, 

DOE is proposing to divide this into two classes, which could either be considered “Large” and “Very Large” or 

“Medium” and “Large.” In the LCC and NIA modeling, this was denoted as B-1 and B-2. The rated harvest 

capacityrate break point shown above is based on TSL 3 results.

B. Test Procedures 

On December 8, 2006, DOE published a final rule in which it adopted AirConditioning and Refrigeration Institute (ARI) Standard 810-2003, “Performance Rating 

of Automatic Commercial Ice Makers,” with a revised method for calculating energy use, 

as the DOE test procedure for this equipment. The DOE rule included a clarification to

the energy use rate equation to specify that the energy use be calculated using the entire 

mass of ice produced during the testing period, normalized to 100 lb of ice produced. 71 

33
FR 71340, 71350 (Dec. 8, 2006). ARI Standard 810-2003 requires performance tests to 

be conducted according to the American National Standards Institute (ANSI)/American 

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

29-1988 (reaffirmed 2005), “Method of Testing Automatic Ice Makers.” The DOE test 

procedure incorporated by reference the ANSI/ASHRAE Standard 29-1988 (Reaffirmed 

2005) as the method of test.

On January 11, 2012, DOE published a test procedure final rule (2012 test 

procedure final rule) in which it adopted several amendments to the DOE test procedure. 

This included an amendment to incorporate by reference Air-Conditioning, Heating, and 

Refrigeration Institute (AHRI) Standard 810-2007, which amends ARI Standard 810-

2003 to expand the capacity range of covered equipment, provide definitions and specific 

test procedures for batch and continuous type ice makers, and provide a definition for ice 

hardness factor, as the DOE test procedure for this equipment. 77 FR 1591 (Jan. 11, 

2012). In March 2011, AHRI published Addendum 1 to Standard 810-2007, which 

revised the definition of “potable water use rate” and added new definitions for “purge or 

dump water” and “harvest water.” DOE’s 2012 test procedure final rule incorporated this 

addendum to the AHRI Standard. The 2012 test procedure final rule also included an 

amendment to incorporate by reference the updated ANSI/ASHRAE Standard 29-2009.

Id.

In addition, the 2012 test procedure final rule included several amendments 

designed to address issues that were not accounted for by the previous DOE test 

34
procedure. 77 FR at 1593 (Jan. 11, 2012). First, DOE expanded the scope of the test 

procedure to include equipment with capacities from 50 to 4,000 lb ice/24 hours.17 DOE 

also adopted amendments to provide test methods for continuous type ice makers and to 

standardize the measurement of energy and water use for continuous type ice makers 

with respect to ice hardness. In the 2012 test procedure final rule, DOE also clarified the 

test method and reporting requirements for remote condensing automatic commercial ice 

makers designed for connection to remote compressor racks. Finally, the 2012 test 

procedure final rule discontinued the use of the clarified energy use rate calculation and 

instead required energy-use to be calculated per 100 lb of ice as specified in 

ANSI/ASHRAE Standard 29-2009. The 2012 test procedure final rule became effective 

on February 10, 2012, and the changes set forth in the final rule became mandatory for 

equipment testing starting January 7, 2013. 77 FR at 1593 (Jan. 11, 2012).

The test procedure amendments established in the 2012 test procedure final rule 

are required to be used in conjunction with any new standards promulgated as a result of 

this standards rulemaking. Use of the amended test procedure to demonstrate compliance 

with DOE energy conservation standards or for representations with respect to energy 

consumption of automatic commercial ice makers is required on the compliance date of 

any energy conservation standards established as part of this rulemaking, and on January 

17 EPCA defines automatic commercial ice maker in 42 U.S.C. 6311(19) as “a factory-made assembly (not 

necessarily shipped in 1 package) that—(1) Consists of a condensing unit and ice-making section operating 

as an integrated unit, with means for making and harvesting ice; and (2) May include means for storing ice, 

dispensing ice, or storing and dispensing ice.” This definition includes commercial ice-making equipment 

up to 4,000 lb ice/24 hours, though DOE had not previously established test procedures and standards for 

units with the capacity between 2,500 and 4,000 lb ice/24 hours. While 42 U.S.C. 6313(d)(1) explicitly sets 

standards for cube type ice makers up to 2,500 lb ice/24 hours, 6313(d)(2) provides authority to set 

standards for other equipment types—all of which are covered by the EPCA definition of an automatic 

commercial ice maker.

35

 
7, 2013 for the energy conservation standards set in the Energy Policy Act of 2005 

(EPACT 2005). 77 FR at 1593 (Jan. 11, 2012).

C. Technological Feasibility

1. General

In each standards rulemaking, DOE conducts a screening analysis, which it bases

on information that it has gathered on all current technology options and prototype 

designs that could improve the efficiency of the products or equipment that are the 

subject of the rulemaking. As the first step in such analysis, DOE develops a list of 

design options for consideration, in consultation with manufacturers, design engineers, 

and other interested parties. DOE then determines which of these options for improving 

efficiency are technologically feasible. DOE considers a design option to be 

technologically feasible if it is used by the relevant industry or if a working prototype has 

been developed. Technologies incorporated in commercially available equipment or in 

working prototypes will be considered technologically feasible. 10 CFR 430, subpart C, 

appendix A, section 4(a)(4)(i) Although DOE considers technologies that are proprietary, 

it will not consider efficiency levels that can only be reached through the use of 

proprietary technologies (i.e., a unique pathway), which could allow a single 

manufacturer to monopolize or control the market.

Once DOE has determined that particular design options are technologically 

feasible, it further evaluates each of these design options in light of the following

additional screening criteria: (1) practicability to manufacture, install, or service; (2) 

36
adverse impacts on product utility or availability; and (3) adverse impacts on health or 

safety. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(ii)–(iv) Chapter 4 of the 

NOPR TSD discusses the results of the screening analyses for automatic commercial ice 

makers. Specifically, it presents the designs DOE considered, those it screened out, and 

those that are the bases for the TSLs in this rulemaking.

2. Maximum Technologically Feasible Levels

When DOE proposes to adopt (or not adopt) an amended or new energy 

conservation standard for a type or class of covered equipment such as automatic 

commercial ice makers, it determines the maximum improvement in energy efficiency 

that is technologically feasible for such equipment. (See 42 U.S.C. 6295(p)(1) and 

6313(d)(4)) Accordingly, in the preliminary analysis, DOE determined the maximum 

technologically feasible (“max-tech”) improvements in energy efficiency for automatic 

commercial ice makers in the engineering analysis using the design parameters that

passed the screening analysis. See chapter 5 of the NOPR TSD for the results of the 

analyses, and a list of technologies included in max-tech equipment.

As indicated previously, whether efficiency levels exist or can be achieved in 

commonly used equipment is not relevant to whether they are max-tech levels. DOE 

considers technologies to be technologically feasible if they are incorporated in any 

currently available equipment or working prototypes. Hence, a max-tech level results 

from the combination of design options predicted to result in the highest efficiency level 

possible for an equipment class, with such design options consisting of technologies 

37
already incorporated in commercial equipment or working prototypes. DOE notes that it 

reevaluated the efficiency levels, including the max-tech levels, when it updated its 

results for this NOPR. Table III.2Table III.2 and Table III.3Table III.3 show the max-tech 

levels determined in the engineering analysis for batch and continuous type automatic 

commercial ice makers, respectively.

Table III.2 Max-Tech Levels for Batch Automatic Commercial Ice Makers

Equipment Type * Energy Use Lower than Baseline

IMH-W-Small-B 30%

IMH-W-Med-B 22%

IMH-W-Large-B 17% (at 1,500 lb ice/24 hours)

16% (at 2,600 lb ice/24 hours)

IMH-A-Small-B 33%

IMH-A-Large-B 33% (at 800 lb ice/24 hours)

21% (at 1,500 lb ice /24 hours)

RCU-Small-B Not analyzed – similar to IMH-A-Large-B (1500)

RCU-Large-B 21% (at 1,500 lb ice/24 hours)

21% (at 2,400 lb ice/24 hours)

SCU-W-Small-B Not analyzed - similar to SCU-A-Large-B

SCU-W-Large-B 35%

SCU-A-Small-B 41%

SCU-A-Large-B 36%

* IMH is ice-making head; RCU is remote condensing unit; SCU is self-contained 

unit; W is water-cooled; A is air-cooled; Small refers to the lowest harvest category; 

Med refers to the Medium category (water-cooled IMH only); Large refers to the large 

size category; RCU units were modeled as one with line losses used to distinguish 

standards. 

** For equipment classes that were not analyzed, DOE did not develop specific costefficiency curves but attributed the curve (and maximum technology point) from one 

of the analyzed equipment classes

Table III.3 Max-Tech Levels for Continuous Automatic Commercial Ice Makers

Equipment Type Energy Use Lower than Baseline

IMH-W-Small-C Not analyzed – similar to IMH-A-Large-C (820)

IMH-W-Large-C Not analyzed at 1,000 lb/day – similar to IMH-ALarge-C (820)

Not analyzed at 1,800 lb/day – similar to IMH-ALarge-C (820)

IMH-A-Small-C 25.3%

IMH-A-Large-C 17% (at 820 lb ice/24 hours)

Not analyzed at 1,800 lb/day – similar to IMH-ALarge-C (820)

RCU-Small-C Not analyzed – similar to IMH-A-Large-C (820)

RCU-Large-C Not analyzed – similar to IMH-A-Large-C (820)

SCU-W-Small-C Not analyzed – similar to SCU-A-Small-C

SCU-W-Large-C* No units available

SCU-A-Small-C 24%

SCU-A-Large-C* No units available

38
* DOE’s investigation of equipment on the market revealed that there are no existing 

products in either of these two equipment classes (as defined in this NOPR).

** For equipment classes that were not analyzed, DOE did not develop specific costefficiency curves but attributed the curve (and maximum technology point) from one 

of the analyzed equipment classes

D. Energy and Water Savings

1. Determination of Savings

For each TSL, DOE projected energy savings from automatic commercial ice 

makers purchased in the 30-year period that begins in the year of compliance with 

amended and new standards (2018–2047). The savings are measured over the entire 

lifetime of equipment purchased in the 30-year period. DOE quantified the energy 

savings attributable to each TSL as the difference in energy consumption between each 

standards case and the base case. The base case represents a projection of energy 

consumption in the absence of amended mandatory efficiency standards, and considers 

market forces and policies that affect demand for more-efficient equipment. 

DOE used its NIA spreadsheet model to estimate energy savings from amended 

standards for the equipment that are the subject of this rulemaking. The NIA spreadsheet 

model (described in section IV.H of this notice) calculates energy savings in site energy, 

which is the energy directly consumed by equipment at the locations where they are used. 

Because automatic commercial ice makers use water, water savings were 

quantified in the same way as energy savings. 

For electricity, DOE reports national energy savings in terms of the savings in 

energy that is used to generate and transmit the site electricity. To convert this quantity, 

39
DOE derives annual conversion factors from the model used to prepare the Energy 

Information Administration’s (EIA’s) Annual Energy Outlook.

DOE has also begun to estimate full-fuel-cycle (FFC) energy savings. 76 FR 

51282 (Aug. 18, 2011). The FFC metric includes the energy consumed in extracting, 

processing, and transporting primary fuels, and thus presents a more complete picture of 

the impacts of efficiency standards. DOE’s approach is based on calculation of an FFC 

multiplier for each of the fuels used by covered equipment.

2. Significance of Savings

As noted above, 42 U.S.C. 6295(o)(3)(B) prevents DOE from adopting a standard 

for a covered product unless such standard would result in “significant” energy savings. 

Although the term “significant” is not defined in the Act, the U.S. Court of Appeals, in 

Natural Resources Defense Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985), 

indicated that Congress intended “significant” energy savings in this context to be 

savings that were not “genuinely trivial.” The estimated energy savings in the 30-year 

analysis period for the TSLs (presented in section V.A) are nontrivial, and, therefore, 

DOE considers them “significant” within the meaning of section 325 of EPCA.

E. Economic Justification

1. Specific Criteria

EPCA provides seven factors to be evaluated in determining whether a potential 

energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i) and 

40
6313(d)(4)) The following sections generally discuss how DOE is addressing each of 

those seven factors in this rulemaking. For further details and the results of DOE’s 

analyses pertaining to economic justification, see sections IV and V of today’s 

rulemaking.

a. Economic Impact on Manufacturers and Commercial Customers

In determining the impacts of an amended standard on manufacturers, DOE first 

uses an annual cash flow approach to determine the quantitative impacts. This step 

includes both a short-term assessment—based on the cost and capital requirements during 

the period between when a regulation is issued and when entities must comply with the 

regulation—and a long-term assessment over a 30-year period. The industry-wide 

impacts analyzed include INPV, which values the industry on the basis of expected future 

cash flows; cash flows by year; changes in revenue and income; and other measures of 

impact, as appropriate. Second, DOE analyzes and reports the impacts on different types 

of manufacturers, including impacts on small manufacturers. Third, DOE considers the 

impact of standards on domestic manufacturer employment and manufacturing capacity, 

as well as the potential for standards to result in plant closures and loss of capital 

investment. Finally, DOE takes into account cumulative impacts of various DOE 

regulations and other regulatory requirements on manufacturers.

For a detailed description of the methodology used to assess the economic impact 

on manufacturers, see section IV.J of this rulemaking. For results, see section V.B.2 of 

41
this rulemaking. Additionally, chapter 12 of the NOPR TSD contains a detailed 

description of the methodology and discussion of the results.

For individual customers,

18 measures of economic impact include the changes in 

LCC and the PBP associated with new or amended standards. The LCC, which is 

specified separately in EPCA as one of the seven factors to be considered in determining 

the economic justification for a new or amended standard, 42 U.S.C. 6295(o)(2)(B)(i)(II), 

is discussed in the following section. For customers in the aggregate, DOE also calculates 

the national net present value of the economic impacts applicable to a particular 

rulemaking. For a description of the methodology used for assessing the economic impact 

on customers, see sections IV.G and IV.H; for results, see sections V.B.1 and V.B.2 of 

this rulemaking. Additionally, chapters 8 and 10 and the associated appendices of the 

NOPR TSD contain a detailed description of the methodology and discussion of the 

results. For a description of the methodology used to assess the economic impact on 

manufacturers, see section IV.J; for results, see section V.B.2 of this rulemaking. 

Additionally, chapter 12 of the NOPR TSD contains a detailed description of the 

methodology and discussion of the results.

b. Life-Cycle Costs

The LCC is the sum of the purchase price of equipment (including its installation) 

and the operating costs (including energy, water, maintenance, and repair expenditures) 

18 Customers, or consumers, in the case of commercial and industrial equipment, are considered to be the 

businesses that purchase or lease the equipment or may be responsible for the cost of operating the 

equipment.

42

 
discounted over the lifetime of the equipment. The LCC savings for the considered 

efficiency levels are calculated relative to a base case that reflects projected market trends 

in the absence of new or amended standards. The LCC analysis requires a variety of 

inputs, such as product prices, product energy and water consumption, energy and water 

prices, maintenance and repair costs, product lifetime, and consumer discount rates. For 

its analysis, DOE assumes that consumers will purchase the considered equipment in the 

first year of compliance with amended standards.

To account for uncertainty and variability in specific inputs, such as equipment 

lifetime and discount rate, DOE uses a distribution of values, with probabilities attached 

to each value. DOE identifies the percentage of customers estimated to receive LCC 

savings, or experience an LCC increase, in addition to the average LCC savings 

associated with a particular standard level. DOE also evaluates the LCC impacts of

potential standards on identifiable subgroups of customers that may be affected 

disproportionately by a national standard. For the results of DOE’s analyses related to the 

LCC, see section V.B.1 of this rulemaking and chapter 8 of the NOPR TSD; for LCC 

impacts on identifiable subgroups, see section V.B.1 of this notice and chapter 11 of the 

NOPR TSD.

c. Energy Savings

Although significant conservation of energy is a separate statutory requirement 

for imposing an energy conservation standard, EPCA requires DOE, in determining the 

economic justification of a standard, to consider the total projected energy savings that 

43
are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III) and 

6313(d)(4)) As discussed in section VI.B.3, DOE uses the NIA spreadsheet to project

energy savings.

d. Lessening of Utility or Performance of Equipment

In establishing classes of equipment, and in evaluating design options and the 

impact of potential standard levels, DOE evaluates standards that would not lessen the 

utility or performance of the equipment under consideration. (42 U.S.C. 

6295(o)(2)(B)(i)(IV) and 6313(d)(4)) The standards proposed in today’s rulemaking will 

not reduce the utility or performance of the equipment considered in the rulemaking. For

DOE’s analyses related to the potential impact of amended standards on equipment utility 

and performance, see section V.B.4 of this rulemaking and chapter 4 of the NOPR TSD.

e. Impact of Any Lessening of Competition

EPCA directs DOE to consider the impact of any lessening of competition, as 

determined in writing by the Attorney General, that is likely to result from the imposition 

of a standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It directs the Attorney General to make 

such determination, if any, of any lessening of competition likely to result from a 

proposed standard, and to transmit such determination to the Secretary, within 60 days of 

the publication of a proposed rule, together with an analysis of the nature and extent of 

the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of today’s proposed 

rule to the Attorney General with a request that the Department of Justice (DOJ) provide 

44
its determination on this issue. DOE will address the Attorney General’s determination in 

the final rule.

f. Need of the Nation to Conserve Energy

The energy savings from the proposed standards are likely to provide 

improvements to the security and reliability of the nation’s energy system. Reductions in 

the demand for electricity also may result in reduced costs for maintaining the reliability 

of the nation’s electricity system. DOE conducts a utility impact analysis to estimate how 

standards may affect the nation’s needed power generation capacity. (42 U.S.C. 

6295(o)(2)(B)(i)(VI) and 6316(e)(1)) 

The proposed standards also are likely to result in environmental benefits in the 

form of reduced emissions of air pollutants and greenhouse gases (GHGs) associated with 

energy production. DOE reports the emissions impacts from today’s standards, and from 

each TSL it considered, in sections IV.K, IV.L and V.B.6 of this rulemaking. DOE also 

reports estimates of the economic value of emissions reductions resulting from the 

considered TSLs.

g. Other Factors

EPCA allows the Secretary of Energy, in determining whether a new or amended 

standard is economically justified, to consider any other factors that the Secretary deems 

to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII) and 6316(e)(1)) In developing this 

proposed rule, DOE has also considered the comments submitted by interested parties. 

45
For the results of DOE’s analyses related to other factors, see section V.B.7 of this 

rulemaking.

2. Rebuttable Presumption

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii) and 6313(d)(4), EPCA provides for a 

rebuttable presumption that an energy conservation standard is economically justified if 

the additional cost to the customer of equipment that meets the new or amended standard 

level is less than three times the value of the first year’s energy savings resulting from the 

standard, as calculated under the applicable DOE test procedure. DOE’s LCC and PBP 

analysis generates values used to calculate the effects that proposed energy conservation 

standards would have on the PBP for customers. These analyses include, but are not 

limited to, the 3-year PBP contemplated under the rebuttable presumption test. In 

addition, DOE routinely conducts an economic analysis that considers the full range of 

impacts to the customer, manufacturer, the Nation, and environment, as required under 42 

U.S.C. 6295(o)(2)(B)(i) and 6313(d)(4). The results of these analyses serve as the basis 

for DOE’s evaluation of the economic justification for a potential standard level (thereby 

supporting or rebutting the results of any preliminary determination of economic 

justification). The rebuttable presumption payback calculation is discussed in section 

IV.G.12 of this rulemaking and chapter 8 of the NOPR TSD. 

IV. Methodology and Discussion of Comments

46
A. General Rulemaking Issues

During the February 2012 preliminary analysis public meeting and in subsequent 

written comments, stakeholders provided input regarding general issues pertinent to the 

rulemaking, such as issues of scope of coverage and DOE’s authority in setting standards. 

These issues are discussed in this section. 

1. Statutory Authority

In the preliminary analysis, DOE stated its position that EPCA prevents the 

setting of both energy performance standards and prescriptive design requirements (see 

chapter 2 of the preliminary analysis TSD). DOE also stated its intent to amend the 

energy performance standards for automatic commercial ice makers, and not to set 

prescriptive design requirements at this time (see chapter 2 of the preliminary analysis 

TSD).

2. Test Procedures

As discussed in section III.A, DOE published a test procedure final rule in 

January 2012 (2012 test procedure final rule). 77 FR 1591 (Jan. 11, 2012). All automatic 

commercial ice makers covered by DOE energy conservation standards promulgated as a 

result of this energy conservation standards rulemaking will be required to use the 2012 

test procedures to demonstrate compliance beginning on the compliance date set at the 

conclusion of this rulemaking. 77 FR at 1593 (Jan. 11, 2012). The standards can be found 

at title 10 CFR part 431, subpart H (or, alternatively, 10 CFR 431.134).

47
Since the publication of the 2012 test procedure final rule, DOE has received 

several inquiries from interested parties regarding proper conduct of the DOE test 

procedure. Specifically, interested parties inquired regarding the appropriate use of 

baffles and automatic purge water controls during the DOE test procedure. On January 

28, 2013, DOE published draft guidance documents to address the issues regarding 

baffles19 and automatic purge water controls20 and provided an opportunity for interested 

parties to comment on those interpretations of the DOE test procedure for automatic 

commercial ice makers. The comment period for those guidance documents extended

until February 28, 2013. DOE will publish a final guidance document and responses to all 

comments received on the DOE Appliance and Commercial Equipment Standards 

website (www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1). However, DOE 

notes that these guidance documents serve only to clarify existing test procedure 

requirements, as established in the 2012 test procedure final rule, and do not alter the 

DOE test procedure. 

DOE’s test procedures are set in separate rulemaking processes. However, as part 

of the automatic commercial ice maker energy conservation standards rulemaking, DOE 

did receive two comments related to the test procedures. Howe noted that measuring 

potable water use is important because de-scaling is crucial for maintaining the efficiency 

and utility of automatic commercial ice makers. Howe also recommended that DOE 

19 http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/acim_baffles_faq_2013-9-24final.pdf 20 http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/acim_purge_faq_2013-9-25final.pdf

48

 
obtain information from additional manufacturers on the relationship between potable 

water use and automatic commercial ice maker performance. (Howe, No. 51 at p. 2)21

The People’s Republic of China (China) noted that there are differences among 

test processes for refrigeration products issued by different bodies in the U.S. China 

stated that different test procedures may lead to different results for one product, and it 

will affect the judgment of compliance. Therefore, China suggested that the U.S. 

government unify the test procedure. (China, No. 55 at p. 3)

As noted earlier, the 2012 test procedure final rule was published on January 11, 

2012, and the energy conservation standards will be based on this test procedure. 77 FR 

at 1593. With regard to Howe’s comment, in the final rule, DOE elected to not require 

measurement of potable water. Since DOE is not setting potable water limits for 

automatic commercial ice makers, requiring manufacturers to measure potable water use 

would be an unnecessary expense. With regard to China’s comment, DOE has no 

authority regarding adjustment of the test procedures of other organizations. Also, if there 

is any uncertainty regarding how to conduct the test, manufacturers and others may 

request clarification from DOE. By updating the test procedure to reflect current AHRI 

and ANSI/ASHRAE standards, DOE expects any differences of the type noted by China 

will be minimized.

21 A notation in this form provides a reference for information that is in the docket of DOE’s “Energy 

Conservation Program for Certain Commercial and Industrial Equipment: Energy Conservation Standards 

for Automatic Commercial Ice Makers” (Docket No. EERE-2010-BT-STD-0037), which is maintained at

www.regulations.gov. This notation indicates that the statement preceding the reference is document 

number 51 in the docket for the automatic commercial ice makers energy conservation standards 

rulemaking, and appears at page 2 of that document.

49

 
3. Need for and Scope of Rulemaking 

At the February 2012 preliminary analysis public meeting and in written 

comments, DOE received comments about the need for the rulemaking. Hoshizaki 

suggested DOE not adjust the energy standards for automatic commercial ice makers 

regulated under EPACT 2005, arguing that tightening the regulations that were just 

released 2 years ago would negatively impact both manufacturers and end users. 

(Hoshizaki, No. 53 at p. 3) AHRI opined that, because the full effects of the EPACT 2005 

standards will not be known until at least 2013, DOE should only consider the previously

uncovered continuous and high-capacity batch type ice makers in this rulemaking. 

(AHRI, No. 49 at p. 3) 

Scotsman asked whether the upcoming rulemaking would cover products that 

both make and dispense ice. (Scotsman, Public Meeting Transcript, No. 42 at p. 26)22

In response to the comments about the need for starting this rulemaking, DOE 

notes that under EPACT 2005, DOE must review the existing standards and, if justified, 

develop amended standards by January 1, 2015. Thus, DOE commenced the rulemaking

to ensure compliance with the statutory deadline. During the rulemaking, DOE 

considered alternatives to this rulemaking in the regulatory impact analysis; this analysis 

is described in Section IV.OThus, DOE does not perceive alternatives to commencing the 

22 A notation in the form “Scotsman, Public Meeting Transcript, No. 42 at p. 26” identifies a comment that 

DOE has received during a public meeting and has included in the docket of this rulemaking at 

www.regulations.gov. This particular notation refers to a comment: (1) submitted by Scotsman; (2) 

transcribed from the public meeting in document number 42 of the docket, and (3) appearing on page 26 of 

that document.

50

 
rulemaking. of today’s NOPR. As for covering products that make and dispense ice, the

scope of the rulemaking is ice-making products. While the 42 U.S.C. 6311(19) definition 

of automatic commercial ice maker stated an ice maker may or may not include a means 

for dispensing or storing ice, not all ice makers do include such ancillary equipment. As 

discussed in the preliminary analysis TSD, section 2.2.4.2, DOE determined that 

promulgating standards to regulate the energy usage of dispensers and storage bins may 

have an unintended impact on customer choices when choosing between models that 

include or do not include such ancillary equipment. By regulating energy usage of 

ancillary equipment, DOE could disincentivize the manufacturing of such equipment. If, 

and to the extent that, ice dispensing equipment use electricity, such electricity usage is 

not covered by this rulemaking.

B. Market and Technology Assessment

When beginning an energy conservation standards rulemaking, DOE develops 

information that provides an overall picture of the market for the equipment concerned,

including the purpose of the equipment, the industry structure, and market characteristics. 

This activity includes both quantitative and qualitative assessments based primarily on 

publicly available information (e.g., manufacturer specification sheets, industry 

publications) and data submitted by manufacturers, trade associations, and other 

stakeholders. The subjects addressed in the market and technology assessment for this 

rulemaking include: (1) quantities and types of equipment sold and offered for sale; (2) 

retail market trends; (3) equipment covered by the rulemaking; (4) equipment classes; (5) 

manufacturers; (6) regulatory requirements and non-regulatory programs (such as rebate 

Comment [fp12]: Change requested by OIRA.

51
programs and tax credits); and (7) technologies that could improve the energy efficiency 

of the equipment under examination. DOE researched manufacturers of automatic 

commercial ice makers and made a particular effort to identify and characterize small 

business manufacturers. See chapter 3 of the NOPR TSD for further discussion of the 

market and technology assessment.

1. Equipment Classes

In evaluating and establishing energy conservation standards, DOE generally 

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

another performance-related feature that justifies a different standard for equipment 

having such a feature. (42 U.S.C. 6295(q) and 6313(d)(4)) In deciding whether a feature 

justifies a different standard, DOE must consider factors such as the utility of the feature 

to users. Id. DOE normally establishes different energy conservation standards for 

different equipment classes based on these criteria.

Automatic commercial ice makers are divided into equipment classes based on 

physical characteristics that affect commercial application, equipment utility, and 

equipment efficiency. These equipment classes are based on the following criteria:

• Ice-making process

o “Batch” icemakers that operate on a cyclical basis, alternating between 

periods of ice production and ice harvesting

o “Continuous” icemakers that can produce and harvest ice simultaneously

• Equipment configuration

52
o Ice-making head (a single-package ice-making assembly that does not 

include an ice storage bin)

o Remote condensing

 With remote compressor (compressor packaged with the condenser)

 Without remote compressor (compressor packaged with the 

evaporator)

o Self-contained (with storage bin included)

• Condenser cooling 

o Air-cooled

o Water-cooled

• Capacity range

Table IV.1Table IV.1 shows the 25 automatic commercial ice maker equipment 

classes that DOE is including in the scope of this rulemaking. The capacity ranges for the 

continuous units have changed from the preliminary analysis.

Table IV.1 Automatic Commercial Ice Maker Equipment Classes

Type of Ice 

Maker Equipment Type

Type of 

Condenser 

Cooling

Rated Harvest 

Capacity Rate

lb ice/24 hours

Batch

Ice-Making Head

Water

≥50 and <500

≥500 and <1,436

≥1,436 and <4,000

Air ≥50 and <450

≥450 and <4,000

Remote Condensing 

(but not remote 

compressor)

Air

≥50 and <1,000

≥1,000 and <4,000

Remote Condensing 

and Remote 

Compressor

Air

≥50 and <934

≥934 and <4,000

Self-Contained Unit Water ≥50 and <200≥200 and <4,000

Air ≥50 and <175

53
≥175 and <4,000

Continuous

Ice-Making Head

Water ≥50 and <900

≥900 and <4,000

Air ≥50 and <700

≥700 and <4,000

Remote Condensing 

(but not remote 

compressor)

Air

≥50 and <850

≥850 and <4,000

Remote Condensing 

and Remote 

Compressor

Air

≥50 and <850

≥850 and <4,000

Self-Contained Unit

Water ≥50 and <900

≥900 and <4,000

Air ≥50 and <700

≥700 and <4,000

Batch type and continuous type ice makers are distinguished by the mechanics of 

their respective ice-making processes. Continuous type ice makers are so named because 

they simultaneously produce and harvest ice in one continuous, steady-state process. The 

ice produced in continuous processes is called “flake” or “nugget” ice, which is often a 

“soft” ice with high liquid water content, in the range from 10 to 35 percent, but can also 

be subcooled, i.e., be entirely frozen and at temperature lower than 32 °F. Continuous 

type ice makers were not included in the EPACT 2005 standards and are therefore not 

currently regulated by DOE energy conservation standards.

Current energy conservation standards cover batch type ice makers that produce 

“cube” ice, which is defined as ice that is fairly uniform, hard, solid, usually clear, and 

generally weighs less than two ounces (60 grams) per piece, as distinguished from flake, 

crushed, or fragmented ice. 10 CFR 431.132 Batch ice makers alternate between freezing 

and harvesting periods and therefore produce ice in discrete batches rather than in a 

continuous process. After the freeze period, hot gas is typically redirected from the 

compressor discharge to the evaporator, melting the surface of the ice cubes that is in 

54
contact with the evaporator surface, enabling them to be removed from the evaporator. 

The evaporator is then purged with potable water, which removes impurities that would 

decrease ice clarity. Consequently, batch type ice makers typically have higher potable 

water usage than continuous type ice makers.

After the publication of the Framework document, several parties commented that 

machines producing “tube” ice, which is created in a batch process identical to that which 

produces cube ice, should also be regulated. DOE notes that tube ice machines of the 

covered capacity range that produce ice fitting the definition for cube type ice are covered 

by the current standards, whether or not they are referred to as cube type ice makers 

within the industry. Nonetheless, DOE has addressed the commenters’ suggestions by 

emphasizing that all batch type ice machines are within the scope of this rulemaking, as 

long as they fall within the covered capacity range of 50 to 4,000 lb ice/24 hours. This 

includes tube ice makers and other batch type ice machines (if any) that produce ice that 

does not fit the definition of cube type ice. To help clarify this issue, DOE now refers to 

all batch automatic commercial ice makers as “batch type ice makers,” regardless of the 

shape of the ice pieces that they produce. 77 FR 1591 (Jan. 11, 2012).

During the February 2012 preliminary analysis public meeting and in subsequent 

written comments, a number of stakeholders addressed issues related to proposed 

equipment classes and the inclusion of certain types of equipment in the analysis. These 

topics are discussed in this section. 

55
a. Cabinet Size

Currently, DOE does not consider physical size as a criterion for setting 

equipment classes.

Several stakeholders commented on the size standardization of ice makers. 

Scotsman commented that most ice makers are built in standard widths of 22, 30, and 48 

inches and standard depths between 24 and 28 inches, although heights may vary slightly 

depending on the machine. (Scotsman, Public Meeting Transcript, No. 42 at p. 61) 

Manitowoc noted that the reason for this standardization is that most ice storage bins 

have standard sizes based on ice-making capacity, and the footprint of the ice maker on 

top needs to be the same as the footprint of the storage bin in order for them to fit 

together. Hence, according to Manitowoc, the industry has developed common sizes that 

have facilitated ice maker installations and replacements. (Manitowoc, Public Meeting 

Transcript, No. 42 at pp. 91–92) Howe countered that, contrary to the assertions of other 

stakeholders, there are no “standard” ice maker dimensions. (Howe, No. 51 at pp. 1–2)

Earthjustice commented that it may be helpful to use cabinet size as an additional 

criterion for defining equipment classes because the existing standard sizes of ice makers 

affect their efficiency and their utility to the consumer, both of which are factors that 

DOE typically considers in identifying equipment classes. (Earthjustice, Public Meeting 

Transcript, No. 42 at pp. 90-91) 

56
However, Manitowoc commented that it manufactures ice makers in different 

cabinet sizes that deliver the same ice-making capacity, explaining that this facilitates 

flexible installation decisions but could complicate efforts to define equipment classes by 

cabinet size. (Manitowoc, Public Meeting Transcript, No. 42 at p. 91)

The Appliance Standards Awareness Project (ASAP) commented that it would be 

helpful to see a size analysis that would elucidate the effects of size on utility to the 

customer and potential energy savings. (ASAP, Public Meeting Transcript, No. 42 at pp. 

73-74)

As noted by Manitowoc and Scotsman, there are standard sizes for ice makers. 

DOE’s review of product literature supports these claims, in contrast to Howe’s assertion 

that there are no standard sizes. However, not all customers face size constraints.

DOE notes that a reason to consider separate equipment classes based on physical 

dimensions is to address differences in energy efficiency. An important size-related factor 

that can affect the efficiency of an ice maker is the size of its heat exchangers (i.e., the 

evaporator and condenser).23 A larger evaporator can make more ice per freeze cycle. 

Hence, for a given harvest capacity rate, the cycle can be allowed to take longer, thus 

reducing the required heat transfer rate per evaporator surface. The reduced heat transfer 

rate can be provided by a lower temperature differential between the ice and the 

refrigerant. Likewise, as the surface area of a condenser increases, the temperature 

23 Other examples are use of some higher-efficiency compressors, which can be physically larger, and 

packaging of drain water heat exchangers within the equipment package.

57

 
differential between the refrigerant and the cooling medium (either air or water) 

decreases. These design changes can lead to higher evaporating temperature and lower 

condensing temperature, which both reduce the pressure differential between the 

compressor suction and discharge ports, which reduces the amount of electrical power 

necessary to compress the vapor, thus reducing energy consumption of the ice maker.

To address size limitations and to save energy, DOE could consider Earthjustice’s 

recommendation to use size as a criterion in setting equipment classes. To do so, DOE 

could establish parallel sets of equipment classes—size-constrained classes (in which 

physical size would be limited to a prescribed maximum) and non-size-constrained 

classes (for which there would be no size restrictions). In the size-constrained classes, 

DOE’s ability to set stricter energy usage limits would be limited by the constraint that 

the physical size of the unit cannot be increased. In the non-size-constrained classes, 

additional energy savings could be achieved by setting standards that increase the 

physical size of the unit as well as making the units more efficient. Accounting for size 

constraints is important in the automatic commercial ice maker industry because 

replacement sales comprise a majority of sales and equipment must be able to fit into the 

same space as the unit it replaces, and fit on existing ice storage bins, as described above. 

For opportunities in which physical size is not critical, non-size-constrained equipment 

classes could save energy relative to the size-constrained units. If DOE decided not to 

establish separate equipment classes for space-constrained equipment, it may not be 

reasonable for DOE to consider design options that significantly increase physical size of 

58
the equipment, which would limit potential efficiency gains and/or make them more 

costly, thus likely resulting in less stringent standards for size-limited equipment classes. 

Previous DOE rulemakings provide ample precedent for creating spaceconstrained equipment classes. For instance, DOE developed space-constrained 

equipment classes for packaged terminal air conditioners and through-the-wall air 

conditioners, both of which represent industries in which replacement comprises a 

majority of sales. 10 CFR 430.32 

To determine whether space constraint is an issue (i.e., whether efficiency and 

physical size are direct functions of one another), DOE followed ASAP’s suggestion and 

prepared an analysis of the size and efficiency of automatic commercial ice makers. 

Using publicly available manufacturer information, DOE collected size24 data for 

approximately 600 ice makers and mapped it to efficiency information listed in the AHRI 

database. After plotting and analyzing this data, DOE determined that, although there is a 

correlation between size and efficiency in automatic commercial ice makers, this 

correlation is not conclusive. 

Table IV.2Table IV.2 displays sample results of this size analysis, presenting 

information for two different large, air-cooled IMH batch type ice makers at each of 

several selected harvest capacities. In many cases, the larger equipment is more efficient. 

For example, among the ice makers that can produce 1,500 lb ice/24 hours, the 28 ft3

24 Size is expressed in terms of volume, calculated by multiplying unit width by unit depth and by unit 

height (width × depth × height).

59

 
products have total energy consumption values that are lower than the current energy 

consumption standard by greater than >20 percent, while the 19 ft3 products have total 

energy consumption values that are only 6 percent below the standard. In other cases, the 

data do not support this trend. For example, among the 800 lb ice/24 hour ice makers, the 

17 ft3 products are less efficient than the 11 ft3 products. Finally, in cases such as the 

1,430 lb ice/24 hour machines, there are also products with the same harvest capacity and 

volume that nonetheless have different efficiencies. Therefore, it is difficult to draw a 

decisive conclusion from this data.

Table IV.2 Relationship between Volume and Efficiency for Large IMH Air-Cooled 

Batch Ice Makers

Rated Harvest 

Rate

lb ice/24 hours

Volume

ft3

% Below Baseline 

Energy Use

500 9.1 3.2%

12.4 2.2%

800 10.8 13.5%

16.8 3.5%

1,150 18.0 13.5%

20.8 18.1%

1,430 20.1 3.0%

20.1 4.6%

1,530 19.3 6.0%

27.7 21.3%

Manitowoc noted during the February 2012 preliminary analysis public meeting 

that it produces units with the same harvest rate in different size chassis sizes, and that 

these units have very similar features. (Manitowoc, Public Meeting Transcript, No. 42 at 

p. 91) DOE, in its analysis, has noted that some manufacturers have achieved higher 

efficiencies for ice makers in smaller sizes (at constant harvest rates). Based on this 

information, DOE believes that size does affect efficiency levels (as it allows for large 

60
heat exchangers), but it is not the definitive factor in determining efficiency for ice

makers.

Therefore, DOE has determined that separate equipment classes for sizeconstrained units are not warranted. DOE notes that there is not a strong correlation 

between product size and product efficiency that supports separate equipment classes.

Furthermore, DOE believes that adding additional classes for size-constrained units 

complicates the equipment class structure and analysis but does not improve the 

rulemaking or standards.

b. Large-Capacity Batch Ice Makers

In the November 2010 Framework document for this rulemaking, DOE requested 

comments on whether coverage should be expanded from the current covered capacity 

range of 50 to 2,500 lb ice/24 hours to include ice makers producing up to 10,000 lb

ice/24 hours. All commenters agreed with expanding the harvest capacity coverage, and 

all but one of the commenters supported or accepted an upper harvest capacity cap of 

4,000 lb ice/24 hours, which would be consistent with the current test procedure, AHRI 

Standard 810-2007. Most commenters categorized ice makers with harvest capacities 

above 4,000 lb ice/24 hours as industrial rather than commercial. To be consistent with 

the majority of these comments, DOE proposed during the preliminary analysis to set the 

upper harvest capacity limit to 4,000 lb ice/24 hours, even though there are few ice 

makers currently produced with capacities ranging from 2,500 to 4,000 lb ice/24 hours. 

77 FR 3405 (Jan. 24, 2012) Since the publication of the preliminary analysis, DOE 

61
revised the test procedure, with the final rule published in January 2012, to include all 

batch and continuous type ice makers with capacities between 50 and 4,000 lb ice/24 

hours. 77 FR 1591, 1613-14 (Jan. 11, 2012). In the 2012 test procedure final rule, DOE 

noted that 4,000 lb ice/24 hours represented a reasonable limit for commercial ice 

makers, as larger-sized ice makers were generally used for industrial applications and 

testing machines up to 4,000 lb was consistent with AHRI 810-2007. 77 FR 1591 (Jan. 

11, 2012). Therefore, because DOE now has a procedure for testing ice makers with 

capacities up to 4,000 lb ice/24 hours, DOE proposes in this NOPR to set efficiency 

standards that include all ice makers in this extended capacity range.

In written comments after the publication of the preliminary analysis, AHRI and 

Manitowoc both recommended that DOE refrain from regulating products with capacities 

above 2,500 lb ice/24 hours if there are not enough high-capacity batch machines 

available for DOE to analyze. (AHRI, No. 49 at pp. 3–4; Manitowoc, No. 54 at p. 3)

DOE acknowledges that there are currently few automatic commercial ice makers 

with harvest capacities above 2,500 lb ice/24 hours. However, DOE already has a 

precedent of setting standards for harvest capacity ranges in which there are no products 

available. There are currently no IMH air-cooled ice makers on the market with harvest 

capacities above 1,650 lb ice/24 hours, yet EPACT 2005 amended EPCA to set standards 

for this equipment class of ice makers with harvest capacities up to 2,500 lb ice/24 hours. 

Because it is possible that batch-type ice makers with harvest capacities from 2,500 to 

4,000 lb ice/24 hours will be manufactured in the future, DOE does not find it 

62
unreasonable to set standards in this rulemaking for batch type ice makers with harvest 

capacities in the range up to 4,000 lb ice/24 hours. Therefore, DOE maintains its position 

to include large-capacity batch type ice makers in the scope of this rulemaking. 

However, DOE requests comment and data on the viability of the proposed standard 

levels selected for batch-type ice makers with harvest capacities from 2,500 to 4,000 lb 

ice/24 hours. The proposed standard levels are discussed in Section V.A.2 of today’s 

NOPR.

c. Efficiency/Harvest Capacity Relationship

In the current energy conservation standards, DOE uses discrete harvest capacity 

breakpoints to differentiate cube machine classes, and DOE proposes to do the same with 

new classes for continuous machines.

In reviewing industry literature, DOE found that compressor efficiency increases 

over a range of harvest rate capacities and then tends to flatten out at the higher 

capacities. This trend is illustrated in Table IV.3Table IV.3, which displays the capacities 

and energy efficiency ratios (EERs) of one family of reciprocating compressors. As 

shown in this table, the EERs of compressors in this family level off to between 6.5 and 

7.2 British thermal units per watt-hour (Btu/Wh) at capacities beyond 14,300 Btu per 

hour.

Table IV.3 Relationship of Compressor Capacity to EER

Capacity 

Btu/hr

EER 

Btu/Wh

7,970 5.8

8,440 5.1

8,840 6.0

63
9,870 6.2

10,200 5.5

10,900 6.3

11,300 5.5

12,400 7.0

12,900 6.0

14,100 5.9

14,300 6.5

14,900 6.6

18,100 7.0

18,300 6.5

18,600 6.6

19,600 5.6

22,200 6.5

22,500 7.2

24,300 7.1

24,600 6.6

26,000 6.5

29,300 6.7

29,600 6.6

30,500 6.7

31,300 6.9

34,400 6.7

36,700 6.7

42,200 6.8

Due primarily to the compressor trends discussed above, ice maker energy usage 

also varies as products increase in cooling capacity. Ice maker energy use (in kilowatthours per 100 lb of ice) decreases as the harvest rate increases in all products, but because 

the compressor trends do not continue indefinitely, the ice maker energy usage becomes 

constant at larger harvest rates. The point at which usage becomes constant for ice 

makers varies by equipment type.

DOE has traditionally used a piecewise linear approach25 to depict the standard 

levels, with the breakpoints defining the harvest capacity rate limits of different 

25 A piecewise function is a mathematical relationship where the relationship between the independent 

variable and dependent variable varies over the inspected range. Different functions are used to describe 

this relationship for each discrete interval where this relationship is defined. The piecewise function is a 

way of expressing the full relationship (http://mathworld.wolfram.com/PiecewiseFunction.html).

Comment [fp13]: Change requested in OIRA in 

footnote 25.

64

 
equipment classes. Thus, for the current energy conservation standards for batch type 

equipment, the maximum allowable energy use declines as harvest capacity increases for 

the smallest harvest capacity rate equipment classes. In contrast, for most of the larger 

harvest capacity rate equipment classes, the maximum allowable energy use is a constant. 

The one exception is the large IMH air-cooled equipment class, where the maximum 

allowable energy use continues to decrease as harvest capacity rate increases. DOE 

believes that its piecewise energy consumption limits facilitate the simple calculation of 

energy standards while accurately depicting the complex relationship between capacity 

and efficiency.

Several stakeholders commented on DOE’s decision to set piecewise efficiency 

levels according to harvest capacity. At the February 2012 preliminary analysis public 

meeting, the Northwest Power and Conservation Council (NPCC) questioned whether 

setting standards by capacity range would create discontinuous breakpoints in efficiency 

requirements that would drive manufacturers to seek one level of capacity over another to 

take advantage of a more favorable standard. (NPCC, Public Meeting Transcript, No. 42 

at p. 22) In written comments, the Northwest Energy Efficiency Alliance (NEEA), 

NPCC, and the California Investor-Owned Utilities (CA IOUs) recommended that DOE 

imitate ENERGY STAR and use a single equation for each equipment class to define 

energy consumption standards as a function of harvest rate, rather than having multiple 

efficiency standards for different harvest capacity bins. (NEEA/NPCC, No. 50 at p. 2;

CA IOUs, No. 56 at p. 2) CA IOUs added that, if DOE elects to continue distinguishing 

65
equipment classes based on harvest capacity breakpoints, it should explain its reasoning 

for doing so. (CA IOUs, No. 56 at p. 3)

The newly finalized ENERGY STAR specification eliminates discontinuities by 

using one equation for IMH and self-contained cube equipment as well as all three 

continuous equipment types, while achieving something similar to the asymptotic 

relationship mentioned by Manitowoc. The ENERGY STAR specification accomplishes 

this with equations that are more complex than those currently embodied in DOE’s cube 

ice machine standards, which have simple “intercept and slope” or “fixed and variable” 

components. For example, DOE’s current energy consumption limit for small IMH aircooled equipment is as follows:

Maximum Energy Usage (kWh) ≤ 10.26 - 0.0086H

(Where H= harvest rate capacity, up to 449 lb ice/24 hours)

The April 30, 2012 ENERGY STAR specification for the same equipment is:

Maximum Energy Usage (kWh) ≤ 37.72H-0.298

By means of a more complicated formula, the ENERGY STAR specification 

creates a continuous curve while still respecting the asymptotic relationship between 

efficiency and harvest capacity.

66
Manitowoc commented that it was not particularly important where the DOE 

places capacity breakpoints for different equipment classes as long as the breakpoints 

respect the asymptotic relationships between size and efficiency. Manitowoc also asked 

that there not be any real discontinuities at these breakpoints or discrepancies from the 

industry mean efficiency/capacity relationships. (Manitowoc, Public Meeting Transcript, 

No. 42 at pp. 25-26) CA IOUs similarly requested that DOE base its harvest capacity 

breakpoints on an investigation of the market, rather than automatically using preexisting breakpoints, and added that any new equipment classes generated by resetting 

these breakpoints must not allow backsliding. (CA IOUs, No. 56 at p. 3)

The issue raised by NPCC and echoed by Manitowoc is that the equations used in 

the standards can cause points of discontinuity where rating equipment at slightly 

different capacity levels provides a benefit to the manufacturer in terms of allowable 

energy usage. In the current standards for IMH water-cooled units, one discontinuity 

exists at 500 lb ice/24 hours, the breakpoint between the small and medium harvest 

capacity rate equipment classes, where there is a 0.1 kWh/100 lb energy use gap, 

representing 2.0 percent of the 5.04 kWh/100 lb maximum allowable energy use at this 

harvest capacity rate. However, eliminating this type of gap in the energy conservation 

standards would not require departure from a piecewise linear representation of 

maximum allowable energy use.

Fitting a curve as was done to create the ENERGY STAR limits would be more 

complicated than creating a new standard that mirrors the existing usage limit structure. It 

67
would also be more difficult for customers, such as restaurant owners, who buy ice 

makers and need to make sense of the standards because the ENERGY STAR equation 

requires a calculator or a spreadsheet, and, DOE believes, leads to more questions and 

complexity. 

The single equation approach also runs somewhat contrary to the comments 

received from manufacturers. With the single equation provided by ENERGY STAR, 

energy usage limits for large machines continue to decline to zero (albeit at diminishing 

rates). The manufacturer comments cited in the discussion of large machines above 

provided several reasons that, at very high capacities, design constraints cause these 

products to have constant energy usage across different harvest capacities. This means 

that, at a certain point, efficiency tends to become more constant as harvest capacity 

changes, as is embodied in the current standards. The single equation approach would 

make it more difficult for the DOE standards to reflect this trend in the market.

DOE has decided to continue structuring the equipment classes by utilizing 

multiple harvest rate sizes rather than moving to a single equation approach. By 

continuing to use multiple size classes, DOE will have greater flexibility to adequately 

address the efficiencies of large equipment classes. The risk of exploiting the system at 

size class break points can be mitigated by carefully developing standards. Moreover, 

DOE proposes amending the baseline energy standards to eliminate existing 

discontinuities at harvest capacity breakpoints. Note that under the DOE test procedure 

and specifically the updated ANSI/ASHRAE Standard 29-2009 that was incorporated by 

68
reference in that rule, harvest rates are to be determined at the time of test, and are not 

based on manufacturer specifications. (10 CFR 431.134) Furthermore, in EPACT 2005, 

Congress directed DOE to monitor whether manufacturers reduce harvest rates below 

tested values for the purpose of bringing non-complying equipment into compliance. (42 

U.S.C. 6316(f)(4)(A)) DOE therefore intends to carefully assess whether such 

manipulation occurs as a result of any final rule using distinct break points.

AHRI Standard 810-2007, as referenced by the DOE test procedure, states that the 

energy consumption rate of ice makers should be rounded to the nearest 0.1 kWh. By 

considering the standard levels using this rounding convention, the only existing 

discontinuity in DOE’s standards for batch type ice makers occurs at the breakpoint of 

500 lb/24 hr between the IMH-W-Small-B and IMH-W-Medium-B equipment classes. In 

its analysis, DOE adjusted the baseline energy level for the IMH-W-Small-B equipment 

class to 7.79 – 0.0055H from 7.80 – 0.0055H. This 0.01 change eliminates the 

discontinuity at this breakpoint, as seen in Table IV.4Table IV.4. In setting up TSLs, 

DOE sought to ensure that no discontinuities existed between equipment classes.

Table IV.4 Current Standard and DOE Engineering Baseline for IMH-W-Small-B 

Equipment Type

Equipment Type Current Baseline

(7.80 –0.0055H)

New Baseline

(7.79 –0.0055H)

IMH-W-Small-B 5.1 

(rounded from 5.050)

5.0 

(rounded from 5.040)

IMH-W-Medium-B 5.0 

(rounded from 5.030)

5.0 

(rounded from 5.030)

69
d. Continuous Ice Maker Equipment Classes

The EPACT 2005 amendments to EPCA did not set standards for continuous type 

ice makers. At the February 2012 preliminary analysis public meeting, DOE presented 

NES results (see section IV.H.3 of this notice) that indicated the continuous equipment 

type accounted for approximately 0.03 quads of savings potential over the 30-year 

analysis period. The savings levels are low primarily because continuous type ice-making 

machines represent only 16 percent of automatic commercial ice maker shipments, of 

which only two equipment classes (IMH air-cooled small and self-contained air-cooled 

small equipment) represent three-quarters of shipments. 

At the February 2012 preliminary analysis public meeting and in written 

comments, AHRI and Scotsman both questioned the need to regulate continuous type ice

makers, noting that the preliminary results of DOE’s national impact analysis show 

negligible NES (rounding to 0.000 quads) for most continuous type equipment classes. 

(AHRI, No. 49 at pp. 1-2; Scotsman, No. 46 at p. 5; Scotsman, Public Meeting 

Transcript, No. 42 at p. 105)

AHRI and Scotsman questioned the need to include continuous remote 

condensing units (RCUs) with remote compressors as equipment classes, noting that 

these are niche products that represent a very small portion of the overall market. AHRI 

added that their minimal projected energy savings and low shipment volume would not 

justify the cost of testing and certifying these products to DOE. (AHRI, No. 49 at p. 3; 

Scotsman, No. 46 at p. 2)

70
Pursuant to EPCA, DOE is required to set new or amended energy conservation 

standards for automatic commercial ice makers to: (1) achieve the maximum 

improvement in energy efficiency that is technologically feasible and economically 

justified; and (2) result in significant conservation of energy. (42 U.S.C. 6295(o)(2)(A) 

and (o)(3)(B); 6313(d)(4)) However, the term “significant conservation of energy” is not 

specifically defined. Additionally, The EPCA language does not require DOE to 

determine the significance of savings at the individual equipment class level in order to 

justify setting standards for all equipment classes of an equipment type, although there is 

precedent in other rulemakings for DOE to elect to not cover some equipment classes due 

to small market share.

Ice maker shipments for 2010 are shown in section . Clearly, based on 2010 data, 

self-contained air-cooled small continuous equipment is an important class of ice makers, 

having the fourth highest shipment levels of the 25 proposed equipment classes. It is also 

clear that continuous RCU classes have a small market share. 

DOE does not have a definition to distinguish market segments that are “too 

small” to be regulated. The smallest continuous equipment classes would be eliminated if 

equipment classes with less than 1 percent of market share were not considered. 

However, three of the batch equipment classes, which also fall below the 1-percent 

market share line, are nonetheless currently regulated. Eliminating the standards for those 

Comment [fp14]: Change requested by OIRA.

71
three equipment classes would violate the anti-backsliding provision of EPCA,

26 while

deciding not to regulate the continuous equipment classes would be inconsistent with 

DOE’s past approach.

DOE has decided to regulate all automatic commercial ice maker equipment 

classes. This will bring two important automatic commercial ice maker classes (selfcontained, air-cooled small continuous and IMH air-cooled small continuous) under 

regulation. Regulating all equipment classes will create a consistent approach for 

regulating continuous type equipment as was done for batch type equipment. 

e. Remote Condensing Unit Classes for Equipment with and without Remote 

Compressors

The current standard levels differentiate between remote condensers with 

compressors in the condenser cabinet and remote condensers without remote 

compressors. DOE requested comment on whether to retain these equipment classes as 

separate groups. (DOE, Public Meeting Presentation, No. 7 at p. 30).

Numerous stakeholders expressed their support for DOE’s differentiation of 

RCUs into two separate classes based on the location of their compressors. Manitowoc 

raised the issue at the public meeting, noting that locating the compressor remotely has a 

measurable impact on the overall efficiency of an ice maker. (Manitowoc, Public Meeting 

26 Under 42 U.S.C. 6295(o)(1), the Secretary may not prescribe any amended standard which increases the 

maximum allowable energy use of a covered product. While 42 U.S.C. 6295(o) applies to consumer 

products, a “crosswalk” provision in 42 U.S.C. 6313(d)(4) makes the above anti-backsliding provision 

applicable to automatic commercial ice maker equipment.

72

 
Transcript, No. 42 at pp. 24-25) Scotsman added that these two classes of RCUs perform 

at different efficiencies in the field and provide different utility to the customer, thus 

justifying their separation into separate equipment classes. (Scotsman, Public Meeting 

Transcript, No. 42 at p. 45 and No. 46 at p. 2) NPCC expressed agreement with 

Scotsman’s comment on the issue. (NPCC, Public Meeting Transcript, No. 42 at p. 45)

Based on DOE’s review of these comments and data arising from the analyses, 

DOE believes the location of the compressor provides different customer utility, and that 

each equipment class experiences different energy usage trends due to suction line losses.

DOE did not receive any information indicating that these equipment classes should not 

be kept separate. Therefore, DOE will continue to categorize RCUs with and without 

remote compressors into separate equipment classes.

f. Remote to Rack Equipment

In the preliminary analysis, DOE found that some high-capacity RCU-RC-LargeC ice makers are solely designed to be used with compressor racks and the racks’ 

associated condensers. A compressor rack is typically used with supermarket 

refrigeration equipment and consists of several compressors joined in a parallel 

arrangement to service several refrigeration products at once. One related issue is that the 

manufacturers of these automatic commercial ice makers do not provide for sale a 

condensing unit that could be paired with them as an alternative option. DOE noted that 

these units do not meet the statutory definition of ice makers, which states that an ice 

maker “consists of a condensing unit and ice-making section operating as an integrated 

73
unit, with means for making and harvesting ice.” (42 U.S.C. 6311(19)(A)) Hence, DOE 

determined during the preliminary analysis that rack-only RCUs are not defined as ice 

makers under the statute and thus should not be included in this rulemaking.

Howe recommended that DOE include remote to rack ice makers in the 

rulemaking because such units already represent a significant fraction of annual ice 

maker shipments and will become even more significant once the covered capacity range 

expands to 4,000 lb ice/24 hours. (Howe, No. 51 at p. 4) Conversely, Scotsman 

commented that continuous RCUs with remote compressors comprise a very tiny piece of 

the overall automatic commercial ice maker market and thus questioned the need to 

establish equipment classes for these products. Scotsman added that these RCUs are 

difficult to test27 because they are designed to be connected to supermarket rack systems. 

(Scotsman, No. 46 at p. 2)

Earthjustice observed that DOE has not explained why it believes that ice makers 

designed for use with remote condenser rack systems do not consist of “a condensing unit 

and ice‐making section operating as an integrated unit, with means for making and 

harvesting ice,” as automatic commercial ice makers are defined. Earthjustice argued that 

such ice makers use the same basic components, including both a condensing unit and an 

ice‐making section. Moreover, Earthjustice continued, the two components are directly 

connected, and their integration is not nullified by the fact that other equipment may also 

be connected to the supermarket rack. Earthjustice added that DOE has long regulated 

27 The current and recently completed DOE test procedures do not provide test procedures for this type of 

equipment.

74

 
split system residential and commercial air conditioners despite the fact that the outdoor 

and indoor components are frequently made by different firms. (Earthjustice, No. 47 at p. 

5)

Given the small market share of large continuous RCU remote compressor 

equipment (0.35 percent), DOE finds that Scotsman’s claim is credible in that 

continuous, rack-only equipment comprises only a fraction of the 0.35 percent, and thus a 

tiny piece of the overall market.

The Earthjustice comment drawing a parallel to split system residential 

equipmentair conditioners overlooks key distinctions. Residential equipment may pair 

components from different manufacturers, but only one manufacturer is responsible for 

the certification.28 Supermarket racks simultaneously serve multiple units of equipment 

(including commercial refrigerators and freezers, walk-in coolers and freezers, ice 

makers, air conditioners, and heat pumps), so there is no way to hold one manufacturer 

responsible for certifying its energy consumption. Drawing a parallel between these two 

circumstances is therefore not reasonable in that respect. 

28 Under DOE regulations, it is possible for more than one central air conditioner manufacturer to submit 

certification reports for a given condensing unit. 10 CFR 429.16 requires manufacturers of central air 

conditioners to certify compliance with the energy conservation standards to DOE. Where a coil 

manufacturer may offer a coil for sale to be matched with a condensing unit made by another manufacturer 

(mix-matched combination), the coil manufacturer can make representations for condensing unit coil 

combination, but, since the condensing unit manufacturer does not offer for sale the mixed-matched 

combination, only the coil manufacturer offering the combination for sale is responsible for certification of 

that combination.

Comment [fp15]: Change requested by OIRA.

75

 
Therefore, DOE decided to maintain its position not to cover rack-only RCU units 

in this standards rulemaking. DOE does request comment and supporting data on the 

overall market share of these units and any expected market trends.

g. Ice Makers Covered by the Energy Policy Act of 2005

Of the 25 equipment classes that DOE is considering in this rulemaking, 13 are 

already covered under energy conservation standards that were set for cube type ice 

makers as part of EPACT 2005. Current automatic commercial ice maker standards 

covering cube type ice makers took effect on January 1, 2010. Under the requirements of 

EPCA, DOE must review and make a determination as to whether amendments to the 

standards are technologically and economically justified by January 1, 2015. (42 U.S.C. 

6313(d)(3)(A)) 

In written comments, AHRI opined that, because the full effects of the EPACT 

2005 ruling will not be known until at least 2013, DOE should only consider the 

previously uncovered continuous and high-capacity batch type ice makers in this 

rulemaking. (AHRI, No. 49 at p. 3) Similarly, Hoshizaki asked DOE not to adjust the 

energy standards for automatic commercial ice makers that are currently covered, arguing 

that tightening the regulations that were just released two years ago would negatively 

impact both manufacturers and end users. (Hoshizaki, No. 53 at p. 3)

Comment [fp16]: Change requested by OIRA.

76
DOE is required by statute to review the standards and, if amended standards are 

technologically feasible and economically justified, to issue a rule to amend the 

standards. (42 U.S.C. 6313(d)(3)(A)) 

Manufacturers have asserted that the automatic commercial ice maker industry is 

a small component of the commercial refrigeration industry, and that given their size they 

have little or no influence with the manufacturers of major components such as 

compressors. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 14-15) To aid 

manufacturers in obtaining more efficient components from suppliers to meet proposed 

revisions to the standards, DOE could consider alternative dates for standards to take 

effect.14-15) Manufacturers noted that they are generally restricted to design options 

available to larger customers. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 15)

Consistent with the comments from manufacturers, DOE’s engineering analysis 

included design options that are viable for automatic commercial ice makers. Most of the 

design options are extensively used in existing products, and a few design options 

(brushless DC motors) are available but rarely implemented in this equipment. Chapter 5 

of the NOPR TSD contains further details of the analysis for each design option used.

DOE has alternatives with respect to the date that new standards would take 

effect. EPCA requires that the amended standards established in this rulemaking must

apply to equipment that is manufactured on or after 3 years after the final rule is 

published in the Federal Register unless DOE determines, by rule, that a 3-year period is 

Comment [fp17]: OIRA requested change.

77
inadequate, in which case DOE may extend the compliance date for that standard by an 

additional 2 years. (42 U.S.C. 6313(d)(3)(C)) 

For the NOPR analyses, DOE assumed a 3-year period to prepare for compliance. 

DOE requests comments on whether a January 1, 2018 effective date provides an 

inadequate period for compliance and what economic impacts would be mitigated by a 

later effective date. 

DOE also requests comment on whether the 3-year period is adequate for 

manufacturers to obtain more efficient components from suppliers to meet proposed 

revisions of standards.

h. Regulation of Potable Water Use

Under EPACT 2005, water used for ice—referred to as potable water—was not 

regulated for automatic commercial ice makers.

The amount of potable water used varies significantly among batch type 

automatic commercial ice makers (i.e., cube, tube, or cracked ice machines). Continuous

type ice makers (i.e., flake and nugget machines) convert essentially all of the potable 

water to ice, using roughly 12 gallons of water to make 100 lb of ice. Batch type ice 

makers use an additional 3 to 38 gallons of water in the process of making 100 lb of ice. 

This additional water is referred to as “dump or purge water” and is used to cleanse the 

evaporator of impurities that could interfere with the ice-making process.

Comment [fp18]: Change requested by OIRA.

78
The Alliance for Water Efficiency (Alliance), the Natural Resources Defense 

Council (NRDC), and CA IOUs proposed that DOE regulate the water use of automatic 

commercial ice makers. (Alliance, No. 45 at pp. 3-4; NRDC, No. 48 at p. 2; CA IOUs, 

No. 56 at p. 6) The Alliance noted that the potable water lost from purging represents a 

waste of the energy required to pump, treat, deliver, and dispose of this water on a 

national scale. This embedded energy use, the Alliance argued, gives DOE justification to 

include water efficiency standards along with its energy efficiency standards for 

automatic commercial ice makers. The Alliance recommended that DOE analyze 

technical data from real ice makers in order to accurately determine the minimum potable 

purge water rate required to prevent scaling. The Alliance also observed that the huge 

variation in potable water use among ice makers of similar capacities suggests that some 

ice makers may be purging water at excessive rates in order to overcome poor 

maintenance practices and schedules, which is not a justifiable excuse in the opinion of 

the Alliance. (Alliance, No. 45 at pp. 3-4) CA IOUs also recommended that DOE 

consider establishing potable water use limits, especially because the ENERGY STAR 

program already includes such limits. (CA IOUs, No. 56 at p. 6)

In response to comments from the Alliance, NRDC, and CA IOUs, DOE was not 

given a clearspecific mandate by Congress to regulate potable water. EPCA, as amended, 

explicitly gives DOE the authority to regulate water use in showerheads, faucets, water 

closets, and urinals (42 U.S.C. 6291(6), 6295(j) and (k)), clothes washers (42 U.S.C. 

6295(g)(9)(B)), dishwashers (42 U.S.C. 6295(g)(10)(B)), commercial clothes washers 

Comment [fp19]: OIRA requested change.

79
(42 U.S.C. 6313(e)), and batch (cube) commercial ice makers. (42 U.S.C. 6313(d)) In 

setting standards forWith respect to batch commercial ice makers (cube type machines), 

however, Congress explicitly set standards in EPACT 2005 only for condenser water use, 

which appear at 42 U.S.C. 6313(d)(1), and noted in a footnote to the table that potable 

water use was not included.29 Congress thereby recognized both types of water, opening 

the subject for discussion without granting a clear mandateand did not provide direction 

to DOE with respect to potable water standards. This ambiguity gives the DOE 

considerable discretion to regulate or not regulate potable water. The U.S. Supreme Court 

has determined that, when legislative intent is ambiguous, a government agency may use 

its discretion in interpreting the meaning of a statute, so long as the interpretation is 

reasonable.30 In the case of ice makers, EPACT 2005 is ambiguous on the subject of 

whether DOE must regulate water usage for purposes other than condenser water usage 

in cube-making machines, so DOE therefore has chosen to use its discretion not to 

mandate a standard in this case. DOE instead considered potable water use reduction in 

batch-type ice makers as a design option for reducing energy use. DOE notes that the 

ENERGY STAR program has implemented potable water consumption requirements.

Hoshizaki commented that potable water use varies from place to place, 

depending on water quality, and added that the market is already dictated to use less 

water. (Hoshizaki, Public Meeting Transcript, No. 42 at p. 73) AHRI added that limiting 

potable water use would decrease ice clarity and increase scaling, which would 

29 Footnote to table at 42 U.S.C. 6313(d)(1). 30 Nat’l Cable & Telecomms. Ass’n v. Brand X Internet Servs., 545 U.S. 967, 986 (2005) (quoting Chevron 

U.S.A. Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 845 (1984)).

Comment [fp20]: OIRA requested change.

Comment [fp21]: OIRA requested change.

80

 
subsequently increase the overall energy use of the ice maker. Therefore, AHRI and 

Hoshizaki both recommended against establishing maximum potable water use standards 

in this rulemaking because of the reduced utility and efficiency that it would cause. 

(AHRI, No. 49 at pp. 2-3; Hoshizaki, No. 53 at p. 1)

The Hoshizaki and AHRI comments suggest that DOE intends to implement 

potable water use standards, but this is not the case. Rather, DOE is simply suggesting 

that reduction of potable water use is a viable technology option that satisfies the 

screening analysis criteria, as long as reductions are not excessive. This approach does 

not establish potable water use maximums since manufacturers are not required to use 

this design option in order to meet efficiency standards. Scotsman noted that the 

ENERGY STAR program has limited potable water use in ice makers to 25 gallons per 

100 lb of ice and that the program is moving toward a new standard of 20 gallons per 100 

lb of ice, which it believes to be the minimum levels for avoiding machine performance 

issues. Scotsman recommended that DOE refer to these ENERGY STAR standards in 

determining new potable water use limits. (Scotsman, Public Meeting Transcript, No. 42 

at pp. 64-65 and No. 46 at p. 5) Manitowoc agreed with Scotsman and added that the 

new 20 gallons per 100 lb metric was developed with the aid of manufacturers and that 

further reducing potable water use could impact the long-term reliability of its machines. 

Therefore, Manitowoc stated that 20 gallons per 100 lb is the lowest water use limit with 

which it would be comfortable. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 

65-66)

81
However, Manitowoc also commented that potable water use is a variable in the 

design process that manufacturers have already optimized to satisfy a number of 

competing factors. Manitowoc argued that, although reducing potable water use would 

improve machine efficiency up to a point, it would also decrease reliability and increase 

the required frequency for cleaning due to scaling. Manitowoc stated that the design 

limits for potable water use often depend on proprietary design elements; therefore, it 

would be difficult to set reasonable potable water use standards that were fair to all 

companies, in Manitowoc’s opinion. (Manitowoc, No. 54 at p. 3)

Howe noted that measuring potable water use is important because de-scaling is 

crucial for maintaining the efficiency and utility of automatic commercial ice makers. 

Howe also recommended that DOE obtain information from additional manufacturers on 

the relationship between potable water use and ice maker performance. (Howe, No. 51 at 

p. 2)

DOE has implemented in the analysis the recommendations of several 

stakeholders that 20 gallons per 100 lb of ice is a reasonable lower limit on potable water 

use for batch type ice makers, especially considering that there are numerous batch type 

ice machines that have potable water use at this level or lower. For example, in 

implementing batch water control as a design option, DOE is limiting the reduction in 

potable water use to 20 gallons per 100 lb. This should not be confused with the 

establishment of a standard – this limit affects the extent to which a specific design 

option saves energy by placing a floor under the potable water usage. Though NRDC 

82
claims that reducing potable water use beyond this level would be feasible and beneficial, 

it has not identified specific designs with significantly less potable water use, nor has it 

provided data to show that long-term field use of such equipment is viable. Chapter 5 of 

the NOPR TSD contains more information about this analysis.

2. Technology Assessment

As part of the market and technology assessment, DOE developed a 

comprehensive list of technologies to improve the energy efficiency of automatic 

commercial ice makers, shown in Table IV.5Table IV.5. Chapter 3 of the NOPR TSD 

contains a detailed description of each technology that DOE identified. DOE only 

considered in its analysis technologies that would impact the efficiency rating of 

equipment as tested under the DOE test procedure. The technologies identified by DOE 

were carried through to the screening analysis and are discussed in section IV.C.

Table IV.5 Technology Options for Automatic Commercial Ice Makers

Technology Options Batch Ice 

Makers

Continuous 

Ice Makers Notes

Compressor Improved compressor efficiency √ √

Part load operation √ √

Condenser

Increased surface area √ √

Enhanced fin surfaces √ √ Air-cooled 

only

Increased air flow √ √ Air-cooled 

only

Increased water flow √ √ Water-cooled 

only

Brazed plate condenser √ √ Water-cooled 

only

Microchannel condenser √ √

Fans and Fan 

Motors

Higher efficiency condenser fans and 

fan motors √ √ Air-cooled only

Other Motors Improved auger motor efficiency √

Improved pump motor efficiency √

Controls Smart Technologies √ √

Evaporator

Design options which reduce energy 

loss due to evaporator thermal cycling √

Design options which reduce harvest √

83
meltage or reduce harvest time

Larger evaporator surface area √ √

Tube evaporator configuration √

Insulation

Improved insulating material and/or 

thicker insulation around the 

evaporator compartment

√ √

Refrigeration Line Larger diameter suction line √ √

RCUs with 

remote 

compressor

Potable Water Reduced potable water flow √

Drain water thermal exchange √

a. Reduced Potable Water Flow for Continuous Type Ice Makers

Howe questioned why the list of design options for continuous type ice makers 

did not include reduced potable water flow, considering that such machines can have 

clean or flush cycles. (Howe, Public Meeting Transcript, No. 42 at pp. 30-31)

DOE notes that some continuous machines may include controls or design options 

that may reduce potable water flow. Therefore, DOE has included reduced potable water 

flow for continuous machines as one of its design options.

DOE also notes that the test procedure for continuous type ice makers calls for 

three 14.4-minute long measurements of ice-making production and energy use. The 

flushing cycles in continuous type ice makers typically do not occur within these 

measurement periods and the water used for flushing is not captured in the energy use 

metric; hence, because the engineering analysis cannot evaluate an improvement that

occurs outside of the test procedure, this aspect of equipment operation was screened out 

in the screening analysis.

84
b. Alternative Refrigerants

Scotsman asked whether hydrocarbon refrigerants were considered as a design 

option. (Scotsman, Public Meeting Transcript, No. 42 at p. 32) Manitowoc responded that 

hydrocarbon refrigerants should not be considered in the analysis because they have not 

been approved for use by the U.S. Environmental Protection Agency’s (EPA’s) 

Significant New Alternatives Policy (SNAP). (Manitowoc, Public Meeting Transcript, 

No. 42 at p. 32) AHRI added that refrigerants that are used as alternatives to 

chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) must be approved 

by both the EPA and the SNAP program. AHRI noted that, although some hydrocarbon 

refrigerants were approved for use in residential refrigerators and some commercial 

refrigerated display cases, they have not been approved for ice makers. (AHRI, Public 

Meeting Transcript, No. 42 at pp. 32-33)

Manitowoc observed that future legislation may require the use of refrigerants 

that, based on their current status, have the potential to decrease the energy efficiency of 

ice makers. (Manitowoc, Public Meeting Transcript, No. 42 at p. 33) 

As indicated by AHRI, hydrocarbon refrigerants have not yet been approved by 

the EPA SNAP program and hence cannot be considered as a technology option in 

DOE’s analysis. DOE also notes that, while it is possible that hydrofluorocarbon (HFC)

refrigerants currently used in automatic commercial ice makers may be restricted by 

future legislation, DOE cannot speculate on such future laws and can only consider in its 

rulemakings laws that have been enacted. This is consistent with past DOE rulings, such 

85
as in the 2011 direct final rule for room air conditioners. 76 FR 22454 (April 21, 2011). 

To the extent that there has been experience within the industry, domestically or 

internationally, with the use of alternative low-GWP refrigerants, DOE requests any 

available information, specifically cost and efficiency information relating to use of 

alternative refrigerants. DOE acknowledges that there are government-wide efforts to 

reduce emissions of HFCs, and such actions are being pursued both through international 

diplomacy as well as domestic actions. DOE, in concert with other relevant agencies, 

will continue to work with industry and other stakeholders to identify safer and more 

sustainable alternatives to HFCs while evaluating energy efficiency standards for this 

equipment.

C. Screening Analysis

In the technology assessment section of this NOPR, DOE presents an initial list of 

technologies that can improve the energy efficiency of automatic commercial ice makers. 

The purpose of the screening analysis is to evaluate the technologies that improve 

equipment efficiency to determine which of these technologies is suitable for further 

consideration in its analyses. To do this, DOE uses four screening criteria—design 

options will be removed from consideration if they are not technologically feasible; are 

not practicable to manufacture, install, or service; have adverse impacts on product utility 

or product availability; or have adverse impacts on health or safety. 10 CFR part 430,

subpart C, appendix A, sections (4)(a)(4) and (5)(b) See chapter 4 of the NOPR TSD for 

further discussion of the screening analysis. Additional screening criteria include whether 

a design option is expected to save energy or whether savings can be measured (using the 

Comment [fp22]: OIRA requested change.

86
prescribed test procedure), and whether an option is a proprietary technology or whether 

it is widely available to all manufacturers. Table IV.6Table IV.6 shows the EPCA criteria 

and additional criteria used in this screening analysis, and the design options evaluated 

using the screening criteria.

In the NOPR phase, DOE made several changes to the treatment of design options 

from the preliminary analysis approach. These changes included:

• adding a design option to allow for growth of the unit to increase the size of 

the condenser and/or evaporator;

• adjusting assumptions regarding maximum compressor EER levels based on 

additional research and confidential input from manufacturers;

• adjusting potable water consumption rates for batch type ice makers subject to 

a floor that represents the lowest potable water consumption rate that would 

be expected to flush out dissolved solid reliably;

• adding a design option to allow condenser growth in water-cooled condensers; 

and

• adding a drain water heat exchanger design option.

87
Table IV.6 Screening Justification

Design Option

EPCA Criteria for 

Screening

Not Considered in the 

Analysis for Other 

Reasons

Technological FeasibilityPracticability to Manufacture, Install, and ServiceAdverse Impacts on Product UtilityAdverse Impacts on Health and SafetyNo Energy Savings or Savings not MeasurableTest Procedure Efficiency Metric Does Not Capture SavingsProprietary Technology

Compressor Part Load 

Operation √ √

Enhanced Fin Surfaces √

Brazed Plate Condenser √

Microchannel Condenser √

Technology Options to Reduce 

Evaporator Thermal Cycling √ √

Technology Options Which 

Reduce Harvest Meltage or 

Reduce Harvest Time

√

Tube Evaporator 

Configuration √

Improved or Thicker 

Insulation √

Larger Diameter Suction Line √

Smart Technologies √

Table IV.7Table IV.7 contains the list of technologies that remained after the 

screening analysis.

Table IV.7 Technology Options for Automatic Commercial Ice Makers that were 

Screened In

Technology Options Batch Ice 

Makers

Continuous 

Ice Makers Notes

Compressor Improved compressor efficiency √ √

Condenser

Increased surface area √ √

Increased air flow √ √ Air-cooled 

only

Increased water flow √ √ Water-cooled 

only

88
Fans and Fan 

Motors

Higher efficiency condenser fans and 

fan motors √ √ Air-cooled only

Other Motors Improved auger motor efficiency √

Improved pump motor efficiency √

Evaporator Larger evaporator surface area √ √

Potable Water Reduced potable water flow √

Drain water thermal exchange √

a. Tube Evaporator Design

Among the technologies that DOE considered were tube evaporators that use a 

vertical shell and tube configuration in which refrigerant evaporates on the outer surfaces 

of the tubes inside the shell, and the freezing water flows vertically inside the tubes to 

create long ice tubes that are cut into smaller pieces during the harvest process. Some of 

the largest automatic commercial ice makers in the RCU-NRC-Large-B and the IMH-WLarge-B equipment classes use this technology. However, DOE concluded that 

implementation of this technology for smaller capacity ice makers would significantly

impact equipment utility, due to the greater weight and size of these designs, and to the 

altered ice shape. DOE noted that available tube icemakers (for capacities around 1,500 

lb ice/24 hours and 2,200 lb ice/24 hours) were 150 to 200 percent heavier than 

comparable cube ice makers. Based on the impacts to utility of this technology, DOE 

screened out tube evaporators from consideration in this analysis.

b. Low Thermal Mass Evaporator Design

DOE’s preliminary analysis did not consider low thermal mass evaporator 

designs. Reducing evaporator thermal mass of batch type ice makers reduces the heat that 

must be removed from the evaporator after the harvest cycle, and thus decreases 

refrigeration system energy use. DOE indicated during the preliminary analysis that it 

89
was concerned about the potential proprietary status of such evaporator designs, since 

DOE is aware of only one manufacturer that produces equipment with such evaporators. 

DOE requested comment on the proprietary status of low-thermal-mass evaporator 

designs in general, and the design used by the cited manufacturer (Hoshizaki) in 

particular.

Scotsman commented that Hoshizaki has recently patented or attempted to patent 

modifications to improve evaporator efficiency and noted that using such evaporator 

designs would be difficult for other manufacturers because it would require an expensive 

and risky redesign of entire product lines. (Scotsman, Public Meeting Transcript, No. 42 

at pp. 35-36; Scotsman, No. 46 at pp. 2-3) However, Manitowoc observed that, although 

intellectual property is certainly a concern, there may be ways to implement this low 

thermal mass evaporator technology without exactly duplicating Hoshizaki’s designs. 

(Manitowoc, Public Meeting Transcript, No. 42 at p. 36)

Hoshizaki commented that its batch type evaporators do indeed contain 

intellectual property in past and future designs, adding that the tooling costs for 

manufacturing these evaporators would be too expensive for competing manufacturers to 

replicate. (Hoshizaki, No. 53 at p. 2)

AHRI recommended that DOE eliminate proprietary designs from consideration 

and limit its analysis to technologies that are available to all manufacturers in the ice 

maker industry. (AHRI, No. 49 at p. 4)

90
Manitowoc commented that, in addition to the obvious legal issues associated 

with favoring a proprietary design held by a single manufacturer, DOE’s analysis tools 

are also incapable of predicting the potential benefit of low thermal mass evaporators, 

which are difficult to model accurately. (Manitowoc, Public Meeting Transcript, No 42 at 

pp. 36-37 and No. 54 at p. 3) Manitowoc also warned that the impact of this technology 

on one ice maker should not simply be extrapolated to other machines and that 

oversimplification of this analysis would affect the predicted efficiency benefits of each 

technology level. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 36-37)

Manitowoc added that customers are very loyal to the style of ice that they get from its 

machines and that all manufacturers keep customer loyalty in mind when designing their 

evaporators. Consequently, Manitowoc expressed concern that a new evaporator design 

could force manufacturers to change the style of their ice, which could drive down sales 

and result in a low overall payback despite the improved energy performance, and 

therefore Manitowoc concluded that DOE should not establish higher efficiency levels 

based on this design option. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 36-37 

and No. 54 at p. 3)

On the basis of its proprietary status, DOE concludes that its initial decision to 

screen out low-thermal-mass evaporator technology was appropriate. Thus, DOE has 

screened out this technology in its NOPR analysis.

91
c. Drain Water Heat Exchanger

Batch ice makers can benefit from drain water thermal exchange that cools the 

potable water supply entering the sump, thereby reducing the energy required to cool 

down and freeze the water. Technological feasibility is demonstrated by one 

commercially available drain water thermal heat exchanger that is currently sold only for 

aftermarket installation. This product is designed to be installed externally to the ice 

maker, and both drain water and supply water are piped through the device.

31

In the preliminary analysis, DOE considered whether such a component could be 

considered to be part of an ice maker as defined in EPCA. The EPCA definition for 

automatic commercial ice makers states that the ice maker consists of a condensing unit 

and ice-making section operating as an integral unit, with means for making and 

harvesting ice. (42 U.S.C. 6311(19)) The definition allows that the ice maker may include 

means forstoring ice, dispensing ice, or storing and dispensing ice. None of the 

subcomponents of the ice maker listed in the definition could be interpreted as referring 

to heat exchangers for drain water thermal exchange. DOE notes that an ice maker can 

still make ice without a drain water heat exchanger; hence, the drain water heat 

exchanger cannot be considered an integral part of the equipment. For these reasons, 

DOE concluded during the preliminary analysis that external drain water heat 

exchangers, the only configuration of this technology for which technological feasibility 

is demonstrated, should be screened out, and requested comments on this approach.

31 A.J. Antunes and Co. Vizion Product Catalog. (Last accessed May 18, 2013.) 

<www.ajantunes.com/VIZION/VIZIONProductCatalog/tabid/229/ProdID/481/CatID/280/language/enUS/Default.aspx>

92

 
NPCC asserted that DOE should consider drain water thermal exchange as a 

technology option. NPCC proposed that reducing the inlet water temperature could 

enable an ice maker to maintain the same capacity without increasing the overall size of 

the unit. Although NPCC does not manufacture ice makers, it acknowledged having seen 

this technology implemented in other applications, such as water heating, without 

reducing capacity or increasing overall size. (NPCC, Public Meeting Transcript, No. 42 at 

pp. 37-38)

Earthjustice commented that DOE’s rationale for screening out drain water 

thermal heat exchangers was defective on both legal and factual grounds. In the 

preliminary analysis TSD, DOE suggested that externally mounted drain water heat 

exchangers would fall outside EPCA’s definition of automatic commercial ice makers, 

and that DOE therefore had no authority to consider them in this rulemaking. Earthjustice 

argued that this reading twists the statutory definition’s role in identifying which products 

constitute the “automatic commercial ice makers” subject to efficiency standards into a 

“Dos and Don’ts” list from Congress as to which elements of ice makers DOE may 

examine when amending the standards that Congress enacted. Congress adopted 

standards that apply to the ice maker as a whole, and Earthjustice asserted that there is 

therefore no basis to conclude that EPCA intended to prohibit DOE from looking 

holistically at this equipment when amending the statutory standards. Earthjustice added 

that, if every technological innovation that improved the efficiency of a covered product 

needed to be specifically mentioned in the statute’s definition of the product, there would 

93
be no need for a screening analysis. Earthjustice also noted that, in previous rulemakings, 

DOE consistently recognized that components that improve the efficiency of covered 

products merit consideration in the DOE’s analyses, notwithstanding that they may be 

unnecessary to the basic function performed by the product, not referred to in the 

statutory definition applicable to the product, or external to the case or envelope of the 

device. Finally, Earthjustice commented that DOE’s assertion that internally mounted 

drain heat exchangers would necessarily increase cabinet size is not true for all ice maker 

models. Moreover, Earthjustice stated, DOE has not considered options such as 

microchannel heat exchangers, which would increase both machine efficiency as well as 

available cabinet space within the ice maker. (Earthjustice, No. 47 at pp. 1–4)

DOE has reconsidered its preliminary suggestion that external drain water heat 

exchangers cannot be considered part of an ice maker simply because they are not 

specifically mentioned in the EPCA definition, now concluding that they can be 

considered as a design option and to be part of a basic model ice maker, assuming that the 

drain water heat exchanger is sold and shipped with the unit and that the installation and 

operating instructions clearly reinforce this inclusion by detailing the installation 

requirements for the heat exchanger.

Thus, DOE is including this technology as a design option. As NPCC noted, 

externally mounted drain water heat exchangers would provide energy savings by using 

“waste” water to cool the incoming potable water supply, thus reducing the amount of 

energy necessary to freeze the water into ice. Whereas internal heat exchangers may 

94
require increased cabinet size to fit within the ice maker, allowing external heat 

exchangers as a design option would prevent size increase.

DOE has concluded that drain water heat exchangers, both internally mounted and 

externally mounted, are design options that can increase the energy efficiency of 

automatic commercial ice makers. The current test procedures would give manufacturers 

credit for efficiency improvement of drain water heat exchangers, including externally 

mounted drain water heat exchangers as long as they are provided with the machine and 

the installation instructions for the machine indicate that the heat exchangers are part of 

the machine and must be installed as part of the overall installation. 

d. Design Options that Necessitate Increased Cabinet Size

Some of the design options considered by DOE in its technology assessment 

could require an increased cabinet size. Examples of such design options include 

increasing the surface area of the evaporator or condenser, or both. Larger heat 

exchangers would enable the refrigerant circuit to operate with an increased evaporating 

temperature and a decreased condensing temperature, thus reducing the temperature lift 

imposed on the refrigeration system and hence the compressor power input. In some 

cases the added refrigerant charge associated with increasing heat exchanger size could 

also necessitate the installation of a refrigerant receiver to ensure proper refrigerant 

charge management in all operating conditions for which the unit is designed, thus 

increasing the need for larger cabinet size. 

95
In the preliminary analysis, DOE did not consider design options that increase 

cabinet size, and it requested comment on this approach. (DOE, Public Meeting 

Presentation, No. 29 at p. 35)

Earthjustice observed that this issue, in which certain design options necessitate 

larger products and therefore larger installation costs, is common in rulemakings. Despite 

the potential difficulties that increased size could pose for ice maker manufacturers and 

customers, Earthjustice commented that the preliminary analysis is not necessarily the 

stage of the rulemaking in which such design options should be ruled out. (Earthjustice, 

Public Meeting Transcript, No. 42 at pp. 46-47) 

At the February 2012 preliminary analysis public meeting, Manitowoc pointed 

out that the size of ice makers is severely limited in certain applications, which would 

make it difficult for manufacturers to implement design changes that reduce energy but 

require an increase in size. Manitowoc warned that DOE should not assume that all ice

maker manufacturers can increase the sizes of their ice machines to meet standards. In 

many cases, according to Manitowoc, increasing the size may result in higher installation 

costs, which are not considered in DOE’s analysis. Manitowoc and AHRI both noted that 

a high percentage of the ice machine business involves replacing old units and that the 

size of new ice makers is therefore dictated by the size of the products being replaced. 

(Manitowoc, Public Meeting Transcript, No. 42 at pp. 57-59 and No. 54 at p. 2; AHRI, 

No. 49 at p. 2) AHRI also commented that customers continue to demand smaller ice 

machines as the space used to house them competes against more “usable” spaces, such 

96
as hotel rooms. Hoshizaki agreed that the industry was moving toward smaller ice makers 

and also recommended that DOE limit cabinet size. Consequently, Manitowoc, AHRI, 

and Hoshizaki all commented that DOE should not consider design options that increase 

cabinet size in its analysis. (Manitowoc, No. 54 at p. 2; AHRI, No. 49 at p. 2; Hoshizaki, 

No. 53 at p. 1) 

Scotsman commented that, for products at the top of the capacity range within a 

given standard cabinet size, manufacturers cannot increase the size of internal 

components such as air-cooled condensers without increasing the machines’ cabinet size. 

This would make the machines less competitive because they would no longer physically 

fit in certain applications, according to Scotsman. (Scotsman, Public Meeting Transcript, 

No. 42 at pp. 87-88) Moreover, Scotsman noted that assessing the impact of a 

technology on one type of machine and applying it to other types can be difficult and 

inaccurate. For example, while increasing condenser area could be simple for a 300-lb 

machine, it may require retooling several parts, in addition to increasing cabinet size and 

thus also increasing overall costs, to make the same condenser growth fit in a 600-lb 

machine. (Scotsman, No. 46 at p. 2) Finally, Scotsman stated that increasing the size of 

ice makers will cause cabinet costs to increase. (Scotsman, Public Meeting Transcript, 

No. 42 at p. 64) Therefore, Scotsman agreed with its fellow manufacturers that DOE 

should avoid design options requiring cabinet size increases. (Scotsman, No. 46 at p. 4)

Manitowoc commented that it is rare for manufacturers to have data regarding 

available space, ventilation, or other variables regarding the final installation of their 

97
products. Moreover, Manitowoc added that forcing an ice maker with larger cabinet size 

into an existing space that is too small for it would exacerbate condenser air recirculation, 

which decreases its efficiency and reliability. (Manitowoc, Public Meeting Transcript, 

No. 42 at pp. 62-63)

However, Scotsman also commented that an ice maker’s energy use typically 

decreases as its size increases, meaning that it may be more efficient to use an oversized 

machine than one that has been downsized. (Scotsman, Public Meeting Transcript, No. 42 

at pp. 61-62)

Howe commented that the physical size of an automatic commercial ice maker 

has no effect on its efficiency or its run time. According to Howe, the run time of ice 

makers is a function of their productive capacity as well as the size of their ice storage 

bins, because ice production automatically ceases when the bin is full. Howe added that 

regulating the physical size of ice makers may limit the use of new, more efficient 

technologies in the future. Therefore, Howe urged DOE not to consider limiting the 

physical size of ice makers. (Howe, No. 51 at pp. 1-2)

NEEA/NPCC also urged DOE not to consider limiting ice maker cabinet size in 

the rulemaking. NEEA/NPCC pointed out that, although improving the efficiency of an 

ice maker may require increasing the size of its components, many ice makers have 

sufficient room in their cabinets to accommodate such size increases. According to 

NEEA/NPCC, advanced evaporator designs could be used to meet efficiency and 

98
capacity requirements for ice makers whose evaporators already require the full cabinet 

size. (NEEA/NPCC, No. 50 at p. 2)

CA IOUs agreed that DOE should not screen out design options that would 

require an increase in cabinet size. CA IOUs referred to a limited field study whose 

results indicated to CA IOUs that larger ice-making equipment may be accommodated in 

most situations. CA IOUs added that there is no evidence as to whether there may be 

another space in installation locations that could accommodate a larger ice maker. 

Therefore, CA IOUs asserted that, in the absence of a survey or field study that shows 

size constraints to be an issue, DOE should not use size to screen out design options. (CA 

IOUs, No. 56 at p. 3)

Based on these comments from stakeholders, DOE understands that automatic 

commercial ice makers are often used in applications where space is very limited. DOE 

has not received any data supporting or refuting the characterization that installation 

locations may be able to accommodate larger icemakers.

Although CA IOUs cited a study indicating that installation locations may be able 

to accommodate larger ice makers,

32 the sample size of this study is extremely small and 

is not necessarily representative of the entire automatic commercial ice maker market.

The study does not present any findings on the size constraints and allowances seen in the

32 Karas, A. A Field Study to Characterize Water And Energy Use of Commercial Ice-Cube Machines and 

Quantify Savings Potential. December 2007. Fisher-Nickel, Inc., San Ramon, CA. 

<www.fishnick.com/publications/fieldstudies/Ice_Machine_Field_Study.pdf>

99

 
inspected products, and the pictures themselves are inconclusive. DOE believes it would 

be difficult to support any size-based conclusions using this study.

Particularly because replacements comprise such a large portion of the ice maker 

industry, ice makers affected by the proposed standard must maintain traditional standard 

widths and depths. Allowing design options that necessitate physical size increases may 

push certain capacity units beyond their current standard dimensions and would thus 

force the use of lower-capacity machines in replacement applications, which would 

significantly reduce equipment utility.

On the other hand, screening out size-increasing design options would eliminate 

from consideration technologies that could significantly reduce the energy consumption 

of automatic commercial ice makers.

Consideration of design options that increase the size of ice makers is strongly 

related to consideration of size-constrained design options. DOE notes that, while 

stakeholders have pointed out that many automatic ice maker applications are spaceconstrained, as described in section IV.B.1.a, DOE does not have access to sufficientlydetailed data that would either indicate what percentage of applications could not allow 

size increase, or be the basis to set size limits for space-constrained classes. Thus, DOE 

has also decided not to create size-constrained equipment classes.

100
DOE also notes that there are a wide range of product sizes within most 

equipment classes, and that DOE must seek out the most-efficient configurations. DOE 

noted that the equipment it purchased for reverse engineering inspections reflected a 

general trend that more-efficient units were often larger, had larger condensers, and in 

some cases had larger evaporators. Based on DOE’s market study and equipment 

inspections, larger chassis sizes appeared often to be a means of achieving higher 

efficiencies.

Thus, DOE is including this package-size-increasing technologies as design 

options in the NOPR analysis. DOE only applied these design options for those 

equipment classes where the representative baseline unit had space to grow relative to the 

largest units on the market. The equipment growth allowed for larger heat exchangers to 

increase equipment efficiency.

For equipment classes with remote condensers, DOE only applied this design 

option to the condenser package, and not to the ice-making head that is placed indoors. In 

general, DOE only considered increasing the size of the evaporator whenever the product 

inspections (see section IV.D.4.e) indicated that it was needed to increase efficiency.

In addition, DOE recognizes that space constraints are more critical for SCU 

units; hence, DOE did not consider package size growth for SCU equipment classes.

101
Table IV.8Table IV.8 indicates for which analyzed equipment classes DOE 

considered chassis growing design options.

Table IV.8 Analyzed Equipment Classes Where DOE Analyzed Size-Increasing

Design Options

Unit

Rated Harvest 

CapacityRate

lb ice/24 hours

Used Design Options that 

Increased Size?

IMH-A-Small-B 300 Yes

IMH-A-Large-B (med) 800 Yes

IMH-A-Large-B (large) 1,500 No

IMH-W-Small-B 300 Yes

IMH-W-Med-B 850 No

IMH-W-Large-B 2,600 No

RCU-XXX-Large-B (med) 1,500 For the remote condenser, but 

not for the ice-making head

RCU-XXX-Large-B (large) 2,400 For the remote condenser, but 

not for the ice-making head

SCU-A-Small-B 110 No

SCU-A-Large-B 200 No

SCU-W-Large-B 300 No

IMH-A-Small-C 310 No

IMH-A-Large-C (med) 820 No

SCU-A-Small-C 110 No

Table IV.9Table IV.9 shows the size increases that DOE considered in the 

analysis. DOE only considered these size increases when a unit existed on the market that 

was larger than the baseline unit. DOE based the new chassis sizes on the sizes of current 

units on the market.

Table IV.9 Description of Size Increase Design Options in the Engineering Analysis

Equipment 

class

Equipment

Type

Size

Descriptor

Height

inches

Width

inches

Depth

inches

Volume

cubic feet

IMH-A-Small-B IMH Baseline 16.5 30 24.5 7.02

Growth 21.5 30 24.5 9.14

IMH-A-Large-B 

(Med) IMH Baseline 26 30 24 10.83

Growth 29 30 24 12.08

IMH-W-Small-B IMH Baseline 20 30 24 8.33

Growth 23.5 30 23.5 9.59

Further information on this analysis is available in chapter 5 of the NOPR TSD.

102
e. Microchannel Heat Exchangers

NEEA/NPCC, ASAP, and Earthjustice all recommended that DOE include 

microchannel heat exchanger technology in its examination of design options for 

improving condenser and evaporator efficiency. NEEA/NPCC noted that this technology 

has been used in heat exchangers for air handling equipment for years and it would allow 

for increased efficiency or greater ice production capacity. (NEEA/NPCC, No. 50 at p. 2) 

ASAP commented that, although it is not aware of ice makers on the market that 

incorporate microchannel heat exchangers, ice maker manufacturers who have tested 

prototype units that implement this technology have noticed significant efficiency 

improvements. (ASAP, No. 52 at p. 1) Finally, Earthjustice noted that microchannel heat 

exchanger technology would increase both machine efficiency and available cabinet 

space within the ice maker. (Earthjustice, No. 47 at pp. 1-4)

DOE has not found evidence that this technology is cost-effective. Moreover, 

through discussions with manufacturers, DOE has learned of no instances of energy 

savings associated with the use of microchannel heat exchangers in ice makers.

Manufacturers also noted that the reduced refrigerant charge associated with 

microchannel heat exchangers can be detrimental to the harvest performance of batch 

type ice makers, as there is not enough charge to transfer heat to the evaporator from the 

condenser.

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DOE contacted microchannel manufacturers to determine whether there were 

savings associated with use of microchannel heat exchangers in automatic commercial 

ice makers. These microchannel manufacturers noted that investigation of microchannel 

was driven by space constraints rather than efficiency.

Because the potential for energy savings is inconclusive, based on DOE analysis 

as well as feedback from manufacturers and heat exchanger suppliers, and based on the 

potential utility considerations associated with compromised harvest performance in 

batch type ice makers associated with this heat exchanger technology’s reduced 

refrigerant charge, DOE screened out microchannel heat exchangers as a design option in 

this rulemaking.

f. Smart Technologies

CA IOUs recommended that DOE also consider including “smart” technologies 

as design options that will go beyond simple energy savings by capturing demand 

reductions as well. To support this proposition, CA IOUs referenced a study showing

that, for automatic commercial ice-making equipment, there are 450 megawatts of 

demand reduction potential in California alone, indicating a significant nationwide 

possibility for reducing the energy demand associated with ice makers. If DOE does not 

include “smart” technologies as design options, CA IOUs instead asked that DOE 

comment on whether states will be allowed to implement such design option 

requirements for ice-making equipment. (CA IOUs, No. 56 at pp. 5-6)

104
While there may be energy demand benefits associated with use of “smart 

technologies” in ice makers in that they reduce energy demand (e.g., shift the 

refrigeration system operation to a time of utility lower demand), DOE is not aware of 

any commercialized products or prototypes that also demonstrate improved energy 

efficiency in automatic commercial ice makers. Demand savings alone do not impact 

energy efficiency, and DOE cannot consider technologies that do not offer energy

savings as measured by the test procedure. Since the scope of this rulemaking is to 

consider energy conservation standards that increase the energy efficiency of automatic 

commercial ice makers, not how they operate, for example, in relation to utility demand, 

this technology option has been screened out because it does not save energy as measured 

by the test procedure.

g. Screening Analysis: General Comments

Howe suggested that DOE gather information on a wider variety of design types 

of both batch and continuous type ice makers before completing its analyses, noting that 

DOE may have prematurely screened out design options simply because they had adverse 

effects on the ice makers within the small range of design parameters for which DOE 

collected data. (Howe, No. 51 at p. 4)

Howe has not provided specific examples of technologies that it has claimed that 

DOE prematurely screened out, so DOE is not in a position to respond. During the NOPR 

analysis, DOE analyzed additional units and accounted for this additional data in its 

105
engineering analysis. DOE considered a wide range of design types for ice makers, and 

screened out technologies as described in section IV.D.

D. Engineering Analysis

The engineering analysis determines the manufacturing costs of achieving 

increased efficiency or decreased energy consumption. DOE historically has used the 

following three methodologies to generate the manufacturing costs needed for its 

engineering analyses: (1) the design-option approach, which provides the incremental 

costs of adding to a baseline model design options that will improve its efficiency; (2) the 

efficiency level approach, which provides the relative costs of achieving increases in 

energy efficiency levels, without regard to the particular design options used to achieve 

such increases; and (3) the cost-assessment (or reverse engineering) approach, which 

provides “bottom-up” manufacturing cost assessments for achieving various levels of 

increased efficiency, based on detailed data as to costs for parts and material, labor, 

shipping/packaging, and investment for models that operate at particular efficiency 

levels. 

As discussed in the Framework document and preliminary analysis, DOE 

conducted the engineering analyses for this rulemaking using a combined efficiency 

level/design option/reverse engineering approach to developing cost-efficiency curves for 

automatic commercial ice makers. DOE established efficiency levels defined as percent 

energy use lower than that of baseline efficiency products. DOE’s analysis is based on 

the efficiency improvements associated with groups of design options. Also, DOE 

106
developed manufacturing cost models based on reverse engineering of products to 

develop a baseline manufacturer production cost (MPC) and to support calculation of the 

incremental costs associated with improvement of efficiency.

DOE selected a set of 25 equipment classes to analyze directly in the engineering 

analysis. To develop the analytically derived cost-efficiency curves, DOE collected 

information from various sources on the manufacturing cost and energy use reduction 

characteristics of each of the design options. DOE reviewed product literature, tested and 

conducted reverse engineering of 39 ice makers, and interviewed component vendors of 

compressors and fan motors. DOE also conducted interviews with manufacturers during 

the preliminary analysis. Additional details of the engineering analysis are available in 

chapter 5 of the NOPR TSD and a copy of the engineering questionnaire is reproduced in 

appendix 12A of the NOPR TSD.

Cost information from the vendor interviews and discussions with manufacturers 

provided input to the manufacturing cost model. DOE determined incremental costs 

associated with specific design options from both vendor information and the cost model. 

DOE modeled energy use reduction using the FREEZE program, which was developed in 

the 1990s and upgraded as part of the preliminary analysis. The reverse engineering, 

vendor interviews, and manufacturer interviews provided input for the energy analysis. 

The final incremental cost estimates and the energy modeling results together constitute 

the energy efficiency curves presented in the NOPR TSD chapter 5.

107
DOE also considered conducting the engineering analysis using an efficiency 

level approach based on rated and/or measured energy use and manufacturing cost 

estimates based on reverse engineering data. DOE completed efficiency level analyses for 

several equipment classes but concluded that this approach was not viable, because the 

analysis suggested that cost would be reduced for higher efficiency designs for several of 

the equipment classes. This analysis is discussed in section IV.D.4.e and in chapter 5 of 

the NOPR TSD. 

1. Representative Equipment for Analysis

In performing its engineering analysis, DOE selected representative units for 12 

equipment class to serve as analysis points in the development of cost-efficiency curves. 

In selecting these units, DOE selected models that were generally representative of the 

typical offerings produced within the given equipment class. DOE sought to select 

models having features and technologies typically found in the minimum efficiency 

equipment currently available on the market, but selected some models having features 

and technologies typically found in the highest efficiency equipment currently available 

on the market.

2. Efficiency Levels

a. Baseline Efficiency Levels

EPCA, as amended by the EPACT 2005, prescribed the following standards for 

batch type ice makers, shown in Table IV.10Table IV.10, effective January 1, 2010. (42 

U.S.C. 6313(d)(1)) For the engineering analysis, DOE used the existing batch type 

108
equipment standards as the baseline efficiency level for the equipment types under 

consideration in this rulemaking. Also, DOE applied the standards for equipment with 

harvest capacities up to 2,500 lb ice/24 hours as baseline efficiency levels for the larger 

batch type equipment with harvest capacities between 2,500 and 4,000 lb ice/24 hours, 

which are currently not regulated. DOE applied two exceptions to this approach, as 

discussed below.

For the IMH-W-Small-B equipment class, DOE slightly adjusted the baseline 

energy use level to close a gap between the IMH-W-Small-B and the IMH-W-Medium-B 

equipment classes. For equipment in the IMH-A-Large-B equipment class with harvest 

capacity above 2,500 lb ice per 24 hours, DOE chose a baseline efficiency level equal to 

the current standard level at the 2,500 lb ice per 24 hours capacity. In its analysis, DOE is 

treating the constant portion of the IMH-A-Large-B equipment class as a separate 

equipment class, IMH-A-Extended-B. Section IV.C contains more details of these 

adjustments.

DOE is not proposing adjustment of maximum condenser water use standards for 

batch type ice makers. First, DOE’s authority does not extend to regulation of water use, 

except as explicitly provided by EPCA. Second, DOE determined that increasing 

condenser water use standards to allow for more water flow in order to reduce energy use 

is not cost-effective. The details of this analysis are available in chapter 5 of the NOPR 

TSD.

109
For water-cooled batch equipment with harvest capacity less than 2,500 lb ice per 

24 hours, the baseline condenser water use is equal to the current condenser water use 

standards for this equipment.

For water-cooled equipment with harvest capacity greater than 2,500 lb ice per 24 

hours, DOE proposes to set maximum condenser water standards equal to the current 

standard level for the same type of equipment with a harvest capacity of 2,500 lb ice per 

24 hours—the proposed standard level would not continue to drop as harvest capacity 

increases, as it does for equipment with harvest capacity less than 2,500 lb ice per 24 

hours.

Table IV.10 Baseline Efficiency Levels for Batch Ice Makers

Equipment Type Type of 

Cooling

Rated Harvest 

Rate

lb ice/24 hours

Maximum Energy 

Use

kWh/100 lb ice

Maximum Condenser 

Water Use*

gal/100 lb ice

Ice-Making Head

Water

<500 7.79-0.0055H**, † 200-0.022H

≥500 and <1,436 5.58-0.0011H 200-0.022H

≥1,436 4.0 145

Air

<450 10.26-0.0086H Not Applicable

≥450 and <2,500 6.89-0.0011H Not Applicable

≥2,500 4.1 Not Applicable

Remote Condensing 

(but not remote 

compressor)

Air

<1,000 8.85-0.0038H Not Applicable

≥1,000 5.10 Not Applicable

Remote Condensing 

and Remote 

Compressor

Air

<934 8.85-0.0038H Not Applicable

≥934 5.30 Not Applicable

Self-Contained

Water

<200 11.4-0.019H 191-0.0

≥200 7.60

For <2,500: 191-

0.0315H

For ≥2,500: 112

Air <175 18.0-0.0469H Not Applicable

≥175 9.80 Not Applicable

* Water use is for the condenser only and does not include potable water used to make ice.

** H = rated harvest rate in pounds per 24 hours, indicating the water or energy use for a given rated harvest rate.

Source: 42 U.S.C. 6313(d).

† There is a gap between the existing IMH-W-Small-B standard and the IMH-W-Medium-B standard. The baseline 

equation for the IMH-W-Small-B equipment class was adjusted from 7.8 – 0.0055*H to 7.79 – 0.0055*H to close this 

gap.

110
Currently there are no DOE energy standards for continuous type ice makers. 

During the preliminary analysis, DOE developed baseline efficiency levels using energy 

use data available from several sources, as discussed in chapter 3 of the preliminary TSD. 

DOE chose baseline efficiency levels that would be met by nearly all ice makers 

represented in the databases. Also, because energy use reported at the time DOE was 

preparing the preliminary analysis did not include the hardness adjustment prescribed by 

the new test procedure,

33 DOE made these adjustments to the data. At that time, hardness 

data was also not generally available for ice makers; therefore, DOE used assumptions of 

0.7 ice hardness for flake ice makers and 0.85 for nugget ice makers to make the hardness 

adjustments, thus estimating energy use as it would be measured by the new test 

procedure. 77 FR 3404 (Jan. 24, 2012). DOE selected harvest capacity break points 

(harvest capacities at which the slopes of the trial baseline efficiency levels change) for 

all but the self-contained equipment classes consistent with those selected by the 

Consortium for Energy Efficiency (CEE) for their new Tier 2 efficiency level for flake 

ice makers. Note that DOE did not also adopt the CEE energy use levels for any of its 

incremental efficiency levels because the CEE energy use levels do not incorporate 

adjustment of the measured energy use based on ice hardness. 

For the NOPR analysis, DOE used newly available information published in the 

AHRI Directory of Certified Product Performance, the California Energy Commission, 

the ENERGY STAR program, and vendor websites, to update its icemaker ratings 

database (“DOE icemaker ratings database”). In 2012, AHRI published equipment ratings 

33 Ice hardness is a term used for ice produced by continuous type ice makers, describing what percentage 

of the output is hard ice (as compared to water).

111

 
for many continuous type ice makers, including ice hardness factors calculated as 

prescribed by ASHRAE 29-2009, which is incorporated by reference in the new DOE test 

procedure. DOE recreated its database for continuous type ice makers based on the 

available AHRI data, considering only the ice makers for which AHRI ratings for ice 

hardness were available. DOE also adjusted the harvest capacity break points for the 

continuous equipment classes based on the new data.

The baseline efficiency levels for continuous type ice makers are presented in 

Table IV.11Table IV.11. They are compared with the ice maker energy use data in 

chapter 3 of the NOPR TSD. For the remote condensing equipment, the large-capacity

remote compressor and large-capacity non-remote compressor classes have been 

separated and are different by 0.2 kWh/100 lb, identical to the batch equipment 

differential. This differential is also discussed briefly in section IV.B.1.e. DOE requests 

comments on the development of efficiency levels for continuous type ice makers and 

whether the selected levels appropriately represent baseline equipment.

Table IV.11 Baseline Efficiency Levels for Continuous Ice Maker Equipment 

Classes

Equipment Type Type of 

Cooling

Rated Harvest 

Rate

lb ice/24 hours

Maximum Energy 

Use

kWh/100 lb ice*

Maximum 

Condenser Water 

Use*

gal/100 lb ice

Ice-Making Head

Water

Small (<900) 8.1-0.00333H 160-0.0176H

Large (≥900) 5.1 ≤2,500: 160-0.0176H

>2,500: 116

Air Small (<700) 11.0-0.00629H Not Applicable

Large (≥700) 6.6 Not Applicable

Remote Condensing 

(Remote Compressor) Air Small (<850) 10.2-0.00459H Not Applicable

Large (≥850) 6.3 Not Applicable

Remote Condensing 

(Non-remote 

Compressor)

Air

Small (<850) 10.0-0.00459H Not Applicable

Large (≥850) 6.1 Not Applicable

Self-Contained Water Small (<900) 9.1-0.00333H 153-0.0252H

Large (≥900) 6.1 ≤2,500: 

112
153-0.0252H

>2,500: 90

Air Small (<700) 11.5-0.00629H Not Applicable

Large (≥700) 7.1 Not Applicable

* H = rated harvest capacityrate in lb ice/24 hours

b. Incremental Efficiency Levels

For each of the nine analyzed batch type ice-making equipment classes, DOE 

established a series of incremental efficiency levels for which it has developed 

incremental cost data and quantified the cost-efficiency relationship. DOE chose a set of 

analyzed equipment classes that would be representative of all batch type ice-making 

equipment classes, and grouped non-analyzed equipment classes with analyzed 

equipment classes accordingly in the downstream analysis. Table IV.12Table IV.12

shows the selected incremental efficiency levels.

For the IMH-A-Large-B equipment class, DOE is adopting its suggested approach 

from the preliminary analysis meeting. (DOE, Preliminary Analysis Public Meeting 

Presentation, No. 42 at p. 29) As part of this approach, DOE is treating the largest units 

as an extended equipment class (IMH-A-Extended-B), basing the analysis for this 

equipment class on the analysis for a 1,500 lb ice/24 hour IMH-A-Large-B unit. When 

setting TSLs, DOE is considering the 800 lb ice/24 hour IMH-A-Large-B analysis 

separately from the 1,500 lb ice/24 hour analysis.

Table IV.12 Incremental Efficiency Levels for Batch Ice Maker Equipment Classes

Equipment Type*

Rated Harvest 

Capacity Rate

lb ice/24 hours

EL 2** EL 3 EL 4 EL 5 EL 6

IMH-W-Small-B <500 10% 15% 20% 25%

IMH-W-Med-B ≥500 and <1,436 10% 15% 20%

IMH-W-Large-B ≥1,436 10% 15% 20%

IMH-A-Small-B <450 10% 15% 20% 25% 30%

113
(E-STAR†

)

IMH-A-Large-B‡ ≥450 10%

(E-STAR†) 15% 20% 25%

RCU-NRC-Small-B*** <1,000 9%

(E-STAR†) 15% 20%

RCU-NRC-Large-B ≥1,000 9%

(E-STAR†) 15% 20%

RCU-RC-B

<934 9%

(E-STAR†) 15% 20%

≥934 9%

(E-STAR†) 15% 20%

SCU-W-Small-B*** <200 7% 15% 20% 25% 30%

SCU-W-Large-B ≥200 7% 15% 20% 25% 30%

SCU-A-Small-B <175 7%

(E-STAR†) 15% 20% 25% 30%

SCU-A-Large-B ≥175 7%

(E-STAR†) 15% 20% 25% 30%

* See Table III.1 for a description of these abbreviations.

** EL = efficiency level; EL 1 is the baseline efficiency level, while EL 2 through EL 6 represent increased efficiency 

levels.

*** These equipment classes were not directly analyzed

† New ENERGY STAR levels became effective on February 1, 2013. These levels represent the ENERGY STAR 

levels prior to February 1, 2013.

‡ The IMH-A-Large-B levels were analyzed at the 800 lb ice/24 hour size and the 1,500 lb ice/24 hour size, and the 

1,500 lb ice/24 hour size were used to set standards for the new IMH-A-Extended-B class.

For each of the three analyzed continuous type ice maker equipment classes, DOE 

established a series of incremental efficiency levels, for which it has developed 

incremental cost data and quantified the cost-efficiency relationship. DOE chose a set of 

analyzed equipment classes that would be representative of all continuous type icemaking equipment classes, and grouped non-analyzed equipment classes with analyzed 

equipment classes accordingly in the downstream analysis, as discussed in section V.A.1. 

Table IV.13Table IV.13 shows the selected incremental efficiency levels. The efficiency 

levels are defined by the percent energy use less than the baseline energy use. 

Table IV.13 Selected Incremental Efficiency Levels for Continuous Type Ice Maker 

Equipment Classes

Equipment 

Type*

Rated 

Harvest 

Capacity

EL 2** EL 3 EL 4 EL 5 EL 6

114
Rate

lb ice/24 

hours

IMH-W-Small-C <900

IMH-W-Large-C ≥900

IMH-A-Small-C <700 10% 15% 20% 25% 30%

IMH-A-Large-C ≥700 10% 15% 20% 25% 30%

RCU-Small-C <850 Not Analyzed

RCU-Large-C ≥850 Not Analyzed

SCU-W-Small-C <900 Not Analyzed

SCU-W-Large-C ≥900 No existing products on the market

SCU-A-Small-C <700 7% 15% 20% 25%

SCU-A-Large-C ≥700 No existing products on the market

* See Table III.1 for a description of these abbreviations.

** EL 1 is the baseline efficiency level, while EL 2 through EL 6 represent increased efficiency levels.

DOE selected the efficiency levels for the continuous type ice makers based on 

the levels proposed in the preliminary analysis. 

c. IMH-A-Large-B Treatment

The current DOE energy conservation standard for large air-cooled IMH cube 

type ice makers is represented by an equation for which maximum allowable energy 

usage decreases linearly as harvest rate increases from 450 to 2,500 lb ice/24 hours. 

Extending the current IMH-A-Large-B equation to the 4,000 lb ice / 24 hours range 

would result in efficiency levels in the newly covered range (between 2,500 lb/day and 

4,000 lb/day) that may not be technically feasible. For example, at 4,000 lb ice/24 hours, 

the specified baseline energy use would be 2.49 kWh/100 lb, a value far below the energy 

consumption of existing IMH-A-Large-B ice makers (e.g., it is 39 percent lower than the 

lowest rating for IMH-A-Large-B equipment of which DOE is aware, 4.1 kWh/100 lb). 

In the preliminary analysis, DOE proposed establishing baseline and incremental 

115
efficiency levels for this equipment class that maintain a constant level of energy use at 

higher harvest capacities, with exceptions in certain harvest capacity ranges to avoid 

backsliding. For example, for efficiency level 2, DOE proposed that (a) between 1,600 

and 2,080 lb ice/24 hours, the maximum energy use would be independent of harvest 

capacity, as is the case for all other high-harvest-capacity equipment classes, (b) between 

2,080 lb ice/24 hours, the maximum energy usage would be calculated according to the 

current standard to avoid EPCA anti-backsliding provisions, and (c) between 2,500 and 

4,000 lb ice/24 hours, the maximum energy use would remain constant. DOE presented 

this approach in the preliminary analysis and requested comment on it; DOE did not 

receive any comments on this approach.

Hence, DOE is proposing to use the approach it outlined in the preliminary 

analysis meeting for the IMH-A-Large-B equipment class (DOE, Preliminary Analysis 

Public Meeting Presentation, No. at p. 29). Further, DOE proposes to separate capacity 

ranges of this class into ranges designated IMH-A-B and IMH-A-Extended-B, the first 

for equipment with harvest capacity less than 1,500 lb ice/ 24 hours and the second with 

greater harvest capacity. The proposed IMH-A-B efficiency levels would be constant 

between 800 and 1,500 lb ice/24 hours. Each proposed IMH-A-Extended-B efficiency 

level would start at an energy use that is equal to that of one of IMH-A-B efficiency 

levels. Its energy use would remain constant at this level within its lower range of harvest 

capacity rates, but would follow the current DOE standard between the harvest capacity 

for which the constant level equals the current DOE standard and 2,500 lb ice/24 hours. 

116
Beyond 2,500 lb ice/24 hours, it would remain constant from 2,500 to 4,000 lb ice/24 

hours.

d. Maximum Available Efficiency Equipment

For the NOPR analysis, DOE considered the most-efficient equipment available 

on the market, known as maximum available equipment. In some cases, the maximum 

available equipment uses technology options that DOE chose to screen out for its 

analysis. Hence, DOE also identified maximum available equipment without screened 

technologies (see the discussion of the engineering analysis in section IV.D.2.f). The 

technologies that are used in some maximum available equipment that were screened out 

include low thermal-mass evaporators and tube evaporators for batch type ice makers.

Efficiency levels for maximum available equipment in the batch type ice-making 

equipment classes are tabulated in Table V.16Table V.15. This information is based on 

DOE’s icemaker ratings database (also see data in chapter 3 of the NOPR TSD). The 

efficiency levels are represented as an energy use percentage reduction compared to the 

energy use of baseline-efficiency equipment, the selection of which is discussed in 

section IV.D.2.a.

Table IV.14 Efficiency Levels for Maximum Available Equipment in Batch Ice 

Maker Equipment Classes

Equipment Class Energy Use Lower than Baseline

IMH-W-Small-B 24.5%

IMH-W-Med-B 22.4%

IMH-W-Large-B 7.5% (at 1,500 lb ice/24 hours)

8.3% (at 2,600 lb ice/24 hours)

IMH-A-Small-B 23.6%

IMH-A-Large-B 20.7% (at 800 lb ice/24 hours)

21.3% (at 1,500 lb ice/24 hours)

RCU-Small-B 24.6%

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RCU-Large-B 40.2% (at 1,500 lb ice/24 hours)

26.7% (at 2,400 lb ice/24 hours)

SCU-W-Small-B 22.5%

SCU-W-Large-B 27.6%

SCU-A-Small-B 35.8%

SCU-A-Large-B 29.6%*

* This is the second highest rated product; the highest rated product is also a dispenser 

unit.

Efficiency levels for maximum available equipment in the continuous type icemaking equipment classes are tabulated in Table IV.15Table IV.15. This information is 

based on a survey of product databases and manufacturer websites (also see data in 

chapter 3 of the TSD). The efficiency levels are represented as an energy use percentage 

reduction compared to the energy use of baseline-efficiency equipment, the selection for 

which is discussed in section IV.D.2.a. DOE used the maximum available efficiency 

levels to calibrate its engineering analysis against current equipment. 

Table IV.15 Efficiency Levels for Maximum Available Equipment for Continuous

Type Ice Maker Equipment Classes

Equipment Class Energy Use Lower than Baseline

IMH-W-Small-C 16.5%

IMH-W-Large-C 12.2% (at 1,000 lb ice/24 hours)

8.6% (at 1,800 lb ice/24 hours)

IMH-A-Small-C 25.3%

IMH-A-Large-C 8.1% (at 820 lb ice/24 hours)

17.0% (at 1,500 lb ice/24 hours)

RCU-Small-C 18.4%

RCU-Large-C 18.5% 

SCU-W-Small-C 18.7%*

SCU-W-Large-C No equipment on the market*

SCU-A-Small-C 24.4%

SCU-A-Large-C No equipment on the market*

*DOE’s inspection of currently available equipment revealed that there are no 

available products in the defined SCU-W-Large-C and SCU-A-Large-C equipment

classes at this time.

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e. Maximum Technologically Feasible Efficiency Levels

When DOE proposes to adopt (or not adopt) an amended or new energy 

conservation standard for a type or class of covered equipment such as automatic 

commercial ice makers, it determines the maximum improvement in energy efficiency 

that is technologically feasible for such equipment. (See 42 U.S.C. 6295(p)(1) and 

6313(d)(4)) Accordingly, in the preliminary analysis, DOE determined the maximum 

technologically feasible (“max-tech”) improvements in energy efficiency for automatic 

commercial ice makers in the engineering analysis using energy modeling and the design 

options that passed the screening analysis. As part of the NOPR analysis, DOE modified 

its energy use analysis. In addition, DOE considered a different range of design options. 

Evaluation of maximum technological feasibility was again based on energy modeling, 

but DOE compared energy modeling results with maximum available without screened 

technologies to ensure consistency of results with actual designs at that level. See chapter 

5 of the NOPR TSD for the results of the analyses, and a list of technologies included in 

max-tech equipment.

The max-tech efficiency levels represent equipment combining all of the design 

options. However, they are not generally attained by existing equipment—this is largely 

due to the consideration of design options seldom used in commercially available 

equipment because they are not considered to be cost-effective by manufacturers, such as 

brushless DC motors and drain water heat exchangers. DOE does not screen out design 

options based on cost-effectiveness.

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Table III.2Table III.2 and Table III.3Table III.3 show the max-tech levels 

determined in the engineering analysis for batch and continuous type automatic 

commercial ice makers, respectively.

Table IV.16 Max-Tech Levels for Batch Automatic Commercial Ice Makers

Equipment Type * Energy Use Lower than Baseline

IMH-W-Small-B 30%

IMH-W-Med-B 22%

IMH-W-Large-B 17% (at 1,500 lb ice/24 hours)

16% (at 2,600 lb ice/24 hours)

IMH-A-Small-B 33%

IMH-A-Large-B 33% (at 800 lb ice/24 hours)

21% (at 1,500 lb ice /24 hours)

RCU-Small-B Not analyzed

RCU-Large-B 21% (at 1,500 lb ice/24 hours)

21% (at 2,400 lb ice/24 hours)

SCU-W-Small-B Not analyzed

SCU-W-Large-B 35%

SCU-A-Small-B 41%

SCU-A-Large-B 36%

* IMH is ice-making head; RCU is remote condensing unit; SCU is self-contained 

unit; W is water-cooled; A is air-cooled; Small refers to the lowest harvest category; 

Med refers to the Medium category (water-cooled IMH only); Large refers to the large 

size category; RCU units were modeled as one with line losses used to distinguish 

standards. 

Table IV.17 Max-Tech Levels for Continuous Automatic Commercial Ice Makers

Equipment Type Energy Use Lower than Baseline

IMH-W-Small-C Not analyzed

IMH-W-Large-C Not analyzed

IMH-A-Small-C 25.3%

IMH-A-Large-C 17% (at 820 lb ice/24 hours)

RCU-Small-C Not analyzed

RCU-Large-C Not analyzed

SCU-W-Small-C Not analyzed

SCU-W-Large-C* No units available

SCU-A-Small-C 24%

SCU-A-Large-C* No units available

* DOE’s investigation of equipment on the market revealed that there are no existing 

products in either of these two equipment classes (as defined in this NOPR).

f. Comment Discussion

Impact of the Variability of Ice Hardness Measurements on Efficiency Levels for 

Continuous Type Ice Maker Equipment

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Manitowoc noted that there are no industry standards for the calorimetric values 

of different types of ice and cautioned that DOE’s assumptions for these calorimetric 

values may invalidate its analysis of manufacturer-supplied data. (Manitowoc, Public 

Meeting Transcript, No. 42 at pp. 51-52) Hoshizaki recommended that ice hardness have 

one standard that incorporates all continuous type ice maker data and added that DOE 

should readdress the baseline for continuous type ice-making equipment after taking 

AHRI’s 2012 ice hardness verification testing into account. (Hoshizaki, No. 53 at p. 1)

Howe recommended that DOE supplement its data on continuous type ice makers 

by including results from tests using the current test procedure, adding that information 

on continuous type ice makers has changed drastically as of late. (Howe, No. 51 at p. 2)

DOE notes that some of these comments were made before AHRI had completed 

verification testing work that is mentioned by Hoshizaki. DOE updated its database over 

the course of 2012, as many of the continuous type ice maker data in AHRI’s database 

were updated, and hardness data was provided. DOE has primarily used this data, 

supplemented by DOE test data (including hardness test data) to evaluate the energy 

consumption characteristics of continuous type ice-making equipment and to set 

efficiency levels. 

DOE notes that, consistent with Hoshizaki’s suggestion, the proposed standards 

for continuous type ice makers use one metric that combines ice quality and energy 

usage. In addition, DOE has not proposed use of the Canadian efficiency levels for 

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continuous type ice makers. The proposed efficiency levels for continuous type ice

makers are discussed in sections IV.D.2.a and IV.D.2.b.

Correlation of Efficiency Levels with Design Options

Manitowoc expressed confusion over the relationship between the efficiency 

levels and the technology options that go into those efficiency levels. Therefore, 

Manitowoc requested that DOE provide additional information to explain which 

technology options were associated with each efficiency level. (Manitowoc, Public 

Meeting Transcript, No. 42 at p. 51)

Manitowoc pointed out that one of the SCU-air-cooled models used for the maxavailable efficiency level is actually a combined ice machine and hotel dispenser, and as 

such is not a representative example of the SCU category, which generally consists of 

undercounter designs. Manitowoc further stated that its larger size would allow the model 

to achieve higher efficiencies than would normally be possible for the majority of SCU 

air-cooled models. Therefore, Manitowoc commented, this model should not be used to 

justify the max-available efficiency attainable for this category of ice makers. 

(Manitowoc, No. 54 at pp. 2-3)

In response to Manitowoc’s comment regarding the relationship of design options 

and efficiency levels, DOE provided additional information in the automatic commercial 

122
ice maker docket, as a supporting and related material document34 (DOE, Preliminary 

Analysis Presentation Supplementary Engineering Data, No. 43). The data in this 

document reflects the preliminary engineering analysis. For the NOPR analysis, the 

relationship between design options and efficiency levels has changed due to changes 

made to the design options considered, assumptions, and analysis approach. The new 

information is detailed in sections IV.D.4.a (cost model adjustments) and IV.D.4.f

(energy model adjustments) and in the NOPR TSD chapter 5.

DOE notes that Manitowoc is correct in its observation that one of the maxavailable SCU models from the preliminary analysis is not representative of the 

undercounter units that make up the majority of the SCU category. DOE had intended to 

avoid inclusion of oversize SCU models that are not suitable for undercounter design in 

its establishment of maximum technology for SCU equipment classes. DOE has reviewed 

the maximum technology designations and has removed all ice maker-dispenser 

combinations from consideration in its analysis.

RCU Class Efficiency Level Differential

In its preliminary engineering analysis, DOE concluded that the 0.2 kWh per 100 

lb ice differential in maximum allowable energy use for large-sized batch RCU ice 

makers with remote compressors as compared with those with compressors in the icemaking heads is appropriate, both for batch and continuous type ice makers. (DOE, 

34 See www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0037-0043. After the February 

2012 preliminary analysis public meeting, DOE published cost-efficiency curves showing the relationship 

of efficiency levels to design options for each directly analyzed equipment class.

123

 
Preliminary Analysis Public Meeting Presentation, No. 29 at p. 30) DOE requested 

comment on this conclusion. 

Manitowoc confirmed that the 0.2 kWh per 100 lb of ice difference in energy use 

between these two classes of RCUs seemed valid and that it was reasonable to continue 

using this value while developing the new standards. (Manitowoc, Public Meeting 

Transcript, No. 42 at p. 44 and No. 54 at p. 3) CA IOUs stated that its analysis of product 

data indicates that RCUs with and without dedicated remote compressors do not consume 

significantly different levels of energy. CA IOUs thus suggested that DOE continue to 

look at product performance data and customer utility in order to determine whether 

separate equipment classes and efficiency levels are necessary for these two types of 

RCU units. (CA IOUs, No. 56 at p. 2)

Consistent with the comment from Manitowoc, DOE plans to continue using this 

differential of 0.2 kWh per 100 lb of ice to differentiate between RCUs with and without 

remote compressors. 

Batch Efficiency Levels for High-Capacity Ice Maker 

DOE has established baseline and incremental efficiency levels for large-capacity 

ice makers in the newly extended capacity between 2,500 and 4,000 lb ice/24 hours. 

AHRI noted that the current efficiency standard for high-capacity batch machines 

was established based on the performance of ice makers available in the marketplace and 

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that extending this efficiency level to ice makers with capacities exceeding 2,500 lb 

ice/24 hours may not be appropriate. AHRI recommended that DOE either select and 

analyze products in this capacity range or refrain from regulating these products if there 

are not actually enough high-capacity batch machines available for DOE to analyze. 

(AHRI, No. 49 at pp. 3-4)

Manitowoc stated that efficiency curves are typically flat for icemakers with 

capacities above 2,000 to 2,500 lb ice/24 hours and noted that this phenomenon is driven 

mainly by trends in compressor efficiencies, which have decreasing efficiency gains 

above a certain size. Additionally, Manitowoc commented that it tends to use multiple 

evaporators for large-capacity machines, rather than making new evaporators for every 

size, so its overall evaporator performance also does not improve significantly over a 

certain size. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 48-49)

However, Manitowoc also commented that DOE did not adequately analyze the 

efficiency of ice machines in the 2,000 to 4,000 lb ice/24 hour capacity range. Manitowoc 

suggested that it is likely that, above a certain capacity, DOE will find that the relative 

benefit of some design options to be lower due to the relatively higher efficiency of the 

baseline components already in use. (Manitowoc, No. 54 at p. 3)

Howe commented that most high-capacity ice makers are inherently more 

efficient than their lower-capacity counterparts and thus cannot be expected to achieve 

the same incremental efficiency gains. Howe added that, if incremental efficiency gains 

125
do indeed vary significantly by harvest capacity, equipment class definitions may need to 

change. (Howe, No. 51 at pp. 2-3)

Hoshizaki recommended that DOE make equipment plots for high-capacity batch 

models in order to compare existing models against the proposed efficiency levels. 

(Hoshizaki, No. 53 at p. 2)

Hoshizaki commented that DOE needs to analyze the available data for all 

eligible RCU models rather than just relying on software assumptions to inform its 

analysis. Hoshizaki added that there is not enough data available for DOE to adequately 

assess high-capacity (>2,500 lb ice/24 hours) RCU energy use and recommended that 

manufacturers provide input to DOE regarding these high-capacity units. (Hoshizaki, No. 

53 at p. 1)

In response to AHRI, DOE reiterates that there is precedence for setting standards 

for capacity ranges for which equipment is not being sold, including when DOE adopted 

standards for air-cooled IMH cube type ice makers up to 2,500 lb ice/24 hours, even 

though no such equipment is manufactured with capacities above 1,650 lb ice/24 hours. 

DOE simply is extending the capacity range of the standard for consistency with the 

applicability of the test procedure. DOE notes that it has proposed efficiency levels for 

the larger ice makers that, to the extent possible, do not change as a function of harvest 

capacity. Manitowoc’s comments suggest that larger-capacity ice machines would have 

comparable efficiency level as compared with lower-capacity machines, and Howe’s 

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comments suggest that larger-capacity ice machines are inherently more efficient. Hence, 

the constant energy use efficiency level would be appropriate. The commenters did not 

highlight any other specific factors that would suggest that the constant energy use 

approach is inappropriate. Examination of the limited available data showing rated 

energy use as a function of harvest capacity certainly supports the approach, even though 

there is much less data to consider that at the lower capacity levels.

In response to Manitowoc’s comment regarding analysis of batch type ice makers 

in the 2,000 to 4,000 lb ice/24 hours harvest capacity range, DOE notes that it has

conducted analysis for three of these products—given the limited number of such 

products available, this likely represents a greater percentage of the available products 

than DOE evaluated at lower-harvest-capacity rates. Because, as mentioned by 

Manitowoc, efficiency characteristics of the components of ice makers such as 

compressors and evaporators no longer improve as capacity increases, it is reasonable to 

expect that ice maker efficiency will also remain constant at high-harvest-capacity rates.

For this reason, it is appropriate to represent performance of the full harvest capacity 

range with the available ice makers of the highest harvest capacities, as DOE has done.

In response to Howe’s comment, DOE has not considered reductions in efficiency 

at constant kilowatt-hours per 100 lb ice levels across the harvest capacity range. Instead, 

DOE has considered reductions in energy use in terms of percentages of baseline energy 

use. Hence, the energy use reductions associated with the incremental efficiency levels 

would be significantly less for a large-harvest-capacity ice maker with an already 

127
inherently low energy use than it would for a lower-harvest-capacity ice maker. Further, 

if the larger-capacity ice makers are inherently more efficient, as Howe contends, DOE’s 

approach using efficiency levels that do not vary with capacity should not be overly 

aggressive, i.e. setting efficiency levels too stringently.

With respect to Hoshizaki’s recommendation regarding examination of efficiency 

plots, DOE has reviewed energy use data for all products for which such data is available. 

The maximum efficiency levels considered in the analysis are not generally attained by 

existing equipment—this is largely due to the consideration of design options often 

considered not to be cost-effective by manufacturers, such as brushless DC motors and 

drain water heat exchangers. However, DOE’s analysis results compared well to the 

maximum available without screened technologies efficiency level.

In response to the second comment from Hoshizaki, DOE notes that the analysis 

for high-capacity units considered several pieces of information, including available 

performance rating data of the AHRI database and confidential interviews with 

manufacturers. A significant amount of the information obtained from manufacturers in 

confidential interviews was obtained during the NOPR phase, in part in response to 

preliminary analysis phase comments, such as the Hoshizaki comment, recommending 

some information exchange. In addition, DOE purchased and conducted reverse 

engineering on the largest-capacity batch and continuous type ice makers made by the 

manufacturers that comprise 90 percent or greater share of the ice maker market. DOE 

also conducted energy testing on a few of these ice makers. DOE believes that its analysis 

128
of RCU equipment is representative of the large-capacity equipment classes. Additional 

information on the teardown analysis is available in chapter 5 of the NOPR TSD. 

Discrepancies between Maximum Technology Levels and Most-Efficient 

Equipment Available in the Marketplace

NPCC, ASAP, and NEEA/NPCC commented on the max-tech efficiency levels

(i.e., least energy consumptive level) and that, in some cases, max-tech levels were less 

efficient than the most-efficient level on the marketplace (i.e., “max-available” energy 

level). NPCC further commented that DOE should indicate whether this discrepancy is 

due to technologies that were screened out. NEEA/NPCC pointed to products in a Natural 

Resources Canada (NRCan) database that surpassed DOE's max-tech levels. (NPCC, 

Public Meeting Transcript, No. 42 at pp. 45-46; ASAP, Public Meeting Transcript, No. 

42 at p. 50; NEEA/NPCC, No. 50 at pp. 2-4) NPCC also recommended that DOE 

investigate whether there are superior technologies on the market that were not being 

analyzed simply because of the way max-tech is defined. NPCC added that the process 

by which design options are screened out should be very deliberate. (NPCC, Public 

Meeting Transcript, No. 42 at pp. 53-54)

Scotsman noted that, even within a single equipment class, maximum technology 

levels will differ among models. For example, although DOE is considering compressor 

upgrade as a design option, many ice maker units are already using the most-efficient 

compressor suitable to their respective applications. Scotsman added that the analytical 

129
model used to calculate energy use for max-tech levels had not been validated and was 

thus unreliable. (Scotsman, No. 46 at p. 4)

DOE acknowledges that there are units on the market that surpass the max-tech 

levels it proposed for the preliminary analysis. In some cases maximum available

efficiency units include technologies that DOE had decided not to consider. For example, 

some max-tech units utilize proprietary technologies that are not available to the majority 

of manufacturers and were screened out in the screening analysis. Due to these 

differences, DOE’s max-tech efficiency levels did not always exceed the max-available 

levels found on the market. Because they are representative of the whole market, DOE’s 

max-tech levels must take into account issues with proprietary technologies as well as 

utility issues stemming from certain technologies (such as chassis size increases or ice 

cube shapes). 

In the NOPR phase, DOE made several changes to the preliminary analysis.

These changes included:

• adding a design option to allow for growth of the unit to increase the size of 

the condenser and/or evaporator;

• adjusting assumptions regarding maximum compressor EER levels based on 

additional research and confidential input from manufacturers;

• adjusting potable water consumption rates for batch type ice makers subject to 

a floor that represents the lowest potable water consumption rate that would 

be expected to flush out dissolved solid reliably;

130
• adding a design option to allow condenser growth in water-cooled condensers; 

and 

• adding a drain water heat exchanger design option.

These changes have led to new max-tech levels. These levels are compared to the 

most-efficient levels available on the market in Table IV.18Table IV.18. The levels are 

also compared with the most-efficient levels available that do not use technologies that 

DOE screened out in the screening analysis (called “max available without screened 

technologies”). Specifically, for batch type ice makers, the differences between these two 

max available market levels are that the max using analyzed technologies levels do not 

consider (a) low-thermal-mass evaporators, and (b) tube ice evaporators. The new maxtech levels all exceed the “max available without screened technologies” efficiency 

levels. DOE also notes that this discrepancy only existed for batch units, as DOE did not 

screen out any continuous unit technologies in its engineering analysis.

DOE considered max-tech and max-available levels as part of its analysis. The 

max-tech levels for batch and continuous type ice makers are discussed in section 

IV.D.2.e. In addition to comparing the max-tech, “most efficient on market”, and the 

“max available without screened technologies” efficiency levels for batch type ice

makers. Table IV.18Table IV.18 provides brief explanations for the differences between 

max-available and max-tech levels. More details regarding the design options that 

correlate with the different efficiency levels are provided in the NOPR TSD. DOE 

requests comments on the max-tech levels identified in today’s NOPR, the max available 

131
and max available without screened technologies levels, and the reasons cited for the max 

tech/max available differences.

Table IV.18 Comparison of Levels for Batch Automatic Commercial Ice Makers

Equipment Class Max-Tech 

Level

MaxAvailable 

without 

Screened 

Technologies

MaxAvailable

Reason for Gap between 

Max-Available and Max 

Available without Screened 

Technologies

IMH-W-Small-B 30% 22.0% 24.5% Proprietary technology

IMH-W-Med-B 22% 15.7% 22.4% Proprietary technology

IMH-W-Large-B

16% (at 2,600 

lb ice/24 

hours)

8.3% 22.5%

Proprietary technology and

utility issues

IMH-A-Small-B 33% 23.6% 23.6% No gap

IMH-A-Large-B

33% (at 800 lb 

ice/24 hours)

21% (at 1,500 

lb ice/24 

hours)

20.7% 21.3% proprietary technology

RCU-NRC-Small-B Not analyzed 24.6% 24.6% No gap

RCU-NRC-Large-B

21% (at 1,500 

lb ice/24 

hours)

21% (at 2,400 

lb ice/24 

hours)

15.7% 40.2%

Proprietary technology and 

utility issues

RCU-RC-Small-B Not directly 

analyzed 19.0% 19.0% No gap

RCU-RC-Large-B Not directly 

analyzed 15.1% 15.1% No gap

SCU-W-Small-B Not directly 

analyzed 22.2% 22.5% Proprietary technology

SCU-W-Large-B 35% 27.6% 32.9% Proprietary technology

SCU-A-Small-B 41% 27.4% 35.8% Proprietary technology

SCU-A-Large-B 36% 29.6% 33.4% Proprietary technology

Baseline Efficiency Levels for Currently Unregulated Ice Makers

For continuous and high-capacity batch type ice makers, AHRI recommended that 

DOE derive its baseline efficiency levels from machines that are currently on the market, 

for which AHRI's new directory of certified products could be a useful information 

source. AHRI cautioned, however, that its certification program was new and that it 

132
expected the data to change after completion of its 2012 test program. (AHRI, No. 49 at 

p. 3)

Manitowoc asserted that, while EPACT 2005 is the correct baseline efficiency 

level for batch equipment, continuous type ice machines do not have sufficient history 

under any alternative certification programs and therefore require careful review and 

analysis by DOE prior to setting efficiency levels. (Manitowoc, No. 54 at p. 3)

Hoshizaki asserted that DOE should not use Canadian levels for continuous type 

ice makers and instead suggested that DOE use efficiency levels developed for machines 

that are currently on the market. (Hoshizaki, No. 53 at p. 1)

In the preliminary analysis, DOE proposed a set of equations to represent baseline 

efficiency levels for the 12 continuous equipment classes. 77 FR 3404 (Jan. 24, 2012).

The equations were developed based on publicly available information of continuous 

type ice maker energy use for products on the market. As there was no source of ice 

quality data for most of these products to allow calculation of the energy use consistent 

with the new test procedure, which calls for adjustment of the rating to account for ice 

hardness, DOE made these adjustments using ice hardness equal to 0.85 for nugget ice 

makers and 0.8 for flake ice makers. Further details of this analysis are available in the 

preliminary analysis TSD.

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DOE revised its development of continuous type ice maker efficiency levels for 

the NOPR, based on data for continuous type ice machines that was available on the 

AHRI database website as of October 11, 2012. The database now contains ratings for ice 

quality, which DOE incorporated into its analysis. DOE’s analyses consider higher max 

tech levels than the max available levels, as represented by the AHRI data, because the 

analysis considers use of design options, such as higher efficiency permanent magnet

motors, which are not used in the majority of existing ice makers. DOE’s continuous 

baseline levels for the NOPR analysis are presented in Table IV.11Table IV.11. 

DOE has taken advantage of the new information for continuous type ice makers 

that has become available on the AHRI website to support its selection of efficiency 

levels for these equipment classes. 

General Methodology

Howe asked that DOE further clarify the methodology it used to establish 

efficiency and technology levels, especially for equipment classes in which there are few 

models available. Howe also asked whether DOE considered the refrigerating conditions 

used to produce ice or the typical efficiency levels associated with the refrigeration 

system. (Howe, No. 51 at p. 3)

DOE does not have sufficient resources to thoroughly analyze all equipment 

classes. Hence, the analyses for some classes are used to represent other classes. The 

analysis prioritized those classes for which shipments and the number of models available 

134
are high. The energy model used to support the analysis, which is described in the NOPR 

TSD, considers the refrigerating conditions used to produce ice and the capacity and 

power input of the equipment’s refrigerant compressors when operating at these 

conditions.

3. Design Options

After conducting the screening analysis and removing from consideration the 

technologies described above, DOE included the remaining technologies as design 

options in the NOPR engineering analysis. These technologies are listed in Table 

IV.19Table IV.19, with indication of the equipment classes to which they apply.

Table IV.19 Design Options by Equipment Class

Ice Maker 

Type

Equipment 

Class

Compressor UpgradeCondenser Fan MotorsPump MotorsAuger MotorsLarger Air-Cooled CondensersLarger WaterCooled CondensersBatch FillLarger EvaporatorsDrainwater Heat Exchanger

Batch

IMH-W-B √ √ √ √ √ √

IMH-A-B √ √ √ √ √ √ √

RCU-B √ √ √ √ √ √ √

SCU-W-B √ √ √ √ √ √

SCU-A-B √ √ √ √ √ √ √

Continuous

IMH-W-C Not Analyzed

IMH-A-C √ √ √ √ √

RCU-C Not Analyzed

SCU-W-C Not Analyzed

SCU-A-C √ √ √ √ √

135
a. Improved Condenser Performance in Batch Equipment

During the preliminary analysis, DOE considered size increase for the condenser 

to reduce condensing temperature and compressor power input. DOE requested comment 

on use of this design option and on the difficulty of implementing it in ice makers with 

size constraints.

AHRI commented that most condensers are already optimized and occasionally 

oversized; therefore, further increasing condenser area would not have any efficiency 

benefits and could instead necessitate increased cabinet size. (AHRI, No. 49 at p. 2)

Manitowoc commented that the outdoor condensers of RCUs can more easily 

accommodate size increases than the condensers incorporated into IMH equipment. 

However, Manitowoc also noted that increasing the size of the condenser coil in order to 

improve efficiency would necessitate an increased level of refrigerant. Manitowoc stated 

that this could require the installation of a larger receiver in the ice-making head, which 

may be difficult due to size constraints. (Manitowoc, Public Meeting Transcript, No. 42 

at p. 59) 

Manitowoc added that increasing the size of the condenser while maintaining a 

constant evaporator size can also interfere with the ability of the ice machine to properly 

make ice over the full range of ambient conditions. Manitowoc stated that DOE’s 

analysis is only concerned with performance at 90 °F air/70 °F water testing conditions, 

but that real ice makers have to work in air temperatures ranging from 50 to 110 °F and 

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water temperatures from 40 to 90 °F. As air temperature drops, Manitowoc stated, unless 

special refrigerant management devices are employed, a larger condenser will be forced 

to store more refrigerant at a lower temperature. This will prevent batch type ice

machines from being able to harvest ice at low ambient temperatures, according to 

Manitowoc. (Manitowoc, No. 54 at p. 2) Similarly, Scotsman commented that increasing 

the efficiency of the freeze cycle will lengthen the harvest process and minimize overall 

energy savings. (Scotsman, Public Meeting Transcript, No. 42 at pp. 59-60) Scotsman 

asserted that DOE’s analysis of condenser surface area must include this impact on the 

batch harvest cycle. (Scotsman, No. 46 at p. 3)

Hoshizaki commented that manufacturers would need more time to evaluate the 

implications of using larger water-cooled condensers on a closed-loop system. Although 

larger condensers would increase the efficiency of heat transfer, Hoshizaki opined that 

this benefit must be compared with the increased final cost to the consumer as well as the 

potential need to increase cabinet size. (Hoshizaki, No. 53 at p. 2)

In response to Manitowoc’s written comments, DOE has considered data obtained 

through testing of water-cooled units, as well as data provided by manufacturers on 

expected efficiency increases versus condenser growths.

DOE notes that the key concerns expressed in Hoshizaki’s comment relate to the 

potential need to increase cabinet size and the concern about whether the larger 

condenser (and perhaps cabinet) is cost-justified. As discussed in section IV.C.d, DOE 

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has considered a modest size increase for the ice-making head for some ice maker 

equipment classes. Answering the question of whether condenser size increase within 

these modest allowances for cabinet size increase is cost-effective is a key goal of the 

DOE analyses—the potential that the approach is not cost-effective is not a relevant 

argument for screening out this technology. 

In response to Scotsman and Manitowoc’s written comments, DOE conducted 

testing to assess the correlation of batch type ice maker efficiency level with condensing 

temperature and has used this information, which accounts for the increase in harvest 

energy use associated with lower condensing temperature, to adjust its analyses. DOE 

tested a water-cooled batch unit using different water-flow settings; the results are shown 

in Table IV.20Table IV.20. DOE notes that these test results indicate that there are 

energy benefits from increasing condenser area, even though harvest cycle energy use 

increases. The results show that the increase in harvest cycle energy use represents a loss 

of 15 percent of the gain that would have been achieved if harvest energy use had not 

increased. DOE used these test results to adjust the modeled harvest energy when 

condenser improvement such as size increase was applied as a design option. These 

analyses are described in chapter 5 of the NOPR TSD.

Table IV.20 Condenser Water Test Results

Test Attribute

Test Setting 1

(factorysetting)Test Setting 2 Test Setting 3

Condensing Temperature 

°F 97 107 111

Ice Harvest Rate 

lb ice/24 hours 375 361 355

Energy Consumption 

kWh/100 lb ice 4.67 5.13 5.28

Average Harvest Time (s) 104 81 73

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Average Harvest Energy 

Wh 21.2 17.9 17.0

Average Harvest Energy 

per Ice

kWh/100 lb

0.53 0.44 0.42

Percent of Savings Lost 

due to Harvest Energy 

Increase 

15% 12% N/A

DOE inspected baseline and high-efficiency units, including condenser sizes 

typical of each. For equipment classes for which DOE inspected high-efficiency units, 

DOE considered maximum condenser sizes consistent with the inspected units. For 

equipment classes where DOE did not have such information, DOE considered maximum 

condenser sizes consistent with the range of chassis sizes of commercially available 

equipment of the given class and harvest capacity. DOE notes that none of the evaluated 

IMH or SCU equipment has receivers, thus indicating that they would not be needed for 

the range of condenser sizes DOE considered in its analysis for these equipment classes.

DOE also considered whether a larger remote condenser would require installation of a 

larger receiver, and talked with receiver manufacturers about receiver sizing. DOE did 

not seek to increase receiver sizes for any of the models analyzed.

In response to comments by AHRI and Manitowoc, DOE studied the condensing 

temperatures of tested units to set limits for available efficiency improvement. DOE in its 

analyses considered only condenser changes that resulted in condensing temperatures 

within the range of those observed in the tested ice makers for comparable equipment 

classes (for instance DOE used different minimum condensing temperatures for aircooled and water-cooled equipment). These analyses are described in chapter 5 of the 

NOPR TSD.

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b. Harvest Capacity Oversizing

NPCC noted that many ice makers may be oversized for their particular 

applications, suggesting that there would be little compromise of customer utility if the 

capacity available for a given ice maker chassis size decreased as a result of design 

changes that increased their efficiency. (NPCC, Public Meeting Transcript, No. 42 at pp. 

60-61)

Manitowoc countered that its customers are very aware of how much ice they 

need and that they consequently size machines for peak demand days, rather than average 

use. Manitowoc added that it is very important that customers not shut down on days with 

high demand, such as the 4th of July. (Manitowoc, Public Meeting Transcript, No. 42 at 

p. 63)

DOE did not investigate potential down-sizing of equipment, instead relying on 

information regarding commercially available units as the basis for consideration of what 

sizes are acceptable for given capacity levels.

c. Open-Loop Condensing Water Designs

Open-loop cooling systems use condenser cooling water only once before 

disposing of it, whereas closed-loop (single-pass) systems repeatedly recirculate cooling 

water. In closed loops, the water is cooled in a cooling tower and recirculated to accept 

heat from the automatic commercial ice maker condenser again. Alternatively, the water 

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passes through another heat exchanger where the heat is removed and used in another 

piece of equipment, such as a space or water heater, before cycling back to the ice maker 

condenser. Although some condenser water may still be lost to evaporation in cooling 

towers, closed-loop systems still have negligible condenser water disposal or 

consumption compared to open-loop systems.

The Alliance expressed strong opposition to open-loop condenser water cooling 

for automatic commercial ice makers, arguing that such technology is obsolete and 

excessively wastes water and energy. The Alliance noted that more energy-efficient 

technologies such as air cooling, remote condensing, and closed-loop water-cooling 

systems have made single-pass water cooling unnecessary. Therefore, the Alliance urged 

DOE to disallow all ice makers that can be installed and operated with a single-pass 

cooling system. (Alliance, No. 45 at pp. 3-4)

DOE recognizes that open-loop water-cooling systems use significantly more 

water than other condenser cooling technologies. However, DOE determined after the 

Framework public meeting that its rulemaking authority extends only to the 

manufacturing of equipment and not to the installation or usage of equipment. Thus, 

DOE has no authority to mandate that dual-use water-cooled machines (those that can be 

used in either closed-loop or open-loop configurations) be used with closed-loop systems. 

Furthermore, DOE is not aware of any potential design requirements it could impose that 

would effectively prohibit open-loop cooling systems for water-cooled ice makers. Even 

if a design requirement could be effective in this regard, DOE can only adopt either a 

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prescriptive design requirement or a performance standard for commercial equipment. 

(42 U.S.C. 6311(18)) The focus of this rulemaking is an equipment performance 

standard. Due to the nature of this rulemaking, DOE is not considering any prescriptive 

design requirements, and open-loop cooling systems therefore remain a viable option for 

manufacturers of water-cooled ice makers who want to reduce their water consumption.

d. Condenser Water Flow

EPACT 2005 prescribes maximum condenser water use levels for water-cooled 

cube type automatic commercial ice makers. (42 U.S.C. 6313(d))35 For units not 

currently covered by the standard (continuous machines of all harvest rates and batch 

machines with harvest rates exceeding 2,500 lb ice/24 hours), there currently are no 

limits on condenser water use. 

In this rulemaking, DOE considered using higher condenser water flow rates as a 

design option for water-cooled ice makers. 

In chapter 2 of the preliminary TSD, DOE indicated that the ice maker standards 

primarily focus on energy use, and that DOE is not bound by EPCA to comprehensively 

evaluate and propose reductions in the maximum condenser water consumption levels, 

and likewise has the option to allow increases in condenser water use, if this is a costeffective way to improve energy efficiency. 

35 The table in 42 U.S.C. 6313(d)(1) states maximum energy and condenser water usage limits for cubetype ice machines producing between 50 and 2,500 lb of ice per 24 hour period (lb ice/24 hours). A 

footnote to the table states explicitly the water limits are for water used in the condenser and not potable 

water used to make ice.

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DOE did not analyze potential changes in condenser water use standards during 

the preliminary analysis. However, it did propose an approach for balancing energy use 

and condenser water use in the engineering analysis in a way that maintains the 

rulemaking’s focus on energy use reduction while appropriately considering the cost 

implications of changing condenser water use. DOE proposed using appropriate 

representative values for water and energy costs, product lifetime, and discount rates to 

calculate a representative LCC for baseline and modified design configurations as part of 

the engineering analysis. In this way, the engineering analysis would develop a 

relationship between energy efficiency and manufacturing cost as is customary in 

engineering analyses (i.e., the cost-efficiency curves), but the ordering of different design 

configurations in this curve would be based on minimizing the representative LCC 

calculated for the candidate design configurations at each successive efficiency level. 

Using this proposed analytical approach, an energy-saving increase in condenser water 

use would be expected to be cost-effective when the remaining design options, which do 

not change water use, have greater LCC increases than the option of increasing condenser 

water use. This approach would avoid the complexity of developing several cost curves 

representing multiple condenser water use levels and determining in the downstream 

analyses the efficiency levels at which increasing condenser water use would be 

appropriate. During the preliminary analysis, DOE requested comment on this approach 

for addressing condenser water use.

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AHRI commented that water-cooled ice makers are already efficient products and 

that reducing condenser water consumption could significantly increase their energy use. 

AHRI and Scotsman both cautioned that DOE must consider the impact that lower 

condensing temperatures could have on the harvest rate of batch type ice makers and 

ensure that product utility is not diminished by implementing new condenser water use 

standards. (AHRI, No. 49 at p. 4; Scotsman, Public Meeting Transcript, No. 42 at p. 70)

In the public meeting discussions, Manitowoc suggested that DOE consider 

decreasing the allowable condenser water use, which could be a more economical 

approach if water costs increase. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 

70-72) However, Manitowoc also noted in its written comments that condenser water 

use is carefully managed to ensure that ice makers can harvest ice under worst-case 

conditions and maintain water velocities within specified limits in order to avoid erosion. 

Manitowoc expressed doubt about the ability of DOE’s energy model to accurately 

predict the effects of these variables, and for this reason, Manitowoc strongly discouraged 

introducing condenser water use standards. (Manitowoc, No. 54 at pp. 3-4)

DOE stated that EPCA’s anti‐backsliding provision in section 325(o)(1), which 

lists specific products for which DOE is forbidden from prescribing amended standards 

that increase the maximum allowable water use, does not include ice makers. However, 

Earthjustice asserted that DOE lacks the authority to relax condenser water limits for 

water-cooled ice makers. Earthjustice argued that the failure of section 325(o)(1) to 

specifically call out ice maker condenser water use as a metric that is subject to the 

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statute’s prohibition against the relaxation of a standard is not determinative. On the 

contrary, Earthjustice maintained that the plain language of EPCA shows that Congress 

intended to apply the anti‐backsliding provision to ice makers. Earthjustice commented 

that section 342(d)(4) requires DOE to adopt standards for ice‐makers “at the maximum 

level that is technically feasible and economically justified, as provided in [section 325(o) 

and (p)].” (42 U.S.C. 6313(d)(4)) Earthjustice stated that, by referencing all of section 

325(o), the statute pulls in each of the distinct provisions of that subsection, including, 

among other things, the anti‐backsliding provision, the statutory factors governing 

economic justification, and the prohibition on adopting a standard that eliminates certain 

performance characteristics. By applying all of section 325(o) to ice‐makers, section 

342(d)(4) had already made the anti‐backsliding provision applicable to condenser water 

use, according to Earthjustice. Finally, Earthjustice stated that even if DOE concludes 

that the plain language of EPCA is not clear on this point, the only reasonable 

interpretation is that Congress did not intend to grant DOE the authority to relax the 

condenser water use standards for ice makers. Earthjustice added that the anti-backsliding 

provision is one of EPCA’s most powerful tools to improve the energy and water 

efficiency of appliances and commercial equipment, and Congress would presumably 

speak clearly if it intended to withhold its application to a specific product. (Earthjustice, 

No. 47 at pp. 4-5)

Scotsman commented that balancing condenser water use with energy use was a 

reasonable analytical approach. (Scotsman, No. 46 at p. 3) Scotsman added that including 

condenser water usage in the overall energy use of a machine would also impact 

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continuous type ice machines by affecting ice hardness. (Scotsman, Public Meeting 

Transcript, No. 42 at p. 70)

The Alliance argued that water use and energy use cannot be compared on a 

simple price basis because of key differences between the two resources. While energy 

comes from multiple sources and is a commodity whose prices fluctuate based on supply 

and demand, fresh water is in limited supply, the Alliance stated. Hence, water prices are 

heavily regulated and based on the cost of treatment and delivery, which is less directly 

affected by supply and demand, according to the Alliance. Therefore, the Alliance 

recommended that DOE consider the marginal costs of alternative water sources, such as 

desalination, in its analyses to properly account for all water costs as applied to watercooled condensers. (Alliance, No. 45 at p. 4)

In response to Earthjustice’s comment, DOE maintains its position from the 

preliminary analysis that the anti-backsliding provision of EPCA (42 U.S.C. 6313(d)(4)) 

does not apply to condenser water use in batch-type automatic commercial ice makers. 

While EPCA’s anti-backsliding provision (42 U.S.C. 6295(o)) applies to consumer 

products, 42 U.S.C. 6313(d)(4) makes the backsliding provision applicable to automatic 

commercial ice makers. However, 42 U.S.C. Sec. 6295(o)(1) anti-backsliding provisions 

apply to water in only a limited set of residential appliances and fixtures. Under 42 

U.S.C. Sec. 6295(o)(1), “the Secretary may not prescribe any amended standard which 

increases the maximum allowable energy use, or, in the case of showerheads, faucets, 

water closets, or urinals, water use, or decreases the minimum required energy efficiency, 

Comment [fp23]: OIRA requested change.

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of a covered product.” This provision links automatic commercial ice makers to the

energy efficiency anti-backsliding provision as a covered product, and does not include 

automatic commercial ice makers among the products covered by the water efficiency

anti-backsliding provision. Thus, this section of EPCA prohibits DOE from amending 

any standard in such a way as to decrease minimum energy efficiency for any covered

ACIM product.automatic commercial ice maker equipment class. It does not, however,

prohibit an increase in water use in any products other than those enumerated in the 

statute, and nothing in 6313(d)(4) expands the specific list of equipment or appliances to 

which the water anti-backsliding applies. Therefore, an increase in condenser water use 

would not be considered backsliding under the statute. Nevertheless, the proposals do not 

include increases in condenser water use.

Noting that condenser water standards are already in place for batch type ice 

makers, DOE has decided to consider an increase in condenser water use as a design 

option to improve energy efficiency for all water-cooled ice makers. Acknowledging the 

concerns of stakeholders such as AHRI, Manitowoc, and Scotsman, DOE recognizes that 

such an approach must consider the cost-effectiveness of this design option based on the 

end-user’s water cost. DOE does not believe that the contemplated changes would 

diminish product utility, because an increase in the maximum allowed condenser water 

use would increase the flexibility of manufacturers to meet the condenser water use 

standard. Manufacturers would obviously not be required to increase condenser water 

use, especially if such a design decision would negatively impact the energy use or 

harvest rate of their ice makers.

Comment [fp24]: Change requested by OIRA.

Comment [fp25]: Change requested by OIRA.

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In response to Manitowoc’s observation that water velocities must be maintained 

within specified limits in order to avoid erosion, DOE conducted an analysis to determine 

whether current levels of water use in water-cooled condensers are close to exceeding 

these limits. DOE has learned from manufacturers of water-cooled condensers that water 

flow rates generally should not exceed 3.5 gallons per minute per nominal ton of 

condenser cooling capacity (gpm per ton)36. DOE’s analysis of test data for batch 

machines shows that the maximum condenser water flow rate occurs shortly after 

harvest, and that there is some room for increase of condenser water flow rate with the 

3.5 gpm per ton limit. DOE considered some increase of condenser water flow for batch

type units that did not already operate at this limit at the start of the freeze cycle. Unlike 

batch type ice makers, whose condenser loads spike shortly after the harvest cycle, 

continuous type ice makers typically operate in steady-state. DOE’s testing shows that 

flow rates in continuous type ice makers are therefore far from the maximum levels 

recommended to prevent erosion. However, DOE notes that it did not perform direct 

analysis on any water-cooled continuous equipment classes.

As the manufacturers and AHRI point out, DOE must be careful in the analysis of 

condenser water to ensure that the complex relationship between condenser water and 

machine energy usage are modeled correctly. However, balancing energy use and 

condenser water use following the approach outlined above greatly simplifies an 

otherwise highly complex, three-dimensional analysis of design options, condenser water 

36 Personal communication with Piyush Desai at Packless Industries on May 16, 2012

148

 
use levels, and efficiency. This analysis approach helped DOE determine whether 

increasing condenser water limits could cost-effectively save electricity. 

DOE tested three water-cooled ice makers with varying condensing water flow to 

evaluate the potential for energy savings and the cost-effectiveness of using this 

approach. The results of this evaluation for a batch type ice maker are shown in Table 

IV.21Table IV.21. The analysis assumed that in the field half of the ice makers would be 

used in open systems and half in closed-loop systems, which significantly reduce water 

flow, as documented in chapter 5 of the NOPR TSD. 

Table IV.21 Test Data for a Water-Cooled Batch Unit

Condensing Temperature °F 97 107 111

Harvest Capacity

lb/24 hr 375 361 355

Energy Consumption 

kWh/100 lb 4.67 5.13 5.28

LCC Operating Cost 

$/100 lb $1.75 $1.38 $1.32

Condenser Water Use 

gal/100 lb 165.4 106.5 94.1

The analysis shows that increasing condenser water flow is not a cost-effective

way to reduce energy use. This was demonstrated also for the two continuous type ice

makers that were tested. As a result, DOE did not comprehensively evaluate this 

approach for all water-cooled equipment classes in its engineering analysis. Additional 

details are available in chapter 5 of the NOPR TSD.

e. Compressors

Scotsman commented that the high-EER compressors in DOE’s analysis may not 

be feasible for ice makers, particularly batch type ice makers, in which liquid refrigerant 

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can often enter the compressor during the harvest process. Scotsman noted that the design 

changes used by compressor manufacturers to improve EER can reduce reliability, for 

instance placing the compressor suction line closer to the suction intake within the shell, 

which can cause liquid refrigerant to impinge on the suction valve during harvest and 

rapidly lead to compressor failure. (Scotsman, No. 46 at p. 5) Manitowoc echoed 

Scotsman’s second point, indicating that a direct suction compressor would allow liquid 

to enter the compressor cylinder and damage the valve system. (Manitowoc, No. 54 at p. 

2)

In response to these comments, DOE consulted with manufacturers regarding 

which compressors are appropriate for ice makers. DOE removed from its analysis those 

compressors that manufacturers have indicated are unsuitable for use in ice makers. As 

part of the NOPR analyses, DOE also considered additional compressors of compressor 

lines that manufacturers indicated are acceptable. The impact of these changes in the 

analysis on the predicted potential efficiency improvement associated with use of higher

efficiency compressors varied by equipment class. Additional details are available in 

chapter 5 of the NOPR TSD. 

f. Limitations on Available Design Options

Manitowoc commented that the small size of the ice maker industry makes it 

difficult for ice maker manufacturers to implement new technologies or influence the 

component (e.g., compressor or motor) suppliers that they depend on for efficiency gains. 

Manitowoc noted that, compared to other appliance industries, ice maker sales volumes 

150
do not drive component suppliers to make design changes, so ice maker manufacturers 

are limited to those changes that suppliers will implement for larger customers. 

Furthermore, Manitowoc noted that, rather than being independent appliances, ice makers 

are typically part of a larger equipment chain for delivering food service products, which 

places them under physical constraints and causes their technology changes to have 

broader impacts on the entire food delivery industry. (Manitowoc, Public Meeting 

Transcript, No. 42 at pp. 14-15)

For the NOPR analyses, DOE has used design options that are commercially 

available. Many of these technologies are found in ice makers that were inspected, and a 

few are available from component manufacturers. DOE has taken care to ensure that 

those design options identified do apply to these products. 

• For example, DOE has removed from its analysis any compressors that may 

potentially interfere with ice maker operation (based on their design). 

• DOE has also included an option to increase chassis sizes (in order to grow 

internal components such as heat exchangers), but limited chassis growth 

design options to only cover the modest levels suggested by the available 

equipment offerings

Further information on DOE’s analyses is contained in sections IV.D.4.e and 

IV.D.4.f.

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4. Development of the Cost-Efficiency Relationship

In this rulemaking, DOE has adopted a combined efficiency level/design 

option/reverse engineering approach to developing cost-efficiency curves. To support this 

effort, DOE developed manufacturing cost models based heavily on reverse engineering 

of products to develop a baseline MPC. DOE estimated the energy use of different design 

configurations using an energy model whose input data was based on reverse 

engineering, automatic commercial ice maker performance ratings, and test data. DOE 

combined the manufacturing cost and energy modeling to develop cost-efficiency curves 

for automatic commercial ice maker equipment based on baseline-efficiency equipment 

selected to represent their equipment classes. Next, DOE derived manufacturer markups 

using publicly available automatic commercial ice maker industry financial data, in 

conjunction with manufacturer feedback. The markups were used to convert the MPCbased cost-efficiency curves into MSP-based curves. Details of these analyses developed 

for the preliminary analysis were presented in the preliminary analysis TSD and in a 

supplementary data publication posted on the rulemaking website.

Stakeholder comments regarding DOE’s preliminary engineering analyses 

addressed the following broad areas:

1. Estimated costs in many cases were lower than manufacturers’ actual costs.

2. Estimated efficiency benefits of many modeled design options were greater 

than the actual benefits, according to manufacturers’ experience with 

equipment development.

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3. DOE should validate its energy use model based on comparison with actual 

equipment test data.

4. DOE should validate its cost-efficiency analysis by investigating the 

relationship of efficiency with retail prices for ice makers.

5. The incremental costs in the engineering analysis should take into 

consideration the design, development, and testing costs associated with new 

designs.

These topics are addressed in greater detail in the sections below.

a. Manufacturing Cost

Manitowoc requested that DOE provide more information on the inputs and 

methodology behind calculating the MPCs for each efficiency level. (Manitowoc, Public 

Meeting Transcript, No. 42 at pp. 76-77) Manitowoc, Scotsman, and AHRI all asserted 

that it is important for DOE to accurately assess the potential incremental costs associated 

with each efficiency level, since they will drive the decisions in this rulemaking. 

(Manitowoc, Public Meeting Transcript, No. 42 at pp. 170-171 and No. 54 at p. 1; 

Scotsman, Public Meeting Transcript, No. 42 at p. 173; AHRI, No. 49 at p. 6) 

Regarding the accuracy of DOE’s cost model, Manitowoc commented that some 

of the incremental costs between efficiency levels were incorrect. Manitowoc added that, 

while it could not provide its bill of materials, it would be willing to give DOE guidance 

regarding the actual costs of implementing technology design changes at realistic 

153
volumes. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 80-81) Scotsman agreed 

with Manitowoc that the table of incremental costs was optimistic at best and added that 

changing one component in an ice maker will often require also changing other 

components, further affecting incremental costs. (Scotsman, Public Meeting Transcript, 

No. 42 at p. 85)

Specifically, Manitowoc, Scotsman, and AHRI each stated the belief that DOE 

has underestimated the incremental costs of its proposed design options. (Manitowoc, No. 

54 at p. 1; Scotsman, No. 46 at p. 5; AHRI, No. 49 at p. 6) For example, DOE estimated 

that the incremental cost of using an electronically commutated motor (ECM) in place of 

a shaded pole motor would be $13, whereas Scotsman’s supplier quoted an incremental 

cost of $35 for this same design option. Scotsman added that, because the ice maker 

industry is relatively low-volume, ice maker manufacturers face large cost premiums for 

component technologies. (Scotsman, No. 46 at p. 5) AHRI noted that DOE assumed that 

an 8 percent increase in compressor efficiency would cost only $9. However, AHRI 

asserted that most compressors currently used in ice makers are already mechanically 

optimized and could therefore achieve greater efficiency only by switching to permanent 

magnet motors, which would cost seven times more than DOE’s incremental cost 

estimate. AHRI cautioned that DOE should not assume that information it derived for 

other rulemakings is automatically applicable to ice makers. AHRI also opined that DOE 

drastically underestimated the cost of increasing condenser surface area. (AHRI, No. 49 

at p. 2) Finally, Manitowoc commented that DOE’s cost estimates for ECM versions of 

the fan motors and pumps were unrealistically low. (Manitowoc, No. 54 at p. 2)

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In response to Manitowoc’s first comment, DOE has provided additional 

information correlating efficiency levels and design options in this NOPR and its 

accompanying TSD. The TSD details the design option changes and associated costs, 

calculated for each efficiency level for the equipment analyzed.

. In response to the comments by Manitowoc, Scotsman, and AHRI, DOE had 

received very limited feedback from manufacturers regarding cost estimates to support its 

preliminary engineering analysis. During the NOPR phase of this rulemaking, DOE 

emphasized the need to obtain relevant information from stakeholders by extending the 

comment period by 40 days and welcoming comment on specific details presented in the 

TSD regarding technology options and costs. Moreover, DOE’s contractor again worked 

directly with manufacturers under non-disclosure agreements in order to obtain additional 

cost information.

DOE has significantly revised its component cost estimates for the engineering 

analysis for the NOPR phase based on the additional information obtained, both in 

discussions with manufacturers and in stakeholder comments. DOE used the detailed 

feedback that it solicited from manufacturers to update its cost estimates for all ice maker 

components, significantly increasing its estimates of nearly all of these costs. Additional 

details on the adjusted component costs are available in chapter 5 of the NOPR TSD.

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b. Energy Consumption Model

The energy consumption model calculates the energy consumption of automatic 

commercial ice makers in kilowatt-hours per 100 lb of ice based on detailed description 

of equipment design. The DOE analysis for a given equipment class and capacity applied 

the model for a variety of design configurations representing different performance 

levels. The analysis starts with a baseline design, subsequently assessing the differing 

energy consumption for incrementally more-efficient equipment designs that utilize 

increasing numbers of design options. The results of the energy consumption model are 

paired with the cost model results to produce the points on the cost-efficiency curves, 

which correspond to specific equipment configurations. After the publication of the 

preliminary analysis, DOE received numerous stakeholder comments regarding the 

methodology and results of the energy consumption model. 

Manitowoc and Howe both commented that DOE’s models significantly 

overstated the efficiency gains associated with many of the design options. (Howe, No. 

51 at p. 3; Manitowoc, No. 54 at p. 2) As an example, Howe pointed out that using a 

more efficient fan may not have a significant impact on the overall efficiency of the ice 

maker, since the fan represents a small fraction of its overall energy use. (Howe, No. 51 

at p. 3) Manitowoc added that its own tests on actual ice machines under controlled 

conditions resulted in lower performance gains than those predicted by the DOE models. 

(Manitowoc, No. 54 at p. 2) 

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Manitowoc commented that it would like to have more information on the models 

used in DOE’s engineering analysis. In particular, Manitowoc stated that it would like to 

learn more about the FREEZE model, since it is difficult to model the process of freezing 

water into ice and even more difficult to model ice harvesting. Manitowoc noted that this 

model will drive DOE’s estimation of energy efficiency and that it is important for 

manufacturers to understand the impacts of the model before new standards take effect, 

especially if new efficiency levels take manufacturers to technology levels far beyond 

their level of experience. (Manitowoc, Public Meeting Transcript, No. 42 at pp. 171-173)

Manitowoc also commented that the FREEZE model is limited by its inability to 

model the harvest portion of the batch cycle. Manitowoc stated that, although the harvest 

portion is shorter in duration than the freeze portion, it represents a significant fraction of 

energy consumption due to the higher energy input to the compressor and the additional 

energy required to cool the evaporator after each harvest. Manitowoc added that many 

changes that improve the freeze operation efficiency, such as increasing condenser area, 

also reduce harvest operation efficiency. Manitowoc expounded on this example by 

noting that the increased condenser surface area reduces the design temperature of the 

refrigerant, which results in lower energy available during the harvest cycle, which in 

turn results in slower harvest times and an overall increase in energy during the harvest 

cycle. Manitowoc commented that DOE’s FREEZE model is unable to account for such 

behavior. (Manitowoc, No. 54 at pp. 1-2)

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Scotsman and Hoshizaki both commented that the energy model will be 

incomplete until it has been validated with real test results of different technology design 

options. (Scotsman, Public Meeting Transcript, No. 42 at pp. 173-174) Hoshizaki 

asserted that DOE should not use the FREEZE model in the analyses until it has been 

validated. (Hoshizaki, No. 53 at p. 1)

Scotsman inquired whether DOE intends to validate its cost-efficiency model by 

implementing these design changes on actual machines and evaluating their subsequent 

energy performance. (Scotsman, Public Meeting Transcript, No. 42 at pp. 85-86)

In response to comments by Manitowoc, Howe, and Scotsman, DOE has made 

changes to the energy modeling based on feedback received from the manufacturers 

under non-disclosure agreements. To address concerns by Manitowoc that the FREEZE 

model did not adequately model the effects of increased condenser size on the harvesting 

energy, DOE also performed testing of a water-cooled condenser batch unit, and used the 

test data to develop a relationship between condensing temperatures and harvest energy. 

DOE did note that lower condensing temperatures did result in lower overall energy 

consumption, but higher harvest energy consumption.

Table IV.22 Test Data for a Water-Cooled Batch Unit

Test Level Units 1 2 3

Condenser 

Temperature °F 97.36 107.47 111.36

Ice Harvest lb/24 hr 375 361 355

Overall Energy 

Consumption kWh/100 lb 4.67 5.13 5.28

Average Harvest 

Energy 

Consumption

Wh 21.21 17.86 17.03

LCC Operating $/100 lb $1.75 $1.38 $1.32

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Cost

Condenser Water 

Use gal/100 lb 165.4 106.5 94.1

Further information on DOE’s engineering analysis and energy model 

adjustments is contained in sections IV.D.4.e and IV.D.4.f.

c. Retail Cost Review

AHRI and Hoshizaki both questioned the accuracy of DOE’s incremental costefficiency analysis. AHRI and Hoshizaki recommended that DOE validate it by 

comparing its results with actual retail prices. (AHRI, Public Meeting Transcript, No. 42 

at pp. 78-80, 82-83, 174-175, and No. 49 at p. 6; Hoshizaki, Public Meeting Transcript, 

No. 42 at p. 84 and No. 53 at p. 1)

In response to AHRI’s and Hoshizaki’s request for cost validation, DOE prepared 

a price analysis for automatic commercial ice makers to evaluate the correlation of price 

with higher ice maker efficiency. DOE collected list price information from publicly 

available automatic commercial ice maker manufacturer price sheets for 470 ice makers. 

DOE collected other information relevant to the analysis appropriate sources, including 

equipment dimensions, harvest capacity, ENERGY STAR qualification, and energy use. 

For equipment classes for which there were data available for more than 20 ice makers, 

price and ice harvest rate were shown to have a strong linear correlation, with R-squared 

values ranging from 0.63 to 0.84. This result indicates that customers pay more for 

higher-capacity ice makers.

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While an initial evaluation of price trends with efficiency suggested that prices are 

higher for higher efficiency ice makers, subsequent analysis suggests that this trend can 

be attributed to the trend for reduction in energy use for higher harvest capacity and the 

aforementioned relationship between price and harvest capacity. For the equipment 

classes for which there were sufficient ice makers to analyze, DOE determined the bestfit linear relationship predicting price as a function of ice harvest rate. DOE then 

evaluated the relationship between each ice maker’s price differential (i.e., the difference 

between its price and the best-fit linear function), expressed as a percentage of the 

predicted price, with the ice maker’s energy consumption rate (in kWh/100 lb ice), 

developing best-fit linear relationships for these trends. DOE noted that the linear 

relationships showed either no growth or very small growth in price as energy 

consumption increased. These results indicate that there is no correlation between higher 

efficiency and higher retail prices for ice machines. However, DOE did not conclude, 

based on this analysis, that there would be no costs associated with improving equipment 

efficiency—rather, it concluded that retail prices are not a reliable indicator of these 

costs. Additional information on this analysis can be found in chapter 3 of the NOPR 

TSD.

d. Design, Development, and Testing Costs

Hoshizaki commented that DOE’s incremental cost-efficiency analysis must 

include all aspects of design changes, including the additional design time, testing, and 

increased labor, when calculating incremental costs. Hoshizaki added that manufacturers 

could help DOE by reviewing the actual costs associated with redesigning their machines 

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to meet the 2010 DOE energy standards as well as ENERGY STAR standards. Hoshizaki 

expressed its willingness to collaborate with DOE and AHRI. (Hoshizaki, No. 53 at p. 3)

DOE incorporates the cost of additional design time, testing, labor, and tooling 

into its manufacturer impacts analysis, as described in section IV.J. During the NOPR 

analyses, DOE and its contractors contacted manufacturers and obtained related costs 

under non-disclosure agreements. More information on these analyses is available in 

section IV.J.

e. Empirical-Based Analysis

In response to comments from Scotsman and Hoshizaki about the validity of the 

energy model, DOE investigated using an empirical efficiency level approach for the 

engineering analysis rather than the approach combining energy modeling and 

manufacturing cost modeling that was used in the preliminary analysis. DOE performed 

this analysis for eight batch equipment classes and three continuous equipment classes.

The alternative approach was to develop the cost-efficiency curves based on rated or 

tested automatic commercial ice makers energy use levels and costs estimated using the 

manufacturing cost model with updates from manufacturer discussions, as described in 

section IV.D.4.a. To support the empirical analysis, DOE purchased and tested 20 

additional ice makers, giving DOE a total of 39 ice makers for evaluation.

Table IV.23Table IV.23 shows the resulting costs for equipment classes that were 

analyzed using the empirical approach and the energy modeling approach. The 

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incremental cost of reaching a 15 percent below baseline efficiency level is listed below. 

In 7 out of 9 equipment classes, the energy modeling approach result was far more 

conservative (i.e., resulted in higher incremental cost estimates) than the empirical 

approach result; DOE estimated a negative cost-efficiency relationship in five of these 

cases for the empirical approach.

Table IV.23 Comparison of NOPR and Empirical Analysis Approaches at the 15% 

efficiency level

15% EL 

Incremental Cost 

from Empirical

Approach

15% EL Incremental 

Cost from NOPR

(Energy Modeling)

IMH-A-Small-B $ 4.88 $ 45.00 

IMH-A-Large-B $ (32.32) $ 39.00 

IMH-W-Small-B $ (102.62) $ 37.00 

IMH-W-Medium-B $ (543.66) $ 53.00 

RCU-NRC-Small-B $ 4.70 NA*

RCU-NRC-Large-B $ 166.03 $ 198.00 

SCU-A-Large-B $ (106.45) $ 40.00 

SCU-A-Small-B $ 47.41 $ 32.00 

IMH-A-C $ 74.60 $ 46.00 

RCU-NRC-C $ (354.91) NA*

SCU-A-C $ (244.80) $ 28.00 

* The NOPR analysis did not directly analyze this equipment class.

DOE compared the results of the empirical analysis and the results of the energy 

modeling, and concluded that the energy modeling results provided a better and more 

consistent forecast in the ability of manufacturers to reach certain efficiency levels. While 

the analyses rigorously account for the cost differences in key components that affect 

energy use, the costs to achieve higher efficiency levels range from higher than the 

NOPR estimates to very low to negative. DOE is concerned that, while the calculated 

cost differences may accurately reflect actual cost differences between the chosen pairs of 

models, the results may be very dependent on the details associated with the specific 

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model selections, and may vary depending on the units that are selected. DOE’s empirical 

analysis does indicate that the energy modeling approach does not underestimate the costefficiency steps required to reach higher efficiencies. DOE believes that careful 

calibration of the energy model combined with reassessment of the cost model can result 

in accurate cost-efficiency curves.

Thus, DOE decided to proceed with the energy modeling approach as the main 

basis for the engineering analysis. DOE has addressed many of the stakeholder comments 

as it updated the energy modeling analysis. The details of the energy modeling approach 

are described in the next section, section IV.D.4.f.

Additional details and results of the empirical analysis are available in chapter 5 

of the NOPR TSD. DOE believes that the results of the empirical analyses support the 

results of DOE’s design option analysis.

f. Revision of Preliminary Engineering Analysis

After investigation of and rejection of an empirical efficiency level analysis 

approach, DOE instead developed the NOPR engineering analysis by updating the 

preliminary engineering analysis. This included making adjustments to the manufacturing 

cost model as described in section IV.D.4.a. It also included adjustments to energy 

modeling.

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The design options considered in the analysis changed, as the discussion of the 

updated screening analysis details in section IV.C. 

DOE also made several changes to the FREEZE energy model used to estimate 

energy use of different ice maker design configurations. To address the concerns raised 

by Manitowoc and Howe, DOE adjusted its energy models based on input received in 

manufacturers’ public and confidential comments and discussions DOE’s contractor 

conducted under non-disclosure agreements. These changes included:

• adjustment of the compressor coefficients for batch type ice makers;

• using data from tests of ice makers to model the increase of harvest energy as 

condensing temperature decreases for batch type ice makers;

• developing an approach based on test data to determine the condensing

temperature reductions associated with use of larger water-cooled condensers;

• limiting adjustments to the potable water use of batch products to a minimum 

of 20 gallons per 100 lb (or the starting potable water use level, if lower)

• incorporating energy use reduction for drain water heat exchangers used in 

batch equipment.

Finally, for the max-tech design options that extended beyond what was typically 

found in commercially available products (such as permanent magnet motors and drain 

water heat exchangers) that could not be calibrated against existing units, DOE relied on 

testing and literature to properly account for the energy savings of these units.

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For drain water heat exchangers, DOE performed testing of a batch type ice

maker with a commercially available drain water heat exchanger, and used the test results 

to calibrate the energy savings obtained from this technology for each equipment class 

where it was applied.

DOE used motor efficiency ratings discussed in the preliminary analysis and 

verified with stakeholders to scale the motor use of each component using permanent 

magnet motors. During the NOPR analyses, DOE’s energy model was calibrated to 

properly account for the energy consumption of each component, and for energy 

reductions resulting in jumps to PSC technologies. Increases in the efficiency of the 

motor components can then be expressed as reductions in the energy consumption of 

these components.

DOE calibrated the efficiency gains calculated by the energy model against the 

design options and test results gathered during the empirical analysis investigation. DOE 

used this comparison to determine the suite of design options that should be found at the 

appropriate high-efficiency level, and calibrated the results of the energy against the 

inspected results.

For example, DOE inspected a pair of IMH-A-Small-B automatic commercial ice 

makers with measured efficiency levels of 2.2 percent below baseline and 17.5 percent

below baseline, and noted the following changes between units:

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• increases in both the evaporator face area and condenser volume, and an 

increase in the chassis size to accommodate these growths,

• an increase in condenser fan size and a change from an SPM motor to a PSC 

motor, and

• an increase in compressor EER.

In the energy model, DOE separated out each of the different design options and 

considered separately, ordering them in order of cost-efficiency. For this equipment class, 

DOE had the following design options to increase efficiency from baseline to 23.5

percent below baseline, as shown in Table IV.24Table IV.24.

Table IV.24 IMH-A-Small-B Design Options

% Below Baseline Design Option

0.00% Baseline

6.22% Increase compressor EER from 4.86 EER to 5.25 EER

7.71% Increase condenser width (no chassis size increase)

20.52% Increase Evaporator Area (with chassis size increase)

23.51% Switch to PSC Condenser Fan Motor

In some instances, DOE considered slightly different design options, especially 

when DOE’s analysis found that more efficient compressor options were available. For 

example, the maximum compressor EER used in the energy modeling analysis was more 

efficient than the inspected unit compressor EER. This is the reason this suite of design 

options reaches higher efficiencies. DOE did not consider chassis sizes larger than those 

available on the market.

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DOE believes that these changes help ensure that the energy model results 

accurately reflect technology behavior in the market. Further details on the analyses are 

available in chapter 5 of the NOPR TSD.

E. Markups Analysis

DOE applies multipliers called “markups” to the MSP to calculate the customer

purchase price of the analyzed equipment. These markups are in addition to the 

manufacturer markup (discussed in section IV.D.4) and are intended to reflect the cost 

and profit margins associated with the distribution and sales of the equipment between 

the manufacturer and customer. DOE identified three major distribution channels for 

automatic commercial ice makers, and markup values were calculated for each 

distribution channel based on industry financial data. Table IV.25Table IV.25 shows the 

three distribution channels and the percentage of the shipments each is assumed to reflect. 

The overall markup values were then calculated by weighted-averaging the individual 

markups with market share values of the distribution channels. See chapter 6 of the 

NOPR TSD for more details on DOE’s methodology for markups analysis.

Table IV.25 Distribution Channel Market Shares

Analysis Phase

National Account 

Channel:

Manufacturer Direct 

to Customer (1-party)

Wholesaler Channel:

Manufacturer to 

Distributor

to Customer (2-party)

Contractor Channel:

Contractor Purchase 

from

Distributor for 

Installation

(3-party)

Preliminary Analysis 6% 32% 62%

NOPR 0% 38% 62%

In general, DOE has found that markup values vary over a wide range based on 

general economic outlook, manufacturer brand value, inventory levels, manufacturer 

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rebates to distributors based on sales volume, newer versions of the same equipment 

model introduced into the market by the manufacturers, and availability of cheaper or 

more technologically advanced alternatives. Based on market data, DOE divided 

distributor costs into (1) direct cost of equipment sales; (2) labor expenses; (3) occupancy 

expenses; (4) other operating expenses (such as depreciation, advertising, and insurance); 

and (5) profit. DOE assumed that, for higher efficiency equipment only, the “other 

operating costs” and “profit” scale with MSP, while the remaining costs stay constant 

irrespective of equipment efficiency level. Thus, DOE applied a baseline markup through 

which all estimated distribution costs are collected as part of the total baseline equipment 

cost, and the baseline markups were applied as multipliers only to the baseline MSP.

Incremental markups were applied as multipliers only to the MSP increments (of higher 

efficiency equipment compared to baseline) and not to the entire MSP. Taken together 

the two markups are consistent with economic behavior in a competitive market—the 

participants are only able to recover costs and a reasonable profit level.

DOE received a number of comments regarding markups after the publication of 

the preliminary analysis. 

AHRI stated that equipment markups often result in retail prices that are lower 

than what is observed in the market place, and stated that DOE should supplement its 

analysis with a survey or retail sale prices. (AHRI, No. 49 at pp. 4-5) Scotsman 

suggested reviewing equipment pricing on the internet because many ice makers are 

available online. (Scotsman, No. 46 at p. 5) 

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Scotsman stated that the national account chain is not accurate. Scotsman 

commented that the national account distribution chain resembles the wholesaler 

distribution chain, because an equipment supplier is part of the process. The supplier may 

contract directly with the customer but equipment still goes through another party, 

according to Scotsman. (Scotsman, No. 42 at p. 97) Manitowoc agreed with Scotsman 

that the national accounts chain is misrepresented, and actually includes a third party to 

do installation, repair, and maintenance. (Manitowoc, No. 42 at pp. 99-100)

Manitowoc stated that mechanical contractors are typically not part of the 

distribution chain. Manitowoc indicated dealers may in fact provide those services, but 

the model is a little different from the model presented. (Manitowoc, No. 42 at p. 102-3)

Hoshizaki agreed with the analysis of distribution channels. (Hoshizaki, No. 53 at 

p. 2) Manitowoc suggested another distribution channel exists: rather than a sale to an 

end-user, the dealer leases it to the customer. (Manitowoc, No. 42 at p. 98) Manitowoc 

was of the opinion that whether the equipment was sold or leased to the customer, the end 

result would be that the ultimate equipment price would not be affected. (Manitowoc, No. 

42 at p. 99)

Manitowoc questioned the basic methodology of using a base and incremental 

markup. Manitowoc stated that if it changed a product, it would expect the same gross 

margin on the incremental cost as on the base. (Manitowoc, No. 42 at p. 104) Manitowoc 

169
stated that entities in the distribution chain take the manufacturer’s list price and add a 

markup. Manitowoc stated that by using the incremental markup, DOE is understating the 

impact in the market place of adding additional costs to raise the efficiency level, and that 

is not what happens in the market, according to Manitowoc. (Manitowoc, No. 42 at p. 

105) Manitowoc stated that the incremental markup should be the same as the baseline 

markup and that it would be unreasonable to expect that vendors would earn a lower 

margin on additional costs associated with complying by the increased minimum 

efficiency regulations. (Manitowoc, No. 54 at p. 3)

With regard to the AHRI, Scotsman, and Manitowoc comments related to retail 

prices surveys or studies to determine if DOE was underestimating prices, DOE 

performed a market price survey, reported earlier in the engineering section IV.D.4.c.

Previously DOE has not performed retail price surveys, believing that scatter in the 

data—particularly when internet and non-internet prices are co-mingled—would cause 

surveys to provide data of poor value or usefulness. The results of the retail price survey 

performed for the engineering analysis supports this belief.

With regard to the comment that mechanical contractors are typically not part of 

the distribution chain, DOE is using mechanical contractor cost information to model a 

three-party distribution channel. Available Census Bureau data as well as comments 

received at the Framework public meeting indicates that a three-party distribution 

channel is common. At present the mechanical contractor cost data is the best information 

available for quantifying the local contractor portion of the three-party channel, and DOE 

170
used this data for developing costs contained in this notice. DOE requests specific data or 

data sources to better categorize the third party costs attributable to local dealers or 

contractors. 

The Scotsman and Manitowoc comments about the national account chain being 

misrepresented indicate that the national account channel is basically the same as the 

wholesaler channel. Thus, the 6 percent of shipments initially assigned to the national 

account channel will be combined with the wholesaler channel shipments and assessed 

the wholesaler channel markup. With regard to adding another channel for leased 

equipment, since Manitowoc suggested the pricing of equipment in such a hypothetical 

channel would not differ from other equipment, DOE elects to not add an additional 

channel.

With respect to the comments questioning the use of an incremental markup, 

DOE believes that there is likely an inaccurate comparison taking place. In competitive 

markets, such as the automatic commercial ice maker market, the participants are 

expected to be able to recover costs and a reasonable profit, which is what the markups 

designed and used by participants would be expected to do. In the DOE analysis, the 

baseline markup has been calculated to recover all currently existing overhead expenses 

with baseline equipment costs. DOE’s analysis focuses on changes. Profit margin and 

other costs that change as MSP changes were assigned to incremental markups. Most 

overhead costs were allocated to the base markup because DOE does not expect these 

costs to change because of MSP changes brought on by efficiency standards. DOE 

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developed the baseline and incremental markup methodology to ensure all overhead costs 

are fully collected and a reasonable profit margin is received and to identify costs that 

change, and apply such to the incremental MSP in the form of incremental markups.

F. Energy Use Analysis

For the preliminary analysis and for the NOPR, DOE estimated energy usage for 

use in the LCC and NIA models based on the kWh/100 lb ice and gal/100 lb ice values 

developed in the engineering analysis in combination with other assumptions. In the 

preliminary analysis, DOE assumed that ice makers on average are used to produce onehalf of the ice the machines could produce (i.e., a 50 percent capacity factor). DOE also 

assumed that when not making ice, on average ice makers would draw 5 watts of power.

DOE modeled condenser water usage as “open-loop” installations, or installations where 

water is used in the condenser one time (single pass) and released into the wastewater 

system.

Several stakeholders agreed with the 50 percent capacity factor being reasonable.

Scotsman stated that the 50 percent utilization factor is relatively close, given the wide 

spectrum that exists based on seasonality and installation location. (Scotsman, Public 

Meeting Transcript, No. 42 at p. 108) AHRI stated that on average, across all applications 

and seasons, the 50 percent utilization factor assumed by DOE is appropriate. (AHRI, 

No. 49 at p. 5) Manitowoc agreed that 50 percent utilization is a good number to use.

(Manitowoc, Public Meeting Transcript, No. 42 at p. 110) Hoshizaki, on the other hand, 

thought 50 percent was on the low side for the industry, and some business types, like 24-

172
hour restaurants, might have much higher usage factors. (Hoshizaki, Public Meeting 

Transcript, No. 42 at p. 111) NPCC expressed a desire to have information made 

available to determine if there is an equipment class relationship between the duty cycles 

and the business type, and whether duty cycle is related to the equipment class and/or the 

product capacity. NPCC believed that this may determine whether one is more costeffective to pursue than another. (NPCC, Public Meeting Transcript, No. 42 at p. 111)

For the NOPR, DOE has continued to utilize a 50 percent capacity factor, as most 

commenters believed it to be a reasonable number and DOE did not receive utilization 

data in the comments that would lead it to consider alternative capacity factors in the 

analysis. In response to the Hoshizaki comment and in agreement with the NPCC 

comment, DOE requests additional information about reasonable values that could be 

used to vary the assumption by business type.

Several stakeholders commented on the assumption of an open-loop installation 

for water-cooled condensers. Scotsman commented that the majority of ice makers are 

installed in open-loop configurations. Scotsman stated that in some business types like 

hotels or casinos, there will typically be cooling towers and recirculation systems that the 

ice maker can tap into. In smaller locations without that type of a resource, it would 

typically be open loop, according to Scotsman. (Scotsman, Public Meeting Transcript,

No. 42 at pp. 108-109) Scotsman added that single-pass configuration provides a worstcase energy use, and is appropriate for this analysis. (Scotsman, No. 46 at p. 3) 

Manitowoc stated that it only knows of installations in casinos or other large projects 

173
where ice makers are installed on closed loops, and suspects that most historical 

installations are open loop. (Manitowoc, No. 42 at p. 110)

NEEA recommended that DOE investigate the market share of automatic 

commercial ice makers with single-pass condensers, because they use substantially more 

water than those with other condenser configurations. (NEEA, Public Meeting Transcript, 

No, 42 at pp. 165–166) NPCC stated that some jurisdictions do not permit open-loop 

installations because of water usage. (NPCC, Public Meeting Transcript, No. 42 at pp. 

109-110) 

Hoshizaki suggested placing water-cooled units in closed-loop systems. 

(Hoshizaki, No. 42 at p. 110) Hoshizaki stated that, in certain areas, water-cooled 

condensers could be the most effective form of condensing. (Hoshizaki, No. 53 at p. 2)

DOE agrees with Hoshizaki’s comment that water-cooled condensers can be a 

cost-effective form of condensing. DOE does not envision promulgating any rule that 

would eliminate water-cooled condensers. Since DOE’s regulatory authority relates to the 

efficiency of equipment manufactured or sold in the U. S. but not to how equipment is 

installed or used, DOE does not plan to promulgate rules mandating use of closed loops. 

DOE is not proposing to perform the research suggested by NEEA into the prevalence of

open- versus closed-loop installations. It is always DOE’s objective to model energy 

usage as accurately as possible, so DOE requests stakeholder assistance in quantifying 

the impact of local regulations such as any local regulation potentially forbidding an 

174
open-loop installation. Scotsman and Manitowoc stated that, historically, most 

installations were likely open-loop, but the regulations discussed by NPCC would argue 

that in the future such is less likely to be true. DOE’s analyses to date have not included 

design options that would change condenser water usage, a fact that means the question 

of modeling condenser water in the LCC models condenser water usage as open- or 

closed-loop impacts the absolute value of life-cycle costs and total national costs of 

ownership and operation, but not LCC savings or increases/decreases in NPV. Given that 

Scotsman and Manitowoc believe that historically most installations have likely been 

open loop, DOE chose to continue to model water usage as an open-loop (or single-pass) 

system.

G. Life-Cycle Cost and Payback Period Analysis

In response to the requirements of EPCA in (42 U.S.C. 6295(o)(2)(B)(i) and

6313(d)(4)), DOE conducts LCC and PBP analysis to evaluate the economic impacts of 

potential amended energy conservation standards on individual commercial customers—

that is, buyers of the equipment. This section describes the analyses and the spreadsheet 

model DOE used. NOPR TSD chapter 8 details the model and all the inputs to the LCC 

and PBP analyses. 

LCC is defined as the total customer cost over the lifetime of the equipment, and 

consists of installed cost (purchase and installation costs) and operating costs 

175
(maintenance, repair, water,

37 and energy costs). DOE discounts future operating costs to 

the time of purchase and sums them over the expected lifetime of the unit of equipment. 

PBP is defined as the estimated amount of time it takes customers to recover the higher 

installed costs of more-efficient equipment through savings in operating costs. DOE 

calculates the PBP by dividing the increase in installed costs by the savings in annual 

operating costs. DOE measures the changes in LCC and in PBP associated with a given 

energy and water use standard level relative to a base-case forecast of equipment energy 

and water use (or the “baseline energy and water use”). The base-case forecast reflects 

the market in the absence of new or amended energy conservation standards. 

The installed cost of equipment to a customer is the sum of the equipment 

purchase price and installation costs. The purchase price includes MPC, to which a 

manufacturer markup (which is assumed to include at least a first level of outbound 

freight cost) is applied to obtain the MSP. This value is calculated as part of the 

engineering analysis (chapter 5 of the NOPR TSD). DOE then applies additional markups 

to the equipment to account for the costs associated with the distribution channels for the 

particular type of equipment (chapter 6 of the NOPR TSD). Installation costs are varied 

by State depending on the prevailing labor rates. 

Operating costs for automatic commercial ice makers are the sum of maintenance 

costs, repair costs, water, and energy costs. These costs are incurred over the life of the 

37 Water costs are the total of water and wastewater costs. Wastewater utilities tend to not meter customer 

wastewater flows, and base billings on water commodity billings. For this reason, water usage is used as 

the basis for both water and wastewater costs, and the two are aggregated in the LCC and PBP analysis. 

176

 
equipment and therefore are discounted to the base year (2018, which is the proposed 

effective date of the amended standards that will be established as part of this 

rulemaking). The sum of the installed cost and the operating cost, discounted to reflect 

the present value, is termed the life-cycle cost or LCC.

Generally, customers incur higher installed costs when they purchase higher

efficiency equipment, and these cost increments will be partially or wholly offset by 

savings in the operating costs over the lifetime of the equipment. Usually, the savings in 

operating costs are due to savings in energy costs because higher efficiency equipment 

uses less energy over the lifetime of the equipment. Often, the LCC of higher efficiency 

equipment is lower compared to lower-efficiency equipment. 

The PBP of higher efficiency equipment is obtained by dividing the increase in 

the installed cost by the decrease in annual operating cost. For this calculation, DOE uses 

the first-year operating cost decreases as the estimate of the decrease in operating cost, 

noting that some of the repair and maintenance costs used in the analysis are annualized 

estimates of costs. DOE calculates a PBP for each efficiency level of each equipment 

class. In addition to the energy costs (calculated using the electricity price forecast for the 

first year), the first-year operating costs also include annualized maintenance and repair 

costs. 

Apart from MSP, installation costs, and maintenance and repair costs, other 

important inputs for the LCC analysis are markups and sales tax, equipment energy 

177
consumption, electricity prices and future price trends, expected equipment lifetime, and 

discount rates.

As part of the engineering analysis, design option levels were ordered based on 

increasing efficiency (decreased energy and water consumption) and increasing MSP 

values. DOE developed four to seven energy use levels for each equipment class, 

henceforth referred to as “efficiency levels,” through the analysis of engineering design 

options. For all equipment classes, efficiency levels were set at specific intervals—e.g., 

10 percent improvement over base energy usage, 15 percent improvement, 20 percent 

improvement. The max-tech efficiency level is the only exception. At the max-tech level,

the efficiency improvement matched the specific levels identified in the engineering 

analysis.

The base efficiency level (level 1) in each equipment class is the least efficient 

and the least expensive equipment in that class. The higher efficiency levels (level 2 and 

higher) exhibit progressive increases in efficiency and cost with the highest efficiency 

level corresponding to the max-tech level. LCC savings and PBP are calculated for each 

selected efficiency level of each equipment class.

Many inputs for the LCC analysis are estimated from the best available data in the 

market, and in some cases the inputs are generally accepted values within the industry. In 

general, each input value has a range of values associated with it. While single 

representative values for each input may yield an output that is the most probable value 

178
for that output, such an analysis does not give the general range of values that can be 

attributed to a particular output value. Therefore, DOE carried out the LCC analysis in 

the form of Monte Carlo simulations38 in which certain inputs were expressed as a range 

of values and probability distributions that account for the ranges of values that may be 

typically associated with the respective input values. The results or outputs of the LCC 

analysis are presented in the form of mean LCC savings, percentages of customers 

experiencing net savings, net cost and no impact in LCC, and median PBP. For each 

equipment class, 10,000 Monte Carlo simulations were carried out. The simulations were 

conducted using Microsoft Excel and Crystal Ball, a commercially available Excel add-in 

used to carry out Monte Carlo simulations.

LCC savings and PBP are calculated by comparing the installed costs and LCC 

values of standards-case scenarios against those of base-case scenarios. The base-case

scenario is the scenario in which equipment is assumed to be purchased by customers in 

the absence of the proposed energy conservation standards. Standards-case scenarios are 

scenarios in which equipment is assumed to be purchased by customers after the 

amended energy conservation standards, determined as part of the current rulemaking, go 

into effect. The number of standards-case scenarios for an equipment class is equal to one 

less than the total number of efficiency levels in that equipment class because each 

efficiency level above efficiency level 1 represents a potential amended standard. 

38 Monte Carlo simulation is, generally, a computerized mathematical technique that allows for 

computation of the outputs from a mathematical model based on multiple simulations using different input 

values. The input values are varied based on the uncertainties inherent to those inputs. The combination of 

the input values of different inputs is carried out in a random fashion to simulate the different probable 

input combinations. The outputs of the Monte Carlo simulations reflect the various probable outputs that 

are possible due to the uncertainties in the inputs.

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Usually, the equipment available in the market will have a distribution of efficiencies. 

Therefore, for both base-case and standards-case scenarios, in the LCC analysis, DOE 

assumed a distribution of efficiencies in the market, and the distribution was assumed to 

be spread across all efficiency levels in the LCC analysis (see NOPR TSD chapter 10).

Recognizing that different types of businesses and industries that use automatic 

commercial ice makers face different energy prices, and apply different discount rates to 

purchase decisions, DOE analyzed variability and uncertainty in the LCC and PBP results 

by performing the LCC and PBP calculations for seven types of businesses: (1) health 

care; (2) lodging; (3) foodservice; (4) retail; (5) education; (6) food sales; and (7) offices. 

Different types of businesses face different energy prices and also exhibit differing 

discount rates that they apply to purchase decisions.

Expected equipment lifetime is another input for which it is inappropriate to use a 

single value for each equipment class. Therefore, DOE assumed a distribution of 

equipment lifetimes that are defined by Weibull survival functions.39

Equipment lifetime is a key input for the LCC and PBP analysis. For automatic 

commercial ice maker equipment, there is a general consensus among industry 

stakeholders that the typical equipment lifetime is approximately 7 to 10 years with an 

average of 8.5 years. There was no data or comment to suggest that lifetimes are unique 

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to each equipment class. Therefore, DOE assumed a distribution of equipment lifetimes 

that is defined by Weibull40 survival functions, with an average value of 8.5 years. 

Another factor influencing the LCC analysis is the State in which the automatic 

commercial ice maker is installed. Inputs that vary based on this factor include 

installation costs, water and energy prices, and sales tax (plus the associated distribution 

chain markups). At the national level, the spreadsheets explicitly modeled variability in 

the model inputs for water price, electricity price, and markups using probability 

distributions based on the relative populations in all States.

Detailed descriptions of the methodology used for the LCC analysis, along with a 

discussion of inputs and results, are presented in chapter 8 and appendices 8A and 8B of 

the NOPR TSD.

1. Equipment Cost

To calculate customer equipment costs, DOE multiplied the MSPs developed in 

the engineering analysis by the distribution channel markups, described in section IV.E. 

DOE applied baseline markups to baseline MSPs and incremental markups to the MSP 

increments associated with higher efficiency levels.

In the preliminary analysis, DOE developed a projection of price trends for 

automatic commercial ice maker equipment, indicating that based on historical price 

40 Weibull survival function is a continuous probability distribution function that is commonly used to 

approximate the distribution of equipment lifetimes.

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trends the MSP would be projected to decline by 0.4 percent from the 2012 estimation of 

MSP values through the 2018 assumed start date of new or amended standards. The 

preliminary analysis also indicated an approximately 1.6 percent decline from the MSP 

values estimated in 2012 to the end of the 30-year NIA analysis period used in the 

preliminary analysis. Price trends generated considerable discussion during the LCC 

presentation at the February 2012 preliminary analysis public meeting (and nearly all 

comments specific to the NIA were concerning price trends).

Scotsman stated that it typically sees some increase in costs and that it tries to 

recapture at least some of the increased cost in the form of price increases and usually 

cannot recover all of it. Scotsman stated that it does not expect to see prices going down 

over the years and does not think it makes a lot of sense. Scotsman added that for 

household refrigerators and other industries, much of the price decrease that has been 

seen over the years is offshored manufacturing. The automatic commercial ice maker

manufacturers do not have the scale to consider doing that, according to Scotsman. 

(Scotsman, Public Meeting Transcript, No. 42 at p. 127-128) Scotsman analyzed the 

historical shipments data and provided graphs showing how different the forecast would 

be if a different time period was selected. Scotsman suggested that a long-term growth 

trend of 1.5 percent is most realistic. (Scotsman, No. 46 at pp. 6-7)

NRDC stated that price learning is theoretically expected and empirically 

demonstrated, and that it supported DOE’s incorporation of price learning in the 

rulemaking. (NRDC, No. 48 at p. 2)

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AHRI urged DOE to assume that price learning is zero, or in other words, to hold 

MSP constant. AHRI stated that it had performed an analysis of the data used by DOE 

and that it believed that the data did not support an assumption of price learning greater 

than zero. (AHRI, No. 49 at p. 5 and exhibit A)

Manitowoc stated that there is no real basis to expect that the manufacturing costs 

of ice machines will decrease in the future due to efficiency gains in production because 

the ice machine designs are mature and the manufacturing processes are stable. 

Manitowoc added that the increase in costs associated with design options is only due to 

higher cost components or higher cost material employed and that the annual production 

volumes do not allow for further investment in automation of the manufacturing 

processes beyond what is already in place. (Manitowoc, No. 54 at p. 4) 

As is customary between the preliminary analysis and the NOPR phases of a 

rulemaking, DOE re-examined the data available and updated the analyses, in this 

specific instance, the price trend analysis. At a high level, DOE agrees with the NRDC 

comment that evidence indicates price learning is theoretically expected. In response to 

the AHRI, Manitowoc, and Scotsman comments that the data do not support the price 

trends, DOE re-examined the data used in the analysis, and re-analyzed price trends with 

updated data. In the preliminary analysis, DOE used a Producer Price Index (PPI) that 

included air-conditioning, refrigeration, and forced air heating equipment. For the NOPR, 

DOE was able to identify a PPI that was a subset of the PPI used for the preliminary 

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analysis. The subset includes only commercial refrigeration and related equipment, and 

excludes unrelated equipment. Using this PPI for the automatic commercial ice maker

price trends analysis yields a price decline of roughly 1.6 percent over the period of 2012 

(the year for which MSP was estimated) through 2047. 

2. Installation, Maintenance, and Repair Costs

a. Installation Costs

Installation cost includes labor, overhead, and any miscellaneous materials and 

parts needed to install the equipment. The installation costs may vary from one 

equipment class to another, but they typically do not vary among efficiency levels within 

an equipment class. Most automatic commercial ice makers are installed in fairly 

standard configurations. For its preliminary analysis, DOE tentatively concluded that the 

engineering design options do not impact the installation cost within an equipment class. 

DOE therefore assumed that the installation cost for automatic commercial ice makers 

does not vary among efficiency levels within an equipment class. Costs that do not vary 

with efficiency levels do not impact the LCC, PBP, or NIA results. In the preliminary 

analysis, DOE estimated the installation cost as a fixed percentage of the total MSP for 

the baseline efficiency level for a given equipment class, set at 10 percent.

Manitowoc agreed with DOE’s assumption that installation costs generally would 

be unaffected by moving to the higher efficiency level. However, Manitowoc pointed out 

that some efficiency differences may cause variation in installation costs. Manitowoc 

further explained that many remote condensers require a crane for installation; therefore, 

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bigger condensers of automatic commercial ice maker equipment with higher efficiency 

levels might result in higher rental and labor costs associated with the installation. 

(Manitowoc, Public Meeting Transcript, No, 42 at p. 136) In its written comments to 

DOE, Manitowoc further clarified that higher efficiency equipment would not incur 

additional installation costs unless the size of the equipment increases in such a way as to 

exceed the industry norms. (Manitowoc, No 54 at p. 4) However, Hoshizaki indicated 

installation costs will increase with higher levels of energy efficiency due to special 

installation requirements for the new machine and possible changes to the structure that 

might be required. Furthermore, AHRI commented that it is incorrect for DOE to assume 

that changes in installation will be negligible for more-efficient equipment. (AHRI, No. 

49 at p. 5)

Scotsman pointed out that if the technology were assumed to involve a drain 

water heat exchange, the installation costs would increase. (Scotsman, No, 46 at p. 3)

In responses to the comments above, DOE further evaluated the costs associated 

with installation and revised the installation cost estimation methods. For the NOPR, 

DOE estimated material and labor cost to install equipment based on RS Means cost 

estimation data41 and on telephone conservations with contractors. Estimated installation 

costs vary by equipment class and by State. DOE decided to continue to assume 

installation cost will be constant for all efficiency levels within an equipment class.

41 RS Means Company, Inc. 2013 RS Means Electrical Cost Data. 2013. Kingston, MA.

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In response to Manitowoc’s comment that greater equipment size might result in 

higher rental and labor costs, DOE notes that while the initial decision to avoid 

equipment size increases in the engineering analysis was eliminated, DOE attempted to 

minimize equipment size increases. Thus, proposed standard levels should not add 

significantly to labor and crane rental costs. Nor does DOE believe the size increases 

would require structural changes as hypothesized by Hoshizaki. In response to the 

Manitowoc and Scotsman comments about drain water heat exchanger installation costs, 

DOE notes the promotional material of drain water heat exchanger manufacturers 

indicate the units can be installed with four additional water attachments, a level of effort 

that would likely not add to the cost of installations. Finally, in response to Hoshizaki’s 

general statement that higher efficiency levels will impose specialized installation 

requirements, a review of the design options included in the DOE engineering analysis 

did not reveal any options likely to impose specific cost increases. To better respond to 

the Hoshizaki comment, DOE requests specificity—which design options will impose 

increases in installation costs and what would the magnitude of such cost increases be?

b. Repair and Maintenance Costs

The repair cost is the average annual cost to the customer for replacing or 

repairing components in the automatic commercial ice maker that have failed. In the 

preliminary analysis, DOE approximated the repair cost as a 3-percent fixed percentage 

of the total baseline MSP for each equipment class and assumed that repair costs were 

constant within an equipment class for all efficiency levels.

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Maintenance costs are associated with maintaining the proper operation of the 

equipment. The maintenance cost does not include the costs associated with the 

replacement or repair of components that have failed, which are included as repair costs. 

In the preliminary analysis, DOE applied a 3-percent preventative maintenance cost that 

remains constant across all equipment efficiency levels because data were not available to 

indicate how maintenance costs vary with equipment levels. 

Scotsman stated that, in general, whenever new technology is introduced, failure 

rates increase. Scotsman stated that when the failures occur during the warranty period, 

the cost falls on manufacturers. Ice makers stress components in ways that they are not 

stressed in steady-state machines, according to Scotsman, so even with well-known 

technologies it is not known how their failure rates will fare in ice makers. In addition, 

Scotsman commented that if the technology was assumed to involve a drain water heat 

exchanger, the maintenance cost would increase. (Scotsman, No, 46 at pp. 3-4)

Likewise, Hoshizaki stated that repair costs are relative to each machine and that it is

difficult to compute a standard average. Manufacturers are still working to analyze the 

effects of the 2010 standards on repair costs, according to Hoshizaki. (Hoshizaki, No, 46 

at pp. 3-4)

Manitowoc commented that the repair costs will be affected by the efficiency 

levels. Manitowoc stated that is has specific concerns about some components such as 

motors. Manitowoc pointed out that ECM motors might enhance the energy efficiencies, 

but these motors are probably less reliable than standard permanent split capacitor motors 

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because ECM motors have more parts. Manitowoc further stated that, in general, more 

parts increase the chances that a component will fail, which in turn potentially increases 

the repair costs. (Manitowoc, Public Meeting Transcript, No, 42 at p. 136) In addition, 

Scotsman stated that modeling repair cost as a percentage of baseline costs would 

understate repair cost. Also using the example of an ECM fan motor, Scotsman explained 

that ECM motor has an incremental cost of $35 to install; however, when it needs to be 

replaced, it is considerably more costly than the replacement of the motors that are 

currently used on the market. Additionally, Scotsman also noted the ECM fan motor has 

more parts than the current motors that are commonly applied in the market, making it 

likely to fail more often. Therefore, according to Scotsman, ECM fan motors might 

require higher average annual repair costs than current motors used in the baseline units. 

(Scotsman, No, 46 at pp. 3–4) Hoshizaki pointed out higher water and energy efficiency 

level may increase maintenance costs. Hoshizaki elaborated that equipment with lower 

water usage and improved electrical efficiencies might need more frequent maintenance 

such as cleaning. (Hoshizaki, No. 53 at p. 2)

In addition, Howe commented on the impact of new standards on repairing and 

maintenance costs. Howe stated that the modification of new ice makers will cause 

increased repair and maintenance costs due to the need to educate service personnel. The 

percentage of the baseline costs will increase, according to Howe. (Howe, No. 51 at p. 4) 

In response to these comments, DOE evaluated how repair and maintenance costs 

were estimated and revised the methodology. For repair costs, DOE examined the major 

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components of ice makers and identified expected failure rates for each component. For 

those components for which available information indicates a failure might occur within 

the expected 8.5-year equipment life, DOE estimated repair or replacement costs. Under 

this methodology, repair and replacement costs are based on the original equipment costs, 

so the more expensive the components are, the greater the expected repair or replacement 

cost. For design options modeled in the engineering analysis, DOE estimated repair costs 

and if they were different than the baseline cost, the repair costs were either increased or 

decreased accordingly. (Although theoretically possible, in the case of the ice maker 

analysis, repair costs did not decrease with efficiency levels for any equipment class.) 

Thus, consistent with Hoshizaki’s comment about the difficulty of estimating one 

standard average, DOE now estimates different repair and replacement costs for all 

equipment classes.

DOE’s revision to the repair cost methodology is consistent with the Manitowoc, 

Hoshizaki, Scotsman, and Howe comments that repair costs should increase with 

efficiency level. Consistent with the Manitowoc and Scotsman comments, DOE assumed 

that ECM fan motors would increase repair costs relative to the baseline. In response to 

Scotsman’s comments about drain water heat exchangers, DOE notes that manufacturer 

literature indicates an expected useful life greater than 8.5 years, so no replacement was 

assumed for this component.

In the NOPR analyses, DOE estimated material and labor costs for preventative 

maintenance based on RS Means cost estimation data and on telephone conservations 

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with contractors. DOE assumed maintenance cost would remain constant for all 

efficiency levels within an equipment class. In response to Hoshizaki’s comment about 

the impact of reduced water usage on maintenance, the DOE analyses for 7 of 12 primary 

equipment classes did not involve changes to water usage. In the remaining 5 (batch) 

equipment classes, DOE’s analysis did not assume potable water usage would be reduced 

below 20 gallons per 100 lb ice—a level manufacturers indicated was a point below 

which maintenance costs would increase. (Scotsman, Public Meeting Transcript, No. 42 

at p. 64; Manitowoc, Public Meeting Transcript, No. 42 at p. 65) Thus, for the NOPR, 

DOE assumes that maintenance costs will not vary by efficiency level.

3. Annual Energy and Water Consumption 

Chapter 7 of the NOPR TSD details DOE’s analysis of annual energy and water 

usage at various efficiency levels of automatic commercial ice makers. Annual energy 

and water consumption inputs by automatic commercial ice maker equipment class are

based on the engineering analysis estimates of kilowatt-hours of electricity per 100 lb ice 

and gallons of water per 100 lb ice, translated to annual kilowatt-hours and gallons in the 

energy and water use analysis (chapter 7 of the NOPR TSD). The development of energy

and water usage inputs is discussed in section IV.G.6 along with public input and DOE’s 

response to the public input.

4. Energy Prices

DOE calculated average commercial electricity prices using the EIA Form EIA826 data obtained online from the “Database: Sales (consumption), revenue, prices & 

190
customers” web page.42 The EIA data reports average commercial sector retail prices 

calculated as total revenues from commercial sales divided by total commercial energy 

sales in kilowatt-hours, by State and for the nation. DOE received no recommendations 

or suggestions regarding this set of assumptions at the February 2012 preliminary 

analysis public meeting or in written comments.

5. Energy Price Projections

To estimate energy prices in future years for the preliminary analysis TSD, DOE 

multiplied the average regional energy prices described above by the forecast of annual 

average commercial energy price indices developed in the Reference Case from 

AEO2013.

43 AEO2013 forecasted prices through 2040. To estimate the price trends after 

2040, DOE assumed the same average annual rate of change in prices as exhibited by the 

forecast over the 2031 to 2040 period. DOE received no recommendations or suggestions 

regarding this set of assumptions at the February 2012 preliminary analysis public 

meeting or in written comments.

6. Water Prices

To estimate water prices in future years for the preliminary analysis TSD, DOE 

used price data from the 2008,

44 2010,45 and 2012 American Water Works Water

42 U.S. Energy Information Administration. Sales and revenue data by state, monthly back to 1990 (Form 

EIA-826). (Last accessed June 26, 2013). <www.eia.gov/electricity/data.cfm#sales> 43 The spreadsheet tool that DOE used to conduct the LCC and PBP analyses allows users to select price 

forecasts from either AEO’s High Economic Growth or Low Economic Growth Cases. Users can thereby 

estimate the sensitivity of the LCC and PBP results to different energy price forecasts. 44 American Water Works Association. 2008 Water and Wastewater Rate Survey. 2009. Denver, CO. 

Report No. 54004. 

191

 
(AWWA) and Wastewater Surveys.46 The AWWA 2012 survey was the primary data set. 

No data exists to disaggregate water prices for individual business types, so DOE varied 

prices by state only and not by business type within a state. For each state, DOE 

combined all individual utility observations within the state to develop one value for each 

state for water and wastewater service. Since water and wastewater billings are frequently 

tied to the same metered commodity values, DOE combined the prices for water and 

wastewater into one total dollars per 1,000 gallons figure. DOE used the Consumer Price 

Index (CPI) data for water-related consumption (1973–2012) 47 in developing a real 

growth rate for water and wastewater price forecasts.

During the public meeting and in written comments, stakeholders commented on 

the water prices DOE used in its LCC analysis. NPCC stated that water and wastewater 

price escalation has been systematically higher than the CPI. Further, NPCC pointed out 

that EPA’s water-related regulations governed by the Clean Water Act might level out 

the escalation rates once the regulations’ requirements were satisfied, even though NPCC 

does not anticipate the escalation rates will diminish much. Given the impact of EPA’s 

latest water-related regulations was not completed, NPCC then raised the question 

whether DOE should use both a higher escalation rate and CPI in its analysis. NPCC then 

suggested using a higher escalated rate in the analysis for a short-run period until the 

effective date of EPA’s latest water-related regulations and move to the CPI for the 

45 American Water Works Association. 2010 Water and Wastewater Rate Survey. 2011. Denver, CO. 

Report No. 54006. 46 American Water Works Association. 2012 Water and Wastewater Rate Survey. 2013. Denver, CO. 

Report No. 54008. 47 The Bureau of Labor Statistics defines CPI as a measure of the average change over time in the prices 

paid by urban consumers for a market basket of consumer goods and services. For more information see 

www.bls.gov/cpi/home.htm.

192

 
longer term analysis starting with the effective date of EPA’s relevant regulations. 

(NPCC, Public Meeting Transcript, No, 42 at pp. 132–134) In addition, the Alliance 

argued that water use and energy use cannot be compared on a simple price basis because 

of key differences between the two resources. The Alliance stated that, first, energy 

comes from multiple sources and is a commodity whose prices fluctuate based on supply 

and demand. Freshwater, on the other hand, is in limited supply and water prices are 

heavily regulated based on the cost of treatment and delivery, which is less directly 

affected by supply and demand, according to the Alliance. The Alliance further stated 

that when water demand overcomes the readily available fresh water resources in the 

U.S., the alternative water sources will likely require more costly infrastructure and 

operational changes such as desalination to fulfill the demand for fresh water, which is 

also a very energy intensive process. Therefore, the Alliance recommended that DOE 

consider the marginal costs of alternative water sources, such as desalination, in its 

analyses to properly account for all water costs as applied to water-cooled condensers. 

(Alliance, No. 45 at p. 4)

DOE appreciates the comments that EPA water regulations under the Clean Water 

Act may impact the escalation rate of water price used in DOE’s analysis and the

observation about desalination plants being the next source of water available in many 

localities. With respect to the Clean Water Act comment, DOE notes that the Clean 

Water Act has been in existence since 1972. Thus, the water price trends should include 

the impacts of historical costs attributable to the Clean Water Act. Throughout that entire 

period, the CPI for water utility costs grew at an average rate of 1.6 percent faster than 

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the total CPI, perhaps validating the NPCC point. As for capturing the effects of 

unknown future EPA regulations, DOE considers this a speculative effort, and DOE has 

long adhered to a guiding principle that the analyses avoid speculating in this fashion. 

With respect to the comment about desalination and the accompanying suggestion that 

DOE should use marginal water prices, DOE has developed water prices using recent 

water price data, which would include resource costs that underlie the provision of water. 

Looking forward, DOE acknowledges that new water resources brought online in future 

years may differ from those of the past, but DOE has not identified a source that carefully 

and systematically forecasts the impact of future developments of this nature, as the 

AEO2013 does in the case of electricity. Thus, to attempt to project growth rates for 50 

states to capture these resource changes would be speculative. Rather than speculate, ,

DOE has updated the calculation of State-level water prices with the inclusion of the 

2012 AWWA survey48 and additional consumer price index values. 

7. Discount Rates

The discount rate is the rate at which future expenditures are discounted to 

establish their present value. DOE determined the discount rate by estimating the cost of 

capital for purchasers of automatic commercial ice makers. Most purchasers use both 

debt and equity capital to fund investments. Therefore, for most purchasers, the discount 

rate is the weighted average cost of debt and equity financing, or the weighted average

cost of capital (WACC), less the expected inflation.

48 American Water Works Association. 2012 Water and Wastewater Rate Survey. 2013. Denver, CO. 

Report No. 54008.

194

 
To estimate the WACC of automatic commercial ice maker purchasers, DOE used 

a sample of nearly 1,200 companies grouped to be representative of operators of each of 

the commercial business types (health care, lodging, foodservice, retail, education, food 

sales, and offices) drawn from a database of 6,177 U.S. companies presented on the 

Damodaran Online website.49 This database includes most of the publicly-traded 

companies in the United States. The WACC approach for determining discount rates 

accounts for the current tax status of individual firms on an overall corporate basis. DOE 

did not evaluate the marginal effects of increased costs, and, thus, depreciation due to 

more expensive equipment, on the overall tax status. 

DOE used the final sample of companies to represent purchasers of automatic 

commercial ice makers. For each company in the sample, DOE combined companyspecific information from the Damodaran Online website, long-term returns on the 

Standard & Poor’s 500 stock market index from the Damodaran Online website, nominal 

long-term Federal government bond rates, and long-term inflation to estimate a WACC 

for each firm in the sample.

For most educational buildings and a portion of the office buildings and cafeterias 

occupied and/or operated by public schools, universities, and State and local government 

agencies, DOE estimated the cost of capital based on a 40-year geometric mean of an 

49 Damodaran financial data is available at: http://pages.stern.nyu.edu/~adamodar/ (Last accessed January 

31, 2013).

195

 
index of long-term tax-exempt municipal bonds (>20 years).50,51 Federal office space was 

assumed to use the Federal bond rate, derived as the 40-year geometric average of longterm (>10 years) U.S. government securities.52

DOE recognizes that within the business types purchasing automatic commercial 

ice makers there will be small businesses with limited access to capital markets. Such 

businesses tend to be viewed as higher risk by lenders and face higher capital costs as a 

result. To account for this, DOE included an additional risk premium for small 

businesses. The premium, 1.9 percent, was developed from information found on the 

Small Business Administration website.53

Chapter 8 of the TSD provides more information on the derivation of discount 

rates. The average discount rate by business type is shown on Table IV.26.

Table IV.26: Average Discount Rate by Business Type

Business Type Average Discount Rate (real)

Health Care 2.7%

Lodging 6.8%

Foodservice 5.8%

Retail 4.6%

Education 3.0%

Food Sales 5.1%

Office 4.6%

50 Federal Reserve Bank of St. Louis, State and Local Bonds - Bond Buyer Go 20-Bond Municipal Bond

Index. (Last accessed April 6, 2012). Annual data for 1973 – 2011 was available at: 

http://research.stlouisfed.org/fred2/series/MSLB20/downloaddata?cid=32995). 51 Rate for 2012 calculated from monthly data. Data source: U.S. Federal Reserve (Last accessed February 

20, 2013) (Available at: www.federalreserve.gov/releases/h15/data.htm). 52 Rate calculated with 1973–2012 data. Data source: U.S. Federal Reserve (Last accessed February 20, 

2013) (Available at: www.federalreserve.gov/releases/h15/data.htm). 53 Small Business Administration data on loans between $10,000 and $99,000 compared to AAA Corporate 

Rates. <http://www.sba.gov/advocacy/7540/6282> Data last accessed on June 10, 2013.

Comment [fp26]: Change requested by OIRA.

196

 
8. Lifetime 

DOE defines lifetime as the age at which typical automatic commercial ice maker

equipment is retired from service. DOE estimated equipment lifetime based on its 

discussion with industry experts, and concluded a typical lifetime of 8.5 years. AHRI 

agreed with DOE’s proposed average equipment lifetime of 8.5 years. (Alliance, No. 49 

at p. 5) Hoshizaki agreed that 8.5 years is a fair assumption for commercial cube type ice 

makers. However, Hoshizaki stated that continuous type ice makers might have a shorter 

life. (Hoshizaki, No. 53 at p. 2)

For the NOPR analyses, DOE elected to use an 8.5-year average life for all 

equipment classes. With regard to the Hoshizaki statement that continuous type ice

makers might have shorter life spans, DOE requests specific information to assist in 

determining whether continuous and batch type equipment should be analyzed using 

differing assumptions for equipment life. All literature on the subject of ice maker 

lifetimes reviewed by DOE, including comments received during the Framework phase 

of this rulemaking, indicates a 7 to 10 year life, with 8.5 years being a reasonable 

average. DOE therefore is proposing in this NOPR to use 8.5 years as automatic 

commercial ice maker lifetime for DOE’s LCC analysis for covered automatic 

commercial ice maker equipment, but would welcome additional data concerning specific 

differences between equipment classes. 

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9. Compliance Date of Standards

EPCA prescribes that DOE must review and determine whether to amend 

performance-based standards for cube type automatic commercial ice makers by January 

1, 2015. (42 U.S.C. 6313(d)(3)(A)) In addition, EPCA requires that the amended 

standards established in this rulemaking must apply to equipment that is manufactured on 

or after 3 years after the final rule is published in the Federal Register unless DOE 

determines, by rule, that a 3-year period is inadequate, in which case DOE may extend 

the compliance date for that standard by an additional 2 years. (42 U.S.C. 6313(d)(3)(C))

DOE began this rulemaking with the expectation of completing it prior to the January 1, 

2015 required date, and, therefore, assumed during the preliminary analysis that new and 

amended standards would take effect in 2016. However, for the NOPR analyses, based on 

the January 1, 2015 statutory deadline and giving manufacturers 3 years to meet the new 

and amended standards, DOE assumes that the most likely compliance date for the 

standards set by this rulemaking would be January 1, 2018. Therefore, DOE calculated 

the LCC and PBP for automatic commercial ice makers under the assumption that 

compliant equipment would be purchased in 2018, the year when compliance with the 

amended standard is required. DOE requests comments on the January 1, 2018 effective 

date.

10. Base-Case and Standards-Case Efficiency Distributions

To estimate the share of affected customers who would likely be impacted by a 

standard at a particular efficiency level, DOE’s LCC analysis considers the projected 

distribution of efficiencies of equipment that customers purchase under the base case 

198
(that is, the case without new energy efficiency standards). DOE refers to this distribution 

of equipment efficiencies as a base-case efficiency distribution.

DOE’s methodology to estimate market shares of each efficiency level within 

each equipment class is based on an analysis of the automatic commercial ice makers 

currently available for purchase by customers. DOE analyzed all available models, 

calculated the percentage difference between the baseline energy usage embodied in the 

ice maker rulemaking analyses, and organized the available units by the efficiency levels. 

DOE then calculated the percentage of available models falling within each efficiency 

level bin. This efficiency distribution was used in the LCC and other downstream 

analyses as the baseline efficiency distribution.

11. Inputs to Payback Period Analysis

Payback period is the amount of time it takes the customer to recover the higher 

purchase cost of more energy-efficient equipment as a result of lower operating costs. 

Numerically, the PBP is the ratio of the increase in purchase cost to the decrease in 

annual operating expenditures. This type of calculation is known as a “simple” PBP

because it does not take into account changes in operating cost over time (i.e., as a result 

of changing cost of electricity) or the time value of money; that is, the calculation is done 

at an effective discount rate of zero percent. PBPs are expressed in years. PBPs greater 

than the life of the equipment mean that the increased total installed cost of the moreefficient equipment is not recovered in reduced operating costs over the life of the 

equipment, given the conditions specified within the analysis such as electricity prices.

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The inputs to the PBP calculation are the total installed cost to the customer of the 

equipment for each efficiency level and the average annual operating expenditures for 

each efficiency level in the first year. The PBP calculation uses the same inputs as the 

LCC analysis, except that discount rates are not used. 

12. Rebuttable Presumption Payback Period

EPCA (42 U.S.C. 6295(o)(2)(B)(iii) and 6313(d)(4)) established a rebuttable 

presumption that a new or amended standards are economically justified if the Secretary 

finds that the additional cost to the consumer of purchasing a product complying with an 

energy conservation standard level will be less than three times the value of the energy 

savings during the first year that the consumer will receive as a result of the standard, as 

calculated under the applicable test procedure.

While DOE examined the rebuttable presumption criterion, it considered whether 

the standard levels considered are economically justified through a more detailed analysis 

of the economic impacts of these levels pursuant to 42 U.S.C. 6295(o)(2)(B)(iii)

6313(d)(4). The results of this analysis served as the basis for DOE to evaluate the 

economic justification for a potential standard level definitively (thereby supporting or 

rebutting the results of any preliminary determination of economic justification).

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H. National Impact Analysis – National Energy Savings and Net Present Value

The NIA assesses the NES and the NPV of total customer costs and savings that 

would be expected as a result of the amended energy conservation standards. The NES 

and NPV are analyzed at specific efficiency levels (i.e., TSL) for each equipment class of 

automatic commercial ice makers. DOE calculates the NES and NPV based on 

projections of annual equipment shipments, along with the annual energy consumption 

and total installed cost data from the LCC analysis. For the NOPR analysis, DOE 

forecasted the energy savings, operating cost savings, equipment costs, and NPV of 

customer benefits for equipment sold from 2018 through 2047—the year in which the last 

standards-compliant equipment is shipped during the 30-year analysis. 

DOE evaluates the impacts of the amended standards by comparing base-case 

projections with standards-case projections. The base-case projections characterize 

energy use and customer costs for each equipment class in the absence of any amended 

energy conservation standards. DOE compares these base-case projections with 

projections characterizing the market for each equipment class if DOE adopted the 

amended standards at each TSL. For the standards cases, DOE assumed a “roll-up” 

scenario in which equipment at efficiency levels that do not meet the standard level under 

consideration would “roll up” to the efficiency level that just meets the proposed standard 

level, and equipment already being purchased at efficiency levels at or above the 

proposed standard level would remain unaffected. 

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DOE uses a Microsoft Excel spreadsheet model to calculate the energy savings 

and the national customer costs and savings from each TSL. The NOPR TSD and other 

documentation that DOE provides during the rulemaking help explain the models and 

how to use them, and interested parties can review DOE’s analyses by interacting with 

these spreadsheets. The NIA spreadsheet model uses average values as inputs (as 

opposed to probability distributions of key input parameters from a set of possible 

values).

For the current analysis, the NIA used projections of energy prices and 

commercial building starts from the AEO2013 Reference Case. In addition, DOE 

analyzed scenarios that used inputs from the AEO2013 Low Economic Growth and High 

Economic Growth Cases. These cases have lower and higher energy price trends, 

respectively, compared to the Reference Case. NIA results based on these cases are 

presented in chapter 10 of the NOPR TSD.

A detailed description of the procedure to calculate NES and NPV, and inputs for 

this analysis, are provided in chapter 10 of the NOPR TSD. 

1. Shipments

DOE obtained data from AHRI and U.S. Census Bureau’s Current Industrial 

Reports (CIR) to estimate historical shipments for automatic commercial ice makers. 

AHRI provided DOE with automatic commercial ice maker shipment data for 2010 

describing the distribution of shipments by equipment class and by harvest capacity. 

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AHRI’s data to DOE also included a11-year history of total shipments from 2000 to 

2010. Additionally, DOE collected total automatic commercial ice maker shipment data 

for the period of 1973 to 2009 from the CIR. DOE reviewed the total shipments in the 

AHRI and CIR data, and noted that the CIR-reported shipments were consistently higher 

than the AHRI-reported shipments. DOE considered the possibility that these 

discrepancies were associated with net exports. However, the CIR data presented exports 

as a percentage of total production at a high level of industry aggregation, thus making it 

impossible to identify ice maker exports as a percentage of ice maker production. DOE 

requested input to aid in understanding the differences between the AHRI and CIR 

shipments data. DOE identified one source with identifiable export information, the 

North American Association of Food Equipment Manufacturers (NAFEM). NAFEM data 

for two recent calendar years (2007 and 2008) showed approximately 20 percent of total 

ice maker shipments associated with food service equipment as exports. Applying a 20 

percent export factor to the CIR shipments data brought the CIR data into approximate 

agreement with the AHRI data. 

For the preliminary analysis, DOE relied on the CIR shipment values, reduced 20 

percent for exports. Using adjusted CIR data, DOE created a rolling estimate of total 

existing stock by aggregating historical shipments across 8.5-year historical periods. 

DOE used the CIR data to estimate a time series of shipments and total stock for 1994 to 

2006—at the time of the analysis, the last year of data available without significant gaps 

in the data due to disclosure limitations. For each year, using shipments, stock, and the 

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estimated 8.5-year life of the equipment, DOE estimated that, on average, 14 percent of 

shipments were for new installations and the remainder for replacement of existing stock.

DOE then combined the historical shipments, disaggregated between shipments 

for new installations and those for replacement of existing stock, and the historical stock 

values with projections of new construction activity from AEO2011 to generate a forecast 

of shipments. Stock and shipments were first disaggregated to individual business types 

based on data developed for DOE on commercial ice maker stocks.54 The business types 

and share of stock represented by each type are shown in Table IV.27Table IV.26. Using 

a Weibull distribution assuming equipment has an average life of 8.5 years and lasts from 

5 to 11 years, DOE developed a 30-year series of replacement ice maker shipments. 

Using the base shipments to new equipment, and year-to-year changes in new 

commercial sector floor space additions from AEO2011, DOE estimated shipments for 

new construction. (For the NOPR, DOE is using AEO2013 projections of floor space 

additions. The AEO2013 floor space additions by building type are shown in Table 

IV.28Table IV.27.) The combination of the replacement and new construction shipments 

yields total shipments. The final step was to distribute total sales to equipment classes by 

multiplying the total shipments by percentage shares by class. Table IV.29Table IV.28

shows the percentages represented by all equipment classes, both the primary classes 

modeled explicitly in all NOPR analyses as well as the secondary classes.

Table IV.27 Business Types Included in Shipments Analysis

Building Type Building Type as Percent

of Stock

54 Navigant Consulting, Inc. Energy Savings Potential and R&D Opportunities for Commercial 

Refrigeration. Final Report, submitted to the U.S. Department of Energy. September 23, 2009. Page 41.

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Health Care 9%

Lodging 33%

Foodservice 22%

Retail 8%

Education 7%

Food Sales 16%

Office 4%

Total 100%

Table IV.28 AEO2013 Forecast of New Building Square Footage

Year

New Construction

million ft2

Health 

Care Lodging Foodservice Retail Education Food Sales Office

2013 66 147 30 276 247 21 173

2018 67 164 50 424 208 35 409

2020 65 178 48 407 197 33 452

2025 63 181 48 442 169 33 392

2030 71 150 54 508 191 38 273

2035 73 207 56 522 228 39 412

2040 76 190 56 562 252 39 405

Annual 

Growth 

Factor, 

2031-

2040

2.4% 2.5% 2.4% 2.5% 1.7% 2.3% 2.1%

Table IV.29 Percent of Shipped Units of Automatic Commercial Ice Makers

Equipment Class Percentage of 

Shipments

IMH-W-Small-B 4.54%

IMH-W-Med-B 2.90%

IMH-W-Large-B 0.48%

IMH-A-Small-B 27.08%

IMH-A-Large-B 16.14%

RCU-Small-B 5.43%

RCU-RC/NC-Large-B 6.08%

SCU-W-Small-B 0.68%

SCU-W-Large-B 0.22%

SCU-A-Small-B 13.85%

SCU-A-Large-B 6.56%

IMH-W-Small-C 0.68%

IMH-W-Large-C 0.17%

IMH-A-Small-C 3.53%

IMH-A-Large-C 1.07%

RCU-Small-C 0.83%

RCU-Large-C 0.87%

SCU-W-Small-C 0.15%

SCU-W-Large-C 0.00%

SCU-A-Small-C 8.75%

SCU-A-Large-C 0.00%

Total 100.00%

Source: AHRI, 2010 Shipments data submitted 

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to DOE as part of this rulemaking.

Comments related to shipment analysis received during the February 2012 

preliminary analysis public meeting are listed below along with DOE’s responses to the 

comments. 

AHRI, in response to DOE's question about inconsistencies between AHRI and 

CIR data, indicated it has found discrepancies and that these discrepancies relate to the 

way manufacturers report to the Census Bureau. AHRI stated that some residential ice 

makers may be lumped into the Census Bureau data. AHRI stated that it is confident in 

its data and would trust it as compared to the Census Bureau data. (AHRI, Public 

Meeting Transcript, No. 42 at p. 155) AHRI commented that it believes the historical 

shipments numbers it provided to DOE are more consistent in terms of product 

definitions and other factors than the Census Bureau shipments. (AHRI, No. 49 at p. 6) In 

response to a question by NPCC, Manitowoc indicated that while the automatic 

commercial ice makers market was still a little below historical levels, it was recovered 

from 2009. Manitowoc stated the product mix calculated by DOE is a “pretty good”

snapshot, but there are shifts over time between batch and continuous types. (Manitowoc, 

Public Meeting Transcript, No. 42 at p. 147) Howe recommended using the Census 

Bureau shipments data because it is more encompassing. (Howe, No. 51 at p. 4) 

Hoshizaki stated AHRI shipment data could be skewed by models not sold in AHRI 

model class or manufacturers that do not participate with AHRI, but more information is 

needed to evaluate this issue. (Hoshizaki, No. 53 at p. 2) 

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In response to AHRI’s comments about the known consistency of the AHRI data 

versus the less-well-known consistency of the Census Bureau data, DOE elected to use 

the AHRI historical data for the DOE Reference Case projections. As noted by Howe and 

Hoshizaki, the Census Bureau data could reflect broader coverage of all manufacturers. 

Thus, DOE configured the NIA model such that consistent scenarios can be modeled with 

either AHRI or Census Bureau data. With respect to the Manitowoc comments, DOE 

appreciates that the product mix represents a good snapshot. With respect to changing the 

mix, DOE requests additional data concerning trends, in the absence of which, DOE will 

by necessity hold the product mix static in the forecast.

2. Forecasted Efficiency in the Base Case and Standards Cases

The method for estimating the market share distribution of efficiency levels is 

presented in section IV.G.10, and a detailed description can be found in chapter 10 of the 

NOPR TSD. To estimate efficiency trends in the standards cases, DOE uses a “roll-up” 

scenario in its standards rulemakings. Under the roll-up scenario, DOE assumes that 

equipment efficiencies in the base case that do not meet the standard level under 

consideration would “roll up” to the efficiency level that just meets the proposed standard 

level and equipment already being purchased at efficiencies at or above the standard level 

under consideration would be unaffected. Table IV.30Table IV.29 shows the shipmentweighted market shares by efficiency level in the base-case scenario.

Table IV.30 Shipment-Weighted Market Shares by Efficiency Level, Base Case

Equipment Class Market Share by Efficiency Level

Level 1 Level 2 Level 3 Level 4 Level 5 Level 6 Level 7

IMH-W-Small-B 39.1% 26.1% 23.9% 10.9% 0.0% 0.0%

IMH-W-Med-B 69.0% 16.7% 11.9% 0.0% 2.4%

IMH-W-Large-B 

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 IMH-W-Large-B-1 71.4% 0.0% 4.8% 23.8%

 IMH-W-Large-B-2 33.3% 50.0% 0.0% 16.7%

IMH-A-Small-B 37.0% 31.5% 25.9% 5.6% 0.0% 0.0% 0.0%

IMH-A-Large-B 

 IMH-A-Large-B-1 41.5% 43.9% 7.3% 7.3% 0.0% 0.0%

 IMH-A-Large-B-2 33.3% 26.7% 26.7% 13.3%

RCU-Large-B 

 RCU-Large-B-1 42.9% 39.3% 8.9% 0.0% 8.9%

 RCU-Large-B-2 27.3% 45.5% 9.1% 0.0% 18.2%

SCU-W-Large-B 28.6% 0.0% 14.3% 0.0% 42.9% 0.0% 14.3%

SCU-A-Small-B 17.1% 40.0% 5.7% 11.4% 14.3% 11.4% 0.0%

SCU-A-Large-B 28.6% 35.7% 0.0% 7.1% 21.4% 7.1% 0.0%

IMH-A-Small-C 22.9% 22.9% 14.3% 8.6% 17.1% 2.9% 11.4%

IMH-A-Large-C 35.0% 20.0% 15.0% 15.0% 0.0% 5.0% 10.0%

SCU-A-Small-C 26.7% 20.0% 16.7% 13.3% 3.3% 20.0%

3. National Energy Savings

For each year in the forecast period, DOE calculates the NES for each TSL by 

multiplying the stock of equipment affected by the energy conservation standards by the 

estimated per-unit annual energy savings. DOE typically considers the impact of a 

rebound effect, introduced in the energy use analysis, in its calculation of NES for a 

given product. A rebound effect occurs when users operate higher efficiency equipment 

more frequently and/or for longer durations, thus offsetting estimated energy savings. 

When a rebound effect occurs, it is generally because the users of the equipment perceive 

it as less costly to use the equipment and elect to use it more intensively. In the case of 

automatic commercial ice makers, users of the equipment include restaurant wait staff, 

hotel guests, cafeteria patrons, or hospital staff using ice in the treatment of patients. 

Users of automatic commercial ice makers tend to have no perception of the cost of the 

ice, and rather are using the ice to serve a specific need. Given this, DOE believes there is 

no potential for a rebound effect. For the preliminary analysis, DOE used a rebound 

factor of 1, or no effect, for automatic commercial ice makers.

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Inputs to the calculation of NES are annual unit energy consumption, shipments, 

equipment stock, and a site-to-source conversion factor.

The annual unit energy consumption is the site energy consumed by an automatic 

commercial ice maker unit in a given year. Using the efficiency of units at each 

efficiency level and the baseline efficiency distribution, DOE determined annual 

forecasted shipment-weighted average equipment efficiencies that, in turn, enabled 

determination of shipment-weighted annual energy consumption values.

The automatic commercial ice makers stock in a given year is the total number of 

automatic commercial ice makers shipped from earlier years (up to 12 years earlier) that 

remain in use in that year. The NES spreadsheet model keeps track of the total units 

shipped each year. For purposes of the NES and NPV analyses in the NOPR analysis, 

DOE assumed that, based on an 8.5-year average equipment lifetimes, approximately 12 

percent of the existing automatic commercial ice makers are retired and replaced in each 

year. DOE assumes that, for units shipped in 2047, any units still remaining at the end of 

2055 will be replaced. 

DOE uses a multiplicative factor called “site-to-source conversion factor” to 

convert site energy consumption (at the commercial building) into primary or source 

energy consumption (the energy at the energy generation site required to convert and 

deliver the site energy). These site-to-source conversion factors account for the energy 

used at power plants to generate electricity and losses in transmission and distribution, as 

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well as for natural gas losses from pipeline leakage and energy used for pumping. For 

electricity, the conversion factors vary over time due to projected changes in generation 

sources (that is, the power plant types projected to provide electricity to the country). The 

factors that DOE developed are marginal values, which represent the response of the 

system to an incremental decrease in consumption associated with amended energy 

conservation standards.

In the preliminary analysis, DOE used annual site-to-source conversion factors 

based on the version of the National Energy Modeling System (NEMS) that corresponds 

to AEO2008.

55 For today’s NOPR, DOE updated its conversion factors based on the U.S. 

energy sector modeling using the NEMS Building Technologies (NEMS-BT) version that 

corresponds to AEO2013 and which provides national energy forecasts through 2040. 

Within the results of NEMS-BT model runs performed by DOE, a site-to-source ratio for 

commercial refrigeration was developed and. The site-to-source ratio was extended to 

cover the period frombeyond 2040 –2060by using growth rates calculated at 5-year 

intervals to extrapolate the trend to 2045, after which it was held constant through

2060.the end of the analysis period (30-years plus the life of equipment).

DOE has historically presented NES in terms of primary energy savings. In 

response to the recommendations of a committee on “Point-of-Use and Full-Fuel-Cycle 

Measurement Approaches to Energy Efficiency Standards” appointed by the National 

55 In the past for preliminary analysis estimates, DOE typically did not perform analyses using NEMS. 

Rather, DOE relied on existing estimates considered appropriate for the analysis. The site-to-source values 

DOE considered most appropriate were those used in the prior 2009 commercial refrigeration equipment 

rulemaking final rule.

Comment [fp27]: Change requested by OIRA.

210

 
Academy of Science, DOE announced its intention to use full-fuel-cycle (FFC) measures 

of energy use and greenhouse gas and other emissions in the national impact analyses and 

emissions analyses included in future energy conservation standards rulemakings. 76 FR 

51281 (August 18, 2011) While DOE stated in that notice that it intended to use the 

Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) 

model to conduct the analysis, it also said it would review alternative methods, including 

the use of NEMS. After evaluating both models and the approaches discussed in the 

August 18, 2011 notice, DOE published a statement of amended policy in the Federal 

Register in which DOE explained its determination that NEMS is a more appropriate tool 

for its FFC analysis and its intention to use NEMS for that purpose. 77 FR 49701 

(August 17, 2012). DOE received one comment, which was supportive of the use of 

NEMS for DOE’s FFC analysis.56 

The approach used for today’s NOPR, and the FFC multipliers that were applied 

are described in appendix 10D of the NOPR TSD. NES results are presented in both 

primary and in terms of FFC savings; the savings by TSL are summarized in terms of 

FFC savings in section V.B.3.

4. Net Present Value of Customer Benefit

The inputs for determining the NPV of the total costs and benefits experienced by 

customers of the automatic commercial ice makers are: (1) total annual installed cost; (2) 

56 Docket ID: EERE-2010-BT-NOA-0028, comment by Kirk Lundblade.

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total annual savings in operating costs; and (3) a discount factor. DOE calculated net 

national savings for each year as the difference in installation and operating costs 

between the base-case scenario and standards-case scenarios. DOE calculated operating 

cost savings over the life of each piece of equipment shipped in the forecast period. 

DOE multiplied monetary values in future years by the discount factor to 

determine the present value of costs and savings. DOE estimated national impacts with 

both a 3-percent and a 7-percent real discount rate as the average real rate of return on 

private investment in the U.S. economy. These discount rates are used in accordance with 

the Office of Management and Budget (OMB) guidance to Federal agencies on the 

development of regulatory analysis (OMB Circular A-4, September 17, 2003), and 

section E, “Identifying and Measuring Benefits and Costs,” therein. DOE defined the 

present year as 2013 for the NOPR analysis. The 7-percent real value is an estimate of the 

average before-tax rate of return to private capital in the U.S. economy. The 3-percent 

real value represents the “societal rate of time preference,” which is the rate at which 

society discounts future consumption flows to their present. 

As discussed in IV.G.1, DOE included a projection of price trends in the 

preliminary analysis NIA. For the NOPR, DOE reviewed and updated the analysis with 

the result that the projected reference case downward trend in prices is quite modest. For 

the NOPR, DOE also developed high and low case price trend projections, as discussed 

in a NOPR TSD appendix to chapter 10.

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I. Customer Subgroup Analysis

In analyzing the potential impact of new or amended standards on commercial 

customers, DOE evaluates the impact on identifiable groups (i.e., subgroups) of 

customers, such as different types of businesses that may be disproportionately affected. 

Based on the data available to DOE, automatic commercial ice maker ownership in three 

building types represent over 70 percent of the market: food sales, foodservice, and 

hotels. Based on data from the 2007 U.S. Economic Census and size standards set by the 

U.S. Small Business Administration (SBA), DOE determined that a majority of food

sales, foodservice and lodging firms fall under the definition of small businesses. Small 

businesses typically face a higher cost of capital. In general, the lower the cost of 

electricity and higher the cost of capital, the more likely it is that an entity would be 

disadvantaged by the requirement to purchase higher efficiency equipment. Chapter 8 of 

the NOPR TSD presents the electricity price by business type and discount rates by 

building types, respectively, while chapter 11 discusses these topics as they specifically 

relate to small businesses. 

Comparing the foodservice, food sales, and lodging categories, foodservice faces

the highest energy price, with food sales and lodging facing lower and nearly the same 

energy prices. Lodging faces the highest cost of capital. Foodservice faces a higher cost 

of capital than food sales. Given the cost of capital disparity, lodging was selected for 

LCC subgroup analysis. With foodservice facing a higher cost of capital, it was selected 

for subgroup analysis because the higher cost of capital should lead foodservice 

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customers to value first cost more and future electricity savings less than would be the 

case for food sales customers.

At the February 2012 preliminary analysis public meeting, DOE asked for input 

on the LCC subgroup analysis, and in particular, about appropriate groups for analysis. 

Manitowoc recommended that DOE look at small businesses, such as franchise 

operations and independent proprietor-run establishments. Manitowoc added that while 

there are institutional sectors with longer windows, there are others – “mom and pops” –

that represent a large part of the market and which may be unfairly impacted by new 

standards because of their short payback windows and cash constraints. Manitowoc also 

indicated it is not just restaurants, it is hotels operated by franchisees and in some cases 

even hotel chains. (Manitowoc, Public Meeting Transcript, No. 42 at p. 169)

DOE estimated the impact on the identified customer subgroups using the LCC 

spreadsheet model. The standard LCC and PBP analyses (described in section IV.G) 

include various types of businesses that use automatic commercial ice makers. For the 

LCC subgroup analysis, it was assumed that the subgroups analyzed do not have access 

to national purchasing accounts or two major capital markets thereby making the discount 

rates higher for these subgroups. Details of the data used for LCC subgroup analysis and 

results are presented in chapter 11 of the NOPR TSD.

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J. Manufacturer Impact Analysis

1. Overview

DOE performed an MIA to estimate the impacts of amended energy conservation 

standards on manufacturers of automatic commercial ice makers. The MIA has both 

quantitative and qualitative aspects and includes analyses of forecasted industry cash 

flows, the INPV, investments in research and development (R&D) and manufacturing 

capital, and domestic manufacturing employment. Additionally, the MIA seeks to 

determine how amended energy conservation standards might affect manufacturing 

employment, capacity, and competition, as well as how standards contribute to overall 

regulatory burden. Finally, the MIA serves to identify any disproportionate impacts on 

manufacturer subgroups, in particular, small businesses. 

The quantitative part of the MIA primarily relies on the Government Regulatory 

Impact Model (GRIM), an industry cash flow model with inputs specific to this 

rulemaking. The key GRIM inputs include data on the industry cost structure, unit 

production costs, product shipments, manufacturer markups, and investments in R&D 

and manufacturing capital required to produce compliant products. The key GRIM 

outputs are the INPV, which is the sum of industry annual cash flows over the analysis 

period, discounted using the industry weighted average cost of capital, and the impact to 

domestic manufacturing employment. The model estimates the impacts of more-stringent 

energy conservation standards on a given industry by comparing changes in INPV and 

domestic manufacturing employment between a base case and the various TSLs in the 

standards case. To capture the uncertainty relating to manufacturer pricing strategy 

215
following amended standards, the GRIM estimates a range of possible impacts under 

different markup scenarios.

The qualitative part of the MIA addresses manufacturer characteristics and market 

trends. Specifically, the MIA considers such factors as manufacturing capacity, 

competition within the industry, the cumulative impact of other DOE and non-DOE 

regulations, and impacts on small business manufacturers. The complete MIA is outlined 

in chapter 12 of the NOPR TSD.

DOE conducted the MIA for this rulemaking in three phases. In Phase 1 of the 

MIA, DOE prepared a profile of the automatic commercial ice maker industry. This 

included a top-down cost analysis of automatic commercial ice maker manufacturers that 

DOE used to derive preliminary financial inputs for the GRIM (e.g., revenues; materials, 

labor, overhead, and depreciation expenses; selling, general, and administrative expenses 

(SG&A); and R&D expenses). DOE also used public sources of information to further 

calibrate its initial characterization of the automatic commercial ice maker industry, 

including company Securities and Exchange Commission (SEC) 10-K filings, corporate 

annual reports, the U.S. Census Bureau’s Economic Census, and reports from Dunn &

Bradstreet.

In Phase 2 of the MIA, DOE prepared a framework industry cash flow analysis to 

quantify the impacts of new and amended energy conservation standards. The GRIM uses 

several factors to determine a series of annual cash flows starting with the announcement 

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of the standard and extending over a 30-year period following the effective date of the 

standard. These factors include annual expected revenues, costs of sales, SG&A and 

R&D expenses, taxes, and capital expenditures. In general, energy conservation standards 

can affect manufacturer cash flow in three distinct ways: (1) create a need for increased 

investment; (2) raise production costs per unit; and (3) alter revenue due to higher perunit prices and changes in sales volumes. 

In addition, during Phase 2, DOE developed interview guides to distribute to 

manufacturers of automatic commercial ice makers in order to develop other key GRIM 

inputs, including product and capital conversion costs, and to gather additional 

information on the anticipated effects of energy conservation standards on revenues, 

direct employment, capital assets, industry competitiveness, and subgroup impacts.

In Phase 3 of the MIA, DOE conducted structured, detailed interviews with a 

representative cross-section of manufacturers. During these interviews, DOE discussed 

engineering, manufacturing, procurement, and financial topics to validate assumptions 

used in the GRIM and to identify key issues or concerns. See section IV.J.4 for a 

description of the key issues raised by manufacturers during the interviews. As part of 

Phase 3, DOE also evaluated subgroups of manufacturers that may be disproportionately 

impacted by amended standards or that may not be accurately represented by the average 

cost assumptions used to develop the industry cash flow analysis. Such manufacturer 

subgroups may include small manufacturers, low volume manufacturers, niche players, 

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and/or manufacturers exhibiting a cost structure that largely differs from the industry 

average.

DOE identified one subgroup, small manufacturers, for which average cost 

assumptions may not hold. DOE applied the small business size standards published by 

the SBA to determine whether a company is considered a small business. 65 FR 30840, 

May 15, 2000, as amended at 67 FR 52602, Aug. 13, 2002; 74 FR 46313, Sept. 9, 2009. 

To be categorized as a small business under North American Industry Classification 

System (NAICS) 333415, “Air-Conditioning and Warm Air Heating Equipment and 

Commercial and Industrial Refrigeration Equipment Manufacturing,” which includes

commercial ice maker manufacturing, a manufacturer and its affiliates may employ a 

maximum of 750 employees. The 750-employee threshold includes all employees in a 

business’s parent company and any other subsidiaries. Based on this classification, DOE 

identified seven manufacturers of automatic commercial ice makers that qualify as small 

businesses. The automatic commercial ice maker small manufacturer subgroup is 

discussed in chapter 12 of the NOPR TSD and in section VI.B.1 of this rulemaking.

2. Government Regulatory Impact Model 

DOE uses the GRIM to quantify the changes in industry cash flows resulting from 

new or amended energy conservation standards. The GRIM uses manufacturer costs, 

markups, shipments, and industry financial information to arrive at a series of base-case 

annual cash flows absent new or amended standards, beginning with the present year, 

2013, and continuing through 2047. The GRIM then models changes in costs, 

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investments, shipments, and manufacturer margins that may result from new or amended 

energy conservation standards and compares these results against those in the base-case 

forecast of annual cash flows. The primary quantitative output of the GRIM is the INPV, 

which DOE calculates by summing the stream of annual discounted cash flows over the 

full analysis period. For manufacturers of automatic commercial ice makers, DOE used a 

real discount rate of 9.2 percent, the weighted average cost of capital as derived from 

industry financials. DOE then modified this figure based on feedback received during 

confidential interviews with manufacturers. 

The GRIM calculates cash flows using standard accounting principles and 

compares changes in INPV between the base case and the various TSLs. The difference 

in INPV between the base case and a standards case represents the financial impact of the 

amended standard on manufacturers at that particular TSL. As discussed previously, 

DOE collected the necessary information to develop key GRIM inputs from a number of 

sources, including publicly available data and interviews with manufacturers (described 

in the next section). The GRIM results are shown in section V.B.2.a. Additional details 

about the GRIM can be found in chapter 12 of the NOPR TSD.

a. Government Regulatory Impact Model Key Inputs

Manufacturer Production Costs

Manufacturing a higher efficiency product is typically more expensive than 

manufacturing a baseline product due to the use of more complex and typically more 

costly components. The changes in the MPCs of the analyzed products can affect the 

219
revenues, gross margins, and cash flow of the industry, making product cost data key 

GRIM inputs for DOE’s analysis.

For each efficiency level of each equipment class that was directly analyzed, DOE 

used the MPCs developed in the engineering analysis, as described in section IV.A.2 and

further detailed in chapter 5 of the NOPR TSD. For equipment classes that were 

indirectly analyzed, DOE used a composite of MPCs from similar equipment classes, 

substitute component costs, and design options to develop an MPC for each efficiency 

level. For equipment classes that had multiple units analyzed, DOE used a weighted 

average MPC based on the relative shipments of products at each efficiency level as the 

input for the GRIM. Additionally, DOE used information from its teardown analysis, 

described in section IV.D, to disaggregate the MPCs into material and labor costs. These 

cost breakdowns and equipment markups were validated with manufacturers during 

manufacturer interviews.

Base-Case Shipments Forecast

The GRIM estimates manufacturer revenues based on total unit shipment 

forecasts and the distribution of shipments by efficiency level. Changes in sales volumes 

and efficiency mix over time can significantly affect manufacturer finances. For this 

analysis, the GRIM uses the NIA’s annual shipment forecasts derived from the shipments 

analysis from 2013, the base year, to 2047, the end of the analysis period. See chapter 9 

of the NOPR TSD for additional details.

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Product and Capital Conversion Costs

Amended energy conservation standards will cause manufacturers to incur 

conversion costs to bring their production facilities and product designs into compliance. 

For the MIA, DOE classified these conversion costs into two major groups: (1) product 

conversion costs and (2) capital conversion costs. Product conversion costs include 

investments in research, development, testing, marketing, and other non-capitalized costs 

necessary to make product designs comply with new or amended energy conservation 

standards. Capital conversion costs include investments in property, plant, and equipment 

necessary to adapt or change existing production facilities such that new product designs 

can be fabricated and assembled. 

Stranded Assets

If new or amended energy conservation standards require investment in new 

manufacturing capital, there also exists the possibility that they will render existing 

manufacturing capital obsolete. In the case that this obsolete manufacturing capital is not 

fully depreciated at the time new or amended standards go into effect, this would result in 

the stranding of these assets, and would necessitate the write-down of their residual undepreciated value.

DOE used multiple sources of data to evaluate the level of product and capital 

conversion costs and stranded assets manufacturers would likely face to comply with new 

or amended energy conservation standards. DOE used manufacturer interviews to gather 

data on the level of investment anticipated at each proposed efficiency level and validated 

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these assumptions using estimates of capital requirements derived from the product 

teardown analysis and engineering model described in section IV.D. These estimates 

were then aggregated and scaled using information gained from industry product 

databases to derive total industry estimates of product and capital conversion costs and to 

protect confidential information. 

In general, DOE assumes that all conversion-related investments occur between 

the year the final rule is published and the year by which manufacturers must comply 

with the new or amended standards. The investment figures used in the GRIM can be 

found in section V.B.2.a of this notice. For additional information on the estimated 

product conversion and capital conversion costs, see chapter 12 of the NOPR TSD.

b. Government Regulatory Impact Model Scenarios

Markup Scenarios

As discussed in section IV.D, MSPs include direct manufacturing production 

costs (i.e., labor, material, overhead, and depreciation estimated in DOE’s MPCs) and all 

non-production costs (i.e., SG&A, R&D, and interest), along with profit. To calculate the 

MSPs in the GRIM, DOE applied manufacturer markups to the MPCs estimated in the 

engineering analysis. Modifying these markups in the standards case yields different sets 

of impacts on manufacturers. For the MIA, DOE modeled two standards-case markup 

scenarios to represent the uncertainty regarding the potential impacts on prices and 

profitability for manufacturers following the implementation of amended energy 

conservation standards: (1) a preservation of gross margin percentage markup scenario; 

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and (2) a preservation of earnings before interest and taxes (EBIT) markup scenario. 

These scenarios lead to different markups values that, when applied to the MPCs, result 

in varying revenue and cash flow impacts. 

Under the preservation of gross margin percentage scenario, DOE applied a 

single, uniform “gross margin percentage” markup across all efficiency levels. As 

production costs increase with efficiency, this scenario implies that the absolute dollar 

markup will increase as well. Based on publicly available financial information for 

manufacturers of automatic commercial ice makers and comments from manufacturer 

interviews, DOE assumed the industry average markup on production costs to be 1.25. 

Because this markup scenario assumes that manufacturers would be able to maintain their 

gross margin percentage as production costs increase in response to an amended energy 

conservation standard, it represents a lower bound of industry impacts (higher industry 

profitability) under an amended energy conservation standard.

In the preservation of EBIT markup scenario, manufacturer markups are 

calibrated so that EBIT in the year after the compliance date of the amended energy 

conservation standard is the same as in the base case. Under this scenario, as the cost of 

production goes up, manufacturers are generally required to reduce the markups on their 

minimally compliant products to maintain a cost competitive offering. The implicit 

assumption behind this scenario is that the industry can only maintain EBIT in absolute 

dollars after compliance with the amended standard is required. Therefore, operating 

margin (as a percentage) shrinks in the standards cases. This markup scenario represents 

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an upper bound of industry impacts (lower profitability) under an amended energy 

conservation standard.

3. Discussion of Comments

In response to the February 2012 preliminary analysis public meeting, interested 

parties commented on the assumptions and results of the preliminary analysis TSD. Oral 

and written comments addressed several topics, including the impact to suppliers and the 

distribution channel, the importance of the ENERGYSTAR program, cumulative 

regulatory burden, and the impact to small manufacturers.

a. Impact to Suppliers, Distributors, Dealers, and Contractors 

AHRI commented that DOE must perform analyses to assess the impact of the 

rule on component suppliers, distributors, dealers, and contractors. Where the MIA serves 

to assess the impact of amended energy conservation standards on manufacturers of 

automatic commercial ice makers; any impact on distributors, dealers, and contractors 

falls outside the scope of this analysis.

Impacts on component suppliers might arise if manufacturers switched to moreefficient components, or if there was a substantial reduction of orders following new or 

amended standards. In public comments, manufacturers expressed that given their low 

production volumes, the automatic commercial ice maker manufacturing industry has 

little influence over component suppliers relative to other commercial refrigeration 

equipment industries. It follows that energy conservation standards for automatic 

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commercial ice makers would have little impact on component suppliers given their 

marginal contribution to overall commercial refrigeration component demand.

b. ENERGY STAR

Manitowoc commented that it is a very strong supporter of ENERGY STAR and 

that certification is very important to its customers because of the potential for utility 

rebates, Leadership in Energy and Environmental Design (LEED) certification, and other 

reasons. Manitowoc expressed concern that, if efficiency standards were raised to the 

max-tech level, there would be no more room for an ENERGY STAR category, which 

would be disruptive to the industry.

DOE acknowledges the importance of the ENERGY STAR program and of 

understanding its interaction with energy efficiency standards. However, EPCA requires 

DOE to establish energy conservation standards at the maximum level that is technically 

feasible and economically justified. DOE has found, over time, with other products, as 

the standard level is increased, manufacturers’ research results in energy efficiency 

improvements that are regarded by the ENERGY STAR program. As such, any standard 

level below the max-tech level continues to leave room for ENERGY STAR rebate 

programs.

c. Cumulative Regulatory Burden

AHRI commented on the cumulative regulatory burden associated with DOE 

efficiency standards. AHRI indicated that several legislative and regulatory activities 

225
should be considered, including legislation intended to reduce lead in drinking water and 

climate change bills that may be considered by Congress. (AHRI, No. 49 at p. 4)

DOE takes into account the cumulative cost of multiple Federal regulations on 

manufacturers in the cumulative regulatory burden section of its analysis, which can be 

found in section V.B.2.e of this notice. DOE does not analyze the quantitative impacts of 

standards that have not yet been finalized. Similarly, DOE does not analyze the impacts 

of potential climate change bills because any impacts would be speculative in the absence 

of final legislation. 

AHRI noted that California has regulations to limit GHGs and the measures 

established by the California Air Resources Board (CARB) to reduce global warming 

will reduce the use of refrigerants such as HFCs. CARB is currently limiting the in-State 

use of refrigerants considered to have high global warming potential (GWP) in nonresidential refrigeration systems through its Refrigerant Management Program that 

became effective on January 1, 2011.57 According to this new regulation, facilities with 

refrigeration systems that have a refrigerant capacity exceeding 50 lb must repair leaks 

within 14 days of detection, maintain on-site records of all leak repairs, and keep receipts 

of all refrigerant purchases. The regulation applies to any person or company that installs, 

services, or disposes of appliances with high-GWP refrigerants. Refrigeration systems 

with a refrigerant capacity exceeding 50 lb typically belong to food retail operations with 

remote condensing racks that store refrigerant serving multiple commercial refrigeration 

See www.arb.ca.gov/cc/reftrack/reftrackrule.html.

226

 
and ice-making units within a business. However, automatic commercial ice makers in 

food retail establishments are usually installed and serviced by refrigeration contractors, 

not manufacturers. As a result, although these CARB regulations apply to refrigeration 

technicians and owners of facilities with refrigeration systems, they are unlikely to 

represent a regulatory burden for manufacturers of automatic commercial ice makers.

The discussion of cumulative regulatory burden on manufacturers of automatic 

commercial ice makers is detailed further in chapter 12 of the NOPR TSD.

d. Small Manufacturers

Howe observed that most high-capacity ice makers are made by small 

manufacturers, and consequently, setting higher efficiency standards for high-capacity 

equipment may be discriminatory against small manufacturers. (Howe, No. 51 at p. 2)

DOE agrees that amended standards may have disproportionate impacts on 

smaller manufacturers. To make this determination, the DOE conducts an analysis of 

impacts on certain manufacturer subgroups including small businesses to assess if any 

impacts prove to be disproportionate. The results of this analysis are described further in 

section VI.B of this notice and detailed in chapter 12 of the NOPR TSD.

4. Manufacturer Interviews

To inform the MIA, DOE interviewed manufacturers with an estimated combined 

market share of 95 percent. The information gathered during these interviews enabled 

227
DOE to tailor the GRIM to reflect the unique financial characteristics of the automatic 

commercial ice maker industry. These confidential interviews provided information that 

DOE used to evaluate the impacts of amended energy conservation standards on 

manufacturer cash flows, manufacturing capacities, and employment levels.

During the manufacturer interviews, DOE asked manufacturers to describe their 

major concerns about this rulemaking. The following sections describe the most 

significant issues identified by manufacturers. DOE also includes additional concerns in 

chapter 12 of the NOPR TSD.

a. Price Sensitivity

All manufacturers interviewed characterized the market for automatic commercial 

ice makers as extremely price sensitive. They hold the position that new and amended 

standards will result in decreased profit margins as they will be unable to pass through 

costs relating to standards compliance. They noted that this will be particularly 

troublesome for lower capacity equipment classes (Small SCU and Small IMH), which 

are sold primarily to smaller restaurants and food service establishments with limited 

access to capital. Additionally, they noted that distributors tend to be individual 

proprietors or small franchises with limited opportunities to extend financing to their 

customers. Manufacturers went on to report that while energy efficiency is important, it is 

not a feature for which customers would pay a premium. 

228
One manufacturer also noted that replacement parts represented 70 percent of 

sales, and while sales of parts had increased since 2009, unit sales had decreased, 

indicating that customers were holding onto units longer. The ability to extend the life of 

a unit through repairs and refurbishment presents a further economic challenge to 

manufacturers facing energy efficiency standards.

b. Enforcement

Manufacturers characterized the automatic commercial ice maker market as a 

niche market with a high degree of competition. The recent entrance of foreign 

manufacturers has led to a further tightening of price competition due to the lower labor 

costs of these foreign manufacturers. Several domestic manufacturers expressed concern 

about the enforcement of an amended energy efficiency standard for automatic 

commercial ice makers produced overseas. Manufacturers believe that insufficient 

enforcement will lead to market distortions, as companies that make the necessary 

investments to meet amended standards would be at a distinct pricing disadvantage to 

unscrupulous competitors, often times foreign manufacturers, that do not fully comply. 

The manufacturers requested that DOE take the enforcement action necessary to maintain 

a level playing field and to eliminate non-compliant products from the market.

c. Reliability Impacts

Some manufacturers expressed concerns that future energy conservation standards 

would have an adverse impact on the reliability of their products. One manufacturer 

stated that any time new components or designs are introduced, that there is an increase 

229
in service calls and the mean time between failures drops as they work out the issues. 

This manufacturer went on to emphasize that reliability is the most important feature of 

their products.

d. Impact on Innovation 

Several manufacturers expressed concerns over the imbalance of internal 

engineering resources brought about by the regular revision and introduction of energy 

conservation standards. As energy use has become increasingly regulated, manufacturers 

have had to shift engineering and support resources away from other initiatives, adversely 

affecting product innovation outside of energy efficiency. One manufacturer reported that 

a previous round of standards required nearly all of the company’s engineering resources 

for between 1 and 2 years. Where the R&D effort required for compliance is intermittent, 

innovation is impacted without adding to overall employment. DOE requests additional 

comment on the intermittency of R&D efforts directed at compliance with energy 

conservation standards and its impact on other research and development resources.

K. Emissions Analysis

In the emissions analysis, DOE estimates the reduction in power sector emissions 

of CO2, NOx, SO2, and Hg from potential energy conservation standards for automatic 

commercial ice makers. In addition, DOE estimates emissions impacts in production 

activities (extracting, processing, and transporting fuels) that provide the energy inputs to 

power plants. These are referred to as “upstream” emissions. Together, these emissions 

account for the full-fuel-cycle (FFC). In accordance with DOE’s FFC Statement of Policy 

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(76 FR 51282 (Aug. 18, 2011)), as amended at 77 FR 49701 (Aug. 17, 2012), the FFC 

analysis includes impacts on emissions of methane (CH4) and nitrous oxide (N2O), both 

of which are recognized as GHGs. 

DOE conducted the emissions analysis using emissions factors that were derived 

from data in AEO2013, supplemented by data from other sources. DOE developed 

separate emissions factors for power sector emissions and upstream emissions. The 

method that DOE used to derive emissions factors is described in chapter 13 of the 

NOPR TSD.

The emissions intensity factors are expressed in terms of physical units per MWh 

or MMBtu of site energy savings. For CH4 and N2O, DOE also presents results in terms 

of units of carbon dioxide equivalent (CO2eq). Gases are converted to CO2eq by 

multiplying the physical units by the gas' global warming potential (GWP) over a 100 

year time horizon. Based on the Fourth Assessment Report of the Intergovernmental 

Panel on Climate Change, DOE used GWP values of 25 for CH4 and 298 for N2O.

EIA prepares the AEO using NEMS. Each annual version of NEMS incorporates 

the projected impacts of existing air quality regulations on emissions. AEO2013

generally represents current legislation and environmental regulations, including recent 

government actions, for which implementing regulations were available as of December 

31, 2012.

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SO2 emissions from affected electric generating units (EGUs) are subject to 

nationwide and regional emissions cap-and-trade programs. Title IV of the Clean Air Act 

sets an annual emissions cap on SO2 for affected EGUs in the 48 contiguous States and 

the District of Columbia (D.C.). SO2 emissions from 28 eastern States and D.C. were also 

limited under the Clean Air Interstate Rule (CAIR; 70 FR 25162 (May 12, 2005)), which 

created an allowance-based trading program that operates along with the Title IV 

program. CAIR was remanded to U.S. Environmental Protection Agency (EPA) by the 

U.S. Court of Appeals for the District of Columbia Circuit but it remained in effect. See 

North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA, 531 

F.3d 896 (D.C. Cir. 2008). On July 6, 2011 EPA issued a replacement for CAIR, the 

Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). On August 21, 

2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME Homer City 

Generation, LP v. EPA, 696 F.3d 7, 38 (D.C. Cir. 2012). The court ordered EPA to 

continue administering CAIR. The AEO2013 emissions factors used for today’s NOPR 

assume that CAIR remains a binding regulation through 2040. 

The attainment of emissions caps is typically flexible among EGUs and is 

enforced through the use of emissions allowances and tradable permits. Under existing 

EPA regulations, any excess SO2 emissions allowances resulting from the lower 

electricity demand caused by the adoption of an efficiency standard could be used to 

permit offsetting increases in SO2 emissions by any regulated EGU. In past rulemakings, 

DOE recognized that there was uncertainty about the effects of efficiency standards on 

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SO2 emissions covered by the existing cap-and-trade system, but it concluded that 

negligible reductions in power sector SO2 emissions would occur as a result of standards.

Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury 

and Air Toxics Standards (MATS) for power plants. 77 FR 9304 (Feb. 16, 2012). In the 

final MATS rule, EPA established a standard for hydrogen chloride as a surrogate for 

acid gas hazardous air pollutants (HAP), and also established a standard for SO2 (a nonHAP acid gas) as an alternative equivalent surrogate standard for acid gas HAP. The 

same controls are used to reduce HAP and non-HAP acid gas; thus, SO2 emissions will 

be reduced as a result of the control technologies installed on coal-fired power plants to 

comply with the MATS requirements for acid gas. AEO2013 assumes that, in order to 

continue operating, coal plants must have either flue gas desulfurization or dry sorbent 

injection systems installed by 2015. Both technologies, which are used to reduce acid gas 

emissions, also reduce SO2 emissions. Under the MATS, NEMS shows a reduction in 

SO2 emissions when electricity demand decreases (e.g., as a result of energy efficiency 

standards). Emissions will be far below the cap established by CAIR, so it is unlikely that 

excess SO2 emissions allowances resulting from the lower electricity demand would be 

needed or used to permit offsetting increases in SO2 emissions by any regulated EGU. 

Therefore, DOE believes that efficiency standards will reduce SO2 emissions in 2015 and 

beyond.

CAIR established a cap on NOx emissions in 28 eastern States and the District of 

Columbia. Energy conservation standards are expected to have little effect on NOx

233
emissions in those States covered by CAIR because excess NOx emissions allowances 

resulting from the lower electricity demand could be used to permit offsetting increases 

in NOx emissions. However, standards would be expected to reduce NOx emissions in the 

States not affected by the caps, so DOE estimated NOx emissions reductions from the 

standards considered in today’s NOPR for these States.

The MATS limit mercury emissions from power plants, but they do not include 

emissions caps and, as such, DOE’s energy conservation standards would likely reduce 

Hg emissions. DOE estimated mercury emissions reduction using emissions factors based 

on AEO2013, which incorporates the MATS.

L. Monetizing Carbon Dioxide and Other Emissions Impacts

As part of the development of this proposed rule, DOE considered the estimated 

monetary benefits from the reduced emissions of CO2 and NOx that are expected to result 

from each of the TSLs considered. In order to make this calculation similar to the 

calculation of the NPV of consumer benefit, DOE considered the reduced emissions 

expected to result over the lifetime of equipment shipped in the forecast period for each 

TSL. This section summarizes the basis for the monetary values used for each of these 

emissions and presents the values considered in this rulemaking.

For today’s NOPR, DOE is relying on a set of values for the social cost of carbon

(SCC) that was developed by an interagency process. A summary of the basis for these 

234
values is provided below, and a more detailed description of the methodologies used is 

provided as an appendix to chapter 14 of the TSD.

1. Social Cost of Carbon

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of carbon dioxide. A domestic SCC value is meant to 

reflect the value of damages in the United States resulting from a unit change in carbon 

dioxide emissions, while a global SCC value is meant to reflect the value of damages 

worldwide.

Under section 1(b) of Executive Order 12866, agencies must, to the extent 

permitted by law, “assess both the costs and the benefits of the intended regulation and, 

recognizing that some costs and benefits are difficult to quantify, propose or adopt a 

regulation only upon a reasoned determination that the benefits of the intended regulation 

justify its costs.” The purpose of the SCC estimates presented here is to allow agencies to 

incorporate the monetized social benefits of reducing CO2 emissions into cost-benefit 

analyses of regulatory actions that have small, or “marginal,” impacts on cumulative 

global emissions. The estimates are presented with an acknowledgement of the many 

uncertainties involved and with a clear understanding that they should be updated over 

time to reflect increasing knowledge of the science and economics of climate impacts.

235
As part of the interagency process that developed these SCC estimates, technical 

experts from numerous agencies met on a regular basis to consider public comments, 

explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values 

using a defensible set of input assumptions grounded in the existing scientific and 

economic literatures. In this way, key uncertainties and model differences transparently 

and consistently inform the range of SCC estimates used in the rulemaking process.

a. Monetizing Carbon Dioxide Emissions

When attempting to assess the incremental economic impacts of carbon dioxide 

(CO2) emissions, the analyst faces a number of serious challenges. A report from the 

National Research Council58 points out that any assessment will suffer from uncertainty, 

speculation, and lack of information about (1) future emissions of greenhouse gases, (2) 

the effects of past and future emissions on the climate system, (3) the impact of changes 

in climate on the physical and biological environment, and (4) the translation of these 

environmental impacts into economic damages. As a result, any effort to quantify and 

monetize the harms associated with climate change will raise serious questions of 

science, economics, and ethics and should be viewed as provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates 

can be useful in estimating the social benefits of reducing carbon dioxide emissions. Most 

58 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and 

Use. National Academies Press: Washington, DC (2009).

236

 
Federal regulatory actions can be expected to have marginal impacts on global emissions. 

For such policies, the agency can estimate the benefits from reduced (or costs from 

increased) emissions in any future year by multiplying the change in emissions in that 

year by the SCC value appropriate for that year. The net present value of the benefits can 

then be calculated by multiplying each of these future benefits by an appropriate discount 

factor and summing across all affected years. This approach assumes that the marginal 

damages from increased emissions are constant for small departures from the baseline 

emissions path, an approximation that is reasonable for policies that have effects on 

emissions that are small relative to cumulative global carbon dioxide emissions. For 

policies that have a large (non-marginal) impact on global cumulative emissions, there is 

a separate question of whether the SCC is an appropriate tool for calculating the benefits 

of reduced emissions. This concern is not applicable to this notice, however.

It is important to emphasize that the interagency process is committed to updating 

these estimates as the science and economic understanding of climate change and its 

impacts on society improves over time. In the meantime, the interagency group will 

continue to explore the issues raised by this analysis and consider public comments as 

part of the ongoing interagency process.

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

Economic analyses for Federal regulations have used a wide range of values to 

estimate the benefits associated with reducing carbon dioxide emissions. The model year 

2011 Corporate Average Fuel Economy final rule, the U.S. Department of Transportation 

237
(DOT) used both a “domestic” SCC value of $2 per metric ton of CO2 and a “global” 

SCC value of $33 per metric ton of CO2 for 2007 emission reductions (in 2007$), 

increasing both values at 2.4 percent per year. DOT also included a sensitivity analysis at 

$80 per metric ton of CO2.

59 A 2008 regulation proposed by DOT assumed a domestic 

SCC value of $7 per metric ton of CO2 (in 2006$) for 2011 emission reductions (with a 

range of $0-$14 for sensitivity analysis), also increasing at 2.4 percent per year.60 A 

regulation for packaged terminal air conditioners and packaged terminal heat pumps 

finalized by DOE in 2008 used a domestic SCC range of $0 to $20 per metric ton CO2 for 

2007 emission reductions (in 2007$). 73 FR 58772, 58814 (Oct. 7, 2008) In addition, 

EPA’s 2008 Advance Notice of Proposed Rulemaking on Regulating Greenhouse Gas 

Emissions Under the Clean Air Act identified what it described as “very preliminary” 

SCC estimates subject to revision. 73 FR 44354 (July 30, 2008). EPA’s global mean 

values were $68 and $40 per metric ton CO2 for discount rates of approximately 2 

percent and 3 percent, respectively (in 2006$ for 2007 emissions).

In 2009, an interagency process was initiated to offer a preliminary assessment of 

how best to quantify the benefits from reducing carbon dioxide emissions. To ensure 

consistency in how benefits are evaluated across agencies, the Administration sought to 

develop a transparent and defensible method, specifically designed for the rulemaking 

59 See Average Fuel Economy Standards Passenger Cars and Light Trucks Model Year 2011, 74 FR 14196 

(March 30, 2009) (Final Rule); Final Environmental Impact Statement Corporate Average Fuel Economy 

Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-90 (Oct. 2008) (Available at: 

http://www.nhtsa.gov/fuel-economy). 60 See Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015, 73 

FR 24352 (May 2, 2008) (Proposed Rule); Draft Environmental Impact Statement Corporate Average Fuel 

Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-58 (June 2008) 

(Available at: http://www.nhtsa.gov/fuel-economy)

238

 
process, to quantify avoided climate change damages from reduced CO2 emissions. The 

interagency group did not undertake any original analysis. Instead, it combined SCC 

estimates from the existing literature to use as interim values until a more comprehensive 

analysis could be conducted. The outcome of the preliminary assessment by the 

interagency group was a set of five interim values: global SCC estimates for 2007 (in 

2006$) of $55, $33, $19, $10, and $5 per metric ton of CO2. These interim values 

represented the first sustained interagency effort within the U.S. government to develop 

an SCC for use in regulatory analysis. The results of this preliminary effort were 

presented in several proposed and final rules.

c. Current Approach and Key Assumptions

Since the release of the interim values, the interagency group reconvened on a 

regular basis to generate improved SCC estimates. Specifically, the group considered 

public comments and further explored the technical literature in relevant fields. The 

interagency group relied on three integrated assessment models commonly used to 

estimate the SCC: the FUND, DICE, and PAGE models. These models are frequently 

cited in the peer-reviewed literature, and were used in the last assessment of the 

Intergovernmental Panel on Climate Change. Each model was given equal weight in the 

SCC values that were developed. 

Each model takes a slightly different approach to model how changes in 

emissions result in changes in economic damages. A key objective of the interagency 

process was to enable a consistent exploration of the three models while respecting the 

239
different approaches to quantifying damages taken by the key modelers in the field. An 

extensive review of the literature was conducted to select three sets of input parameters 

for these models: climate sensitivity, socio-economic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input 

into all three models. In addition, the interagency group used a range of scenarios for the 

socio-economic parameters and a range of values for the discount rate. All other model 

features were left unchanged, relying on the model developers’ best estimates and 

judgments.

The interagency group selected four sets of SCC values for use in regulatory 

analyses. Three sets of values are based on the average SCC from the three integrated 

assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which 

represents the 95th percentile SCC estimate across all three models at a 3-percent discount 

rate, is included to represent higher-than-expected impacts from temperature change 

further out in the tails of the SCC distribution. The values grow in real terms over time.

Additionally, the interagency group determined that a range of values from 7 percent to 

23 percent should be used to adjust the global SCC to calculate domestic effects, 

although preference is given to consideration of the global benefits of reducing CO2

emissions. Table IV.31Table IV.30 presents the values in the 2010 interagency group 

report,61 which is reproduced in appendix 14-A of the NOPR TSD.

61 Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United States Government, February 2010. 

<www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.>

240

 
Table IV.31 Annual SCC Values from 2010 Interagency Report, 2010–2050 (2007

dollars per metric ton)

Discount Rate

(%)

5 3 2.5 3

Average Average Average 95th

percentile

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

The SCC values used for today’s notice were generated using the most recent versions of 

the three integrated assessment models that have been published in the peer-reviewed 

literature.62 Table IV.32Table IV.31 shows the updated sets of SCC estimates in five year 

increments from 2010 to 2050. The full set of annual SCC estimates between 2010 and 

2050 is reported in appendix 14-B of the NOPR TSD. The central value that emerges is 

the average SCC across models at the 3 percent discount rate. However, for purposes of 

capturing the uncertainties involved in regulatory impact analysis, the interagency group 

emphasizes the importance of including all four sets of SCC values.

62 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 

12866. Interagency Working Group on Social Cost of Carbon, United States Government. May 2013; 

revised November 2013. <http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technicalupdate-social-cost-of-carbon-for-regulator-impact-analysis.pdf>

241

 
Table IV.32 Annual SCC Values from 2013 Interagency Update, 2010–2050 (2007 

dollars per metric ton CO2)

Year

Discount Rate 

(%)

5 3 2.5 3

Average Average Average 95th Percentile

2010 11 32 51 89

2015 11 37 57 109

2020 12 43 64 128

2025 14 47 69 143

2030 16 52 75 159

2035 19 56 80 175

2040 21 61 86 191

2045 24 66 92 206

2050 26 71 97 220

It is important to recognize that a number of key uncertainties remain, and that 

current SCC estimates should be treated as provisional and revisable since they will 

evolve with improved scientific and economic understanding. The interagency group also 

recognizes that the existing models are imperfect and incomplete. The National Research 

Council report mentioned above points out that there is tension between the goal of 

producing quantified estimates of the economic damages from an incremental ton of 

carbon and the limits of existing efforts to model these effects. There are a number of 

concerns and problems that should be addressed by the research community, including 

research programs housed in many of the Federal agencies participating in the 

interagency process to estimate the SCC. The interagency group intends to periodically 

review and reconsider those estimates to reflect increasing knowledge of the science and 

economics of climate impacts, as well as improvements in modeling.

In summary, in considering the potential global benefits resulting from reduced 

CO2 emissions, DOE used the values from the 2013 interagency report adjusted to 2012$ 

using the Gross Domestic Product (GDP) price deflator. For each of the four case of SCC 

242
values, the values for emissions in 2015 were $11.8, $39.7, $61.2, and $117.0 per metric 

ton avoided (values expressed in 2012$). DOE derived values after 2050 using the 

relevant growth rates for the 2040-2050 period in the interagency update.

DOE multiplied the CO2 emissions reduction estimated for each year by the SCC 

value for that year in each of the four cases. To calculate a present value of the stream of 

monetary values, DOE discounted the values in each of the four cases using the specific 

discount rate that had been used to obtain the SCC values in each case.

2. Valuation of Other Emissions Reductions

As noted above, DOE has taken into account how new or amended energy 

conservation standards would reduce NOX emissions in those 22 States not affected by 

emission caps. DOE estimated the monetized value of NOX emissions reductions 

resulting from each of the TSLs considered for today’s NOPR based on estimates found 

in the relevant scientific literature. Estimates of monetary value for reducing NOX from 

stationary sources range from $468 to $4,809 per ton (2012$).63 DOE calculated 

monetary benefits using a medium value for NOX emissions of $2,639 per short ton (in 

2012$), and real discount rates of 3 percent and 7 percent.

63 For additional information, refer to U.S. Office of Management and Budget, Office of Information and 

Regulatory Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal Entities, Washington, DC.

243

 
DOE is evaluating appropriate monetization of avoided SO2 and Hg emissions in 

energy conservation standards rulemakings. It has not included monetization in the 

current analysis.

M. Utility Impact Analysis

In the utility impact analysis, DOE analyzes the changes in electric installed 

capacity and generation that result for each TSL. The utility impact analysis uses a 

variant of NEMS,64 which is a public domain, multi-sectored, partial equilibrium model 

of the U.S. energy sector. DOE uses a variant of this model, referred to as NEMS-BT,65

to account for selected utility impacts of new or amended energy conservation standards. 

DOE’s analysis consists of a comparison between model results for the most recent AEO

Reference Case and for cases in which energy use is decremented to reflect the impact of 

potential standards. The energy savings inputs associated with each TSL come from the 

NIA. Chapter 15 of the NOPR TSD describes the utility impact analysis.

N. Employment Impact Analysis

Employment impacts include direct and indirect impacts. Direct employment 

impacts are any changes in the number of employees of manufacturers of the products 

subject to standards; the MIA addresses those impacts. Indirect employment impacts are 

64 For more information on NEMS, refer to the U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary is National Energy Modeling System: An Overview 

2003, DOE/EIA-0581(2003), March, 2003. 65 DOE/EIA approves use of the name “NEMS” to describe only an official version of the model without 

any modification to code or data. Because this analysis entails some minor code modifications and the 

model is run under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it 

by the name “NEMS-BT” (“BT” is DOE’s Building Technologies Program, under whose aegis this work 

has been performed). 

244

 
changes in national employment that occur due to the shift in expenditures and capital 

investment caused by the purchase and operation of more-efficient appliances. Indirect 

employment impacts from standards consist of the jobs created or eliminated in the 

national economy due to: (1) reduced spending by end users on energy; (2) reduced 

spending on new energy supply by the utility industry; (3) increased customer spending 

on the purchase of new products; and (4) the effects of those three factors throughout the 

economy. 

One method for assessing the possible effects on the demand for labor of such 

shifts in economic activity is to compare sector employment statistics developed by the 

Labor Department’s Bureau of Labor Statistics (BLS). BLS regularly publishes its 

estimates of the number of jobs per million dollars of economic activity in different 

sectors of the economy, as well as the jobs created elsewhere in the economy by this 

same economic activity. Data from BLS indicate that expenditures in the utility sector 

generally create fewer jobs (both directly and indirectly) than expenditures in other 

sectors of the economy.66 There are many reasons for these differences, including wage 

differences and the fact that the utility sector is more capital-intensive and less laborintensive than other sectors. Energy conservation standards have the effect of reducing 

customer utility bills. Because reduced customer expenditures for energy likely lead to 

increased expenditures in other sectors of the economy, the general effect of efficiency 

standards is to shift economic activity from a less labor-intensive sector (i.e., the utility 

sector) to more labor-intensive sectors (e.g., the retail and service sectors). Thus, based 

66 See Bureau of Economic Analysis, “Regional Multipliers: A User Handbook for the Regional InputOutput Modeling System (RIMS II),” U.S. Department of Commerce (1992).

245

 
on the BLS data alone, DOE believes net national employment may increase because of 

shifts in economic activity resulting from amended energy conservation standards for 

automatic commercial ice makers.

For the amended standard levels considered in today’s NOPR, DOE estimated 

indirect national employment impacts using an input/output model of the U.S. economy 

called Impact of Sector Energy Technologies version 3.1.1 (ImSET).67 ImSET is a 

special-purpose version of the “U.S. Benchmark National Input-Output” (I–O) model, 

which was designed to estimate the national employment and income effects of energysaving technologies. The ImSET software includes a computer-based I–O model having 

structural coefficients that characterize economic flows among the 187 sectors. ImSET’s 

national economic I–O structure is based on a 2002 U.S. benchmark table, specially 

aggregated to the 187 sectors most relevant to industrial, commercial, and residential 

building energy use. DOE notes that ImSET is not a general equilibrium forecasting 

model, and understands the uncertainties involved in projecting employment impacts, 

especially changes in the later years of the analysis. Because ImSET does not incorporate 

price changes, the employment effects predicted by ImSET may over-estimate actual job 

impacts over the long run. For the NOPR, DOE used ImSET only to estimate short-term 

(through 2022) employment impacts.

67 Scott, M.J., O.V. Livingston, P.J. Balducci, J.M. Roop, and R.W. Schultz. ImSET 3.1: Impact of Sector 

Energy Technologies. 2009. Pacific Northwest National Laboratory, Richland, WA. Report No. PNNL18412. <www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf>

246

 
For more details on the employment impact analysis, see chapter 16 of the NOPR 

TSD.

At the February 2012 preliminary analysis public meeting, NPCC inquired 

whether the money saved from low water consumption will be moved into the 

employment impact analysis along with the money saved from lower energy 

consumption. (NPCC, No. 42 at pp. 164 and 165) In response, DOE notes that all 

changes in operations and maintenance costs, including water costs, are captured in the 

employment analysis.

For more details on the employment impact analysis and its results, see chapter 16

of the NOPR TSD and section V.B.3.d of this notice.

O. Regulatory Impact Analysis

DOE prepared a regulatory impact analysis (RIA) for this rulemaking, which is 

described in chapter 17 of the NOPR TSD. The RIA is subject to review by OIRA in the 

OMB. The RIA consists of (1) a statement of the problem addressed by this regulation 

and the mandate for Government action; (2) a description and analysis of policy 

alternatives to this regulation; (3) a qualitative review of the potential impacts of the 

alternatives; and (4) the national economic impacts of the proposed standard.

The RIA assesses the effects of feasible policy alternatives to amended automatic 

commercial ice makers standards and provides a comparison of the impacts of the 

247
alternatives. DOE evaluated the alternatives in terms of their ability to achieve significant 

energy savings at reasonable cost, and compared them to the effectiveness of the

proposed rule. 

DOE identified the following major policy alternatives for achieving increased 

automatic commercial ice makers efficiency:

• no new regulatory action

• commercial customer tax credits

• commercial customer rebates

• voluntary energy efficiency targets

• bulk government purchases

• early replacement

DOE qualitatively evaluated each alternative’s ability to achieve significant 

energy savings at reasonable cost and compared it to the effectiveness of the proposed 

rule. DOE assumed that each alternative policy would induce commercial customers to 

voluntarily purchase at least some higher efficiency equipment at any of the TSLs. In 

contrast to a standard at one of the TSLs, the adoption rate of the alternative nonregulatory policy cases may not be 100 percent, which would result in lower energy 

savings than a standard. The following paragraphs discuss each policy alternative. (See 

chapter 17 of the NOPR TSD for further details.) 

248
No new regulatory action: The case in which no regulatory action is taken for 

automatic commercial ice makers constitutes the base-case (or no action) scenario. By 

definition, no new regulatory action yields zero energy savings and an NPV of zero 

dollars. 

Commercial customer tax credits: Customer tax credits are considered a viable 

non-regulatory market transformation program. From a customer perspective, the most 

important difference between rebate and tax credit programs is that a rebate can be 

obtained quickly, whereas receipt of tax credits is delayed until income taxes are filed or 

a tax refund is provided by the Internal Revenue Service (IRS). From a societal 

perspective, tax credits (like rebates) do not change the installed cost of the equipment, 

but rather transfer a portion of the cost from the customer to taxpayers as a whole. DOE, 

therefore, assumed that equipment costs in the customer tax credits scenario were 

identical to the NIA base case. The change in the NES and NPV is a result of the change 

in the efficiency distributions that results from lowering the prices of higher efficiency 

equipment.

Commercial customer rebates: Customer rebates cover a portion of the difference 

in incremental product price between products meeting baseline efficacy levels and those 

meeting higher efficiency levels, resulting in a higher percentage of customers purchasing 

more-efficacious models and decreased aggregated energy use compared to the base case. 

Although the rebate program reduces the total installed cost to the customer, it is financed 

by tax revenues. Therefore, from a societal perspective, the installed cost at any 

249
efficiency level does not change with the rebate program; rather, part of the cost is 

transferred from the customer to taxpayers as a whole. Consequently, DOE assumed that 

equipment costs in the rebates scenario were identical to the NIA base case. The change 

in the NES and NPV is a result of the change in the efficiency distributions that results as 

a consequence of lowering the prices of higher efficiency equipment.

Voluntary energy efficiency targets: While it is possible that voluntary programs 

for equipment would be effective, DOE lacks a quantitative basis to determine how 

effective such a program might be. As noted previously, broader economic and social 

considerations are in play than simple economic return to the equipment purchaser. DOE 

lacks the data necessary to quantitatively project the degree to which voluntary programs 

for more expensive, higher efficiency equipment would modify the market.

Bulk government purchases and early replacement incentive programs: DOE also 

considered, but did not analyze, the potential of bulk government purchases and early 

replacement incentive programs as alternatives to the proposed standards. Bulk 

government purchases would have a very limited impact on improving the overall market 

efficiency of automatic commercial ice makers because they would be a small part of the 

total equipment sold in the market. In the case of replacement incentives, several policy 

options exist to promote early replacement, including a direct national program of 

customer incentives, incentives paid to utilities to promote an early replacement program, 

market promotions through equipment manufacturers, and replacement of governmentowned equipment. In considering early replacements, DOE estimates that the energy 

250
savings realized through a one-time early replacement of existing stock equipment does 

not result in energy savings commensurate to the cost to administer the program. 

Consequently, DOE did not analyze this option in detail.

V. Analytical Results

A. Trial Standard Levels

1. Trial Standard Level Formulation Process and Criteria

DOE selected between four and seven efficiency levels for all equipment classes

for analysis. For all equipment classes, the first efficiency level is the baseline efficiency 

level. Based on the results of the LCC analysis and NIA, DOE selected five TSLs above 

the baseline level for each equipment class for the NOPR stage of this rulemaking. Table 

V.1Table V.1 shows the mapping between TSLs and efficiency levels.

TSL 5 was selected at the max-tech level for all equipment classes.

TSL 4 was chosen as an intermediate level between the max-tech level and the 

maximum customer NPV level, subject to the requirement that the TSL 4 NPV must be 

positive. “Customer NPV” is the NPV of future savings obtained from the NIA. It 

provides a measure of the benefits only to the customers of the automatic commercial ice 

makers, and does not account for the net benefits to the Nation. The net benefits to the 

Nation also include monetized values of emissions reductions in addition to the customer

NPV. Where a sufficient number of efficiency levels allow it, TSL 4 is set at least one 

251
level below max-tech and one level above the efficiency level with the highest NPV. In 

one case, the TSL 4 efficiency level is the maximum NPV level because the next higher 

level had a negative NPV. In cases where the maximum NPV efficiency level is the 

penultimate efficiency level and the max-tech level showed a positive NPV the TSL 4 

efficiency level is also the max-tech level.

TSL 3 was chosen to represent the group of efficiency levels with the highest 

customer NPV at a 7-percent discount rate. 

TSL 2 was selected to provide intermediate efficiency levels that fill the gap

between the TSLs 1 and 3. Note that with the number of efficiency levels available for 

each equipment class, there is often overlap between TSL levels. Thus, TSL 2 includes 

levels that overlap with both TSLs 1 and 3. The intent of TSL 2 is to provide an 

intermediate level to preclude big jumps in efficiency between TSLs 1 and 3.

TSL 1 was set equal to efficiency level 2. In the analysis, efficiency level 2 was 

set equivalent to ENERGY STAR for products rated by ENERGY STAR, and an 

equivalent efficiency improvement for other equipment classes. 

illustrates the efficiency improvements incorporated in all efficiency levels.

Table V.1 Mapping Between TSLs and Efficiency Levels*

Equipment Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B Level 2 Level 3 Level 5 Level 5 Level 6

IMH-W-Med-B Level 2 Level 2 Level 3 Level 4 Level 5

IMH-W-Large-B†

 IMH-W-Large-B1 Level 2 Level 2 Level 2 Level 3 Level 4

252
 IMH-W-Large-B2 Level 2 Level 2 Level 2 Level 3 Level 4

IMH-A-Small-B Level 2 Level 3 Level 5 Level 6 Level 7

IMH-A-Large-B†

 IMH-A-Large-B1 Level 2 Level 3 Level 5 Level 6 Level 6

 IMH-A-Large-B2 Level 2 Level 2 Level 3 Level 4 Level 4

RCU-Large-B†

 RCU-Large-B1 Level 2 Level 2 Level 3 Level 4 Level 5

 RCU-Large-B2 Level 2 Level 2 Level 3 Level 4 Level 5

SCU-W-Large-B Level 2 Level 3 Level 5 Level 6 Level 7

SCU-A-Small-B Level 2 Level 4 Level 6 Level 7 Level 7

SCU-A-Large-B Level 2 Level 4 Level 6 Level 7 Level 7

IMH-A-Small-C Level 2 Level 3 Level 4 Level 5 Level 7

IMH-A-Large-C Level 2 Level 3 Level 5 Level 6 Level 7

SCU-A-Small-C Level 2 Level 3 Level 4 Level 4 Level 6

*For three large equipment classes -- IMH-W-Large-B, IMH-A-Large-B and RCU-Large-B -- because 

the harvest capacity range is so wide DOE analyzed two typical models to ensure models at the low 

and the higher portions of the applicable range were accurately modeled. The smaller of the two is 

noted as B1 and the larger as B2.

†DOE analyzed impacts for the B1 and B2 typical units and aggregated impacts to the equipment class 

level.

Table V.2Table V.2 illustrates the efficiency improvements incorporated in 

all efficiency levels.

Table V.2 Percentage Efficiency Improvement from Baseline by TSL*

Equipment Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 10.0% 15.0% 25.0% 25.0% 29.4%

IMH-W-Med-B 10.0% 10.0% 15.0% 20.0% 21.3%

IMH-W-Large-B 10.0% 10.0% 10.0% 15.0% 16.4%

 IMH-W-Large-B1 10.0% 10.0% 10.0% 15.0% 16.7%

 IMH-W-Large-B2 10.0% 10.0% 10.0% 15.0% 15.5%

IMH-A-Small-B 10.0% 15.0% 25.0% 30.0% 31.3%

IMH-A-Large-B 10.0% 14.2% 23.4% 28.0% 28.0%

 IMH-A-Large-B1 10.0% 15.0% 25.0% 29.4% 29.4%

 IMH-A-Large-B2 10.0% 10.0% 15.0% 20.0% 20.0%

RCU-Large-B 9.0% 9.0% 15.0% 20.0% 20.6%

 RCU-Large-B1 9.0% 9.0% 15.0% 20.0% 20.6%

 RCU-Large-B2 9.0% 9.0% 15.0% 20.0% 20.5%

SCU-W-Large-B 7.0% 15.0% 25.0% 30.0% 30.2%

SCU-A-Small-B 7.0% 20.0% 30.0% 39.3% 39.3%

SCU-A-Large-B 7.0% 20.0% 30.0% 34.9% 34.9%

IMH-A-Small-C 10.0% 15.0% 20.0% 25.0% 31.0%

IMH-A-Large-C 10.0% 15.0% 25.0% 30.0% 30.2%

SCU-A-Small-C 7.0% 15.0% 20.0% 20.0% 28.2%

*Percentage improvements for IMH-W-Large-B, IMH-A-Large-B and RCU-Large-B are a weighted 

average of the B1 and B2 units, using weights provided in TSD chapter 7.

253
Table V.3illustrates the design options associated with each TSL level, for each analyzed 

product class. The design options are discussed in Section IV.D.3 of today’s NOPR, and 

in Chapter 5 of the NOPR TSD.

254
Table V.3: Design Options for Analyzed Products Classes at each TSL

Equipment Class Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Design Options for Each TSL (options are cumulative – TSL5 includes all preceding options)

IMH-W-Small-B No BW Fill, 

PSC PM

Increase 

Comp EER, 

Increase Cond

Same as 

previous

Increase Cond, 

BW Fill

BW Fill, 

Increase 

Evap, ECM 

PM

ECM PM, 

DWHX

IMH-W-Med-B BW Fill, PSC 

PM

Increase 

Comp EER

Same as 

previous

Increase Comp 

EER, Increase 

Cond

Increase 

Comp EER, 

ECM PM, 

DWHX

DWHX

IMH-W-Large-B1 BW Fill, PSC 

PM

Increase 

Comp EER, 

Increase Cond

Same as 

previous

Same as 

previous

Increase 

Cond, ECM 

PM, DWHX

DWHX

IMH-W-Large-B2 BW Fill, PSC 

PM

Increase 

Comp EER, 

Increase Cond

Same as 

previous

Same as 

previous

ECM PM, 

DWHX DWHX

IMH-A-Small-B BW Fill, PSC 

PM, SPM FM

Increase 

Comp EER, 

Increase 

Cond, 

Increase Evap

Increase Evap

Increase Evap, 

PSC FM, ECM 

FM, Increase 

Cond

Increase 

Cond, ECM 

PM, DWHX

DWHX

IMH-A-Large-B1 BW Fill, PSC 

PM, SPM FM

PSC FM, 

Comp EER

Increase Comp 

EER

Increase Comp 

EER, BW Fill, 

ECM PM, ECM 

FM, Increase 

Cond

Increase 

Cond, 

DWHX

DWHX

IMH-A-Large-B2 BW Fill, PSC 

PM, SPM FM

Increase 

Comp EER, 

PSC FM

Same as 

previous

PSC FM, 

Increase Cond

ECM FM, 

ECM PM, 

DWHX

ECM FM, 

ECM PM, 

DWHX

RCU-Large-B1 BW Fill, PSC 

PM, PSC FM

Increase 

Comp EER

Same as 

previous

Increase Comp 

EER, Increase 

Cond, ECM FM

ECM FM, 

Increase 

Cond, ECM 

PM, DWHX

DWHX

RCU-Large-B2

BW Fill, PSC 

PM, PSC FM

Increase 

Comp EER, 

Increase Cond

Same as 

previous

ECM PM

Increase Cond

Increase 

Cond, ECM 

FM, DWHX

DWHX

SCU-W-Large-B No BW Fill, 

PSC PM BW Fill

BW Fill, 

Increase 

Comp EER, 

Increase Cond

Increase Cond, 

ECM PM

ECM PM, 

DWHX DWHX

SCU-A-Small-B

No BW Fill, 

PSC PM, SPM 

FM

PSC FM, 

Increase Cond

Increase 

Cond, 

Increase 

Comp EER

Increase Comp 

EER, BW Fill

BW Fill, 

ECM PM, 

ECM FM, 

DWHX

Same as 

previous

SCU-A-Large-B

No BW Fill, 

PSC PM, SPM 

FM

Increase 

Comp EER

Increase 

Comp EER, 

Increase 

Cond, BW Fill

BW Fill, PSC 

FM, ECM FM, 

ECM PM

ECM PM, 

DWHX

Same as 

previous

IMH-A-Small-C PSC AM, SPM 

FM

PSC FM, 

Increase 

Comp EER

PSC FM, 

Increase 

Comp EER

Increase Comp 

EER, Increase 

Cond, ECM FM

ECM FM, 

ECM AM ECM AM

IMH-A-Large-C PSC AM, SPM 

FM

Increase 

Cond, 

Increase 

Comp EER

Increase 

Comp EER

Increase Comp 

EER, PSC FM, 

ECM FM

ECM FM, 

ECM AM ECM AM

SCU-A-Small-C PSC AM, SPM 

FM Increase Cond

Increase 

Cond, 

Increase 

Comp EER

Increase Comp 

EER, PSC FM

Same as 

previous

ECM FM, 

ECM AM

255
SPM = Shaded Pole Motor

PSC = Permanent Split Capacitor Motor

ECM = Electronically Commutated Motor

FM = Fan Motor (Air-Cooled Units)

PM = Pump Motor (Batch Units)

AM = Auger Motor (Continuous Units)

BW Fill = Batch Water Fill Option Included 

Increase Cond = Increase in Condenser Size

Increase Evap = Increase in Evaporator Size

Increase Comp EER = Increase in Compressor EER

DWHX = Addition of Drainwater Heat Exchanger

DOE requests comment and data related to the required equipment size increases 

associated with the design options at each TSL levels. Chapter 5 of the NOPR TSD 

contains full descriptions of the design options and DOE’s analyses for the equipment 

size increase associated with the design options selected. DOE also requests comments 

and data on the efficiency gains associated with each set of design options. Chapter 5 of 

the NOPR TSD contains DOE’s analyses of the efficiency gains for each design option 

considered. Finally, DOE requests comment and data on any utility impacts associated 

with each set of design options, such as potential ice-style changes.

2. Trial Standard Level Equations

Table V.4Table V.3 and Table V.5Table V.4 translate the TSLs into potential 

standards. In Table V.4Table V.3, the TSLs are translated into energy consumption 

standards for the directly analyzed (primary) equipment classes. Table V.5Table 

V.4.provides the equipment class mapping showing which of the directly analyzed 

standards’ results were used to extend standards to secondary classes. Table V.6Table 

V.5 extends the standards to the remaining (secondary) equipment classes that have not 

been analyzed directly. 

Table V.4 Potential Energy Consumption Standards for Directly Analyzed Classes

Equipment Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 7.01 –

0.0050H

6.62 –

0.0047H

5.84 –

0.0041H

5.84 –

0.0041H

5.49 –

0.0039H

IMH-W-Med-B 5.04 – 4.65 – 3.88 – 3.98 – 3.63 –

256
0.0010H 0.0007H 0.0002H 0.0004H 0.0002H

IMH-W-Large-B 3.6 3.6 3.6 3.4 3.3

IMH-A-Small-B 9.23 –

0.0077H

8.74 –

0.0073H

7.70 –

0.0065H

7.18 –

0.0060H

7.05 –

0.0059H

IMH-A-Large-B 6.20 –

0.0010H

5.86 –

0.0009H

5.17 –

0.0008H

4.82 –

0.0008H

4.74 –

0.0008H

IMH-A-Extended-B

(>= 2,500 

and <4,000)

3.7;

(>=1,240 and 

<1,975)

4.7;

(>=1,975 and 

<2,500)

6.89 –

0.0011H;

(>= 2,500)

4.1

(>=875 and 

<2,210)

4.5;

(>=2,210 and 

<2,500)

6.89 –

0.0011H;

(>= 2,500)

4.1

(>=815 and 

<2,455)

4.2;

(>=2,455 and 

<2,500)

6.89 –

0.0011H;

(>= 2,500)

4.1

(>=710 and 

<2,455)

4.2;

(>=2,455 and 

<2,500)

6.89 –

0.0011H;

(>= 2,500)

4.1

RCU-NRC-Large-B 4.6 4.6 4.3 4.1 4.1

SCU-W-Large-B 7.1 6.5 5.7 5.3 5.3

SCU-A-Small-B 16.74 –

0.0436H

14.40 –

0.0375H

12.6 –

0.0328H

10.34 –

0.0227H

10.34 –

0.0227H

SCU-A-Large-B 9.1 7.8 6.9 6.4 6.4

IMH-A-Small-C 9.90 –

0.0057H

9.35 –

0.0053H

9.24 –

0.0061H

8.69 –

0.0058H

7.55 –

0.0042H

IMH-A-Large-C 5.9 5.6 5.0 4.6 4.6

SCU-A-Small-C 10.70 –

0.0058H

9.75 –

0.0053H

9.20 –

0.0050H

9.20 –

0.0050H

8.26 –

0.0045H

Table V.5 Directly Analyzed Equipment Classes Used to Develop Standards for 

Secondary Classes

Secondary 

Equipment Class

Directly Analyzed Product Class 

Associated with Efficiency Level 

for Secondary Product Class

RCU-NRC-Small-B RCU-NRC-Large-B

RCU-RC-Small-B RCU-NRC-Large-B

RCU-RC-Large-B RCU-NRC-Large-B

SCU-W-Small-B SCU-W-Large-B

IMH-W-Small-C IMH-A-Large-C

IMH-W-Large-C IMH-A-Large-C

RCU-NRC-Small-C IMH-A-Large-C

RCU-NRC-Large-C IMH-A-Large-C

RCU-RC-Small-C IMH-A-Large-C

RCU-RC-Large-C IMH-A-Large-C

SCU-W-Small-C SCU-A-Small-C

SCU-W-Large-C SCU-A-Small-C

SCU-A-Large-C SCU-A-Small-C

Table V.6 Potential Energy Consumption Standards for Secondary Classes

Equipment Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

RCU-NRC-Small-B 8.04 –

0.0034H

8.04 –

0.0034H 7.52 – 0.0032H 7.08 – 0.0030H 7.05 – 0.0030H

RCU-RC-Small-B 8.02 –

0.0034H

8.02 –

0.0034H 7.52 – 0.0032H 7.08 – 0.0030H 7.06 – 0.0030H

257
RCU-RC-Large-B 4.8 4.8 4.5 4.3 4.3

SCU-W-Small-B 10.60 –

0.0177H

9.69 –

0.0162H 8.55 – 0.0143H 7.98 – 0.0133H 7.96 – 0.0133H

IMH-W-Small-C 7.29 –

0.0030H

6.86 –

0.0028H 6.08 – 0.0025H 5.67 – 0.0023H 5.65 – 0.0023H

IMH-W-Large-C 4.6 4.3 3.8 3.6 3.6

RCU-NRC-Small-C 9.00 –

0.0041H

8.50 –

0.0039H 7.5 – 0.0034H 7.00 – 0.0032H 6.98 – 0.0032H

RCU-NRC-Large-C 5.5 5.2 4.6 4.3 4.3

RCU-RC-Small-C 9.18 –

0.0041H

8.67 –

0.0039H 7.65 – 0.0034H 7.14 – 0.0031H 7.12 – 0.0031H

RCU-RC-Large-C 5.7 5.4 4.8 4.5 4.5

SCU-W-Small-C 8.46 –

0.0031H

7.74 –

0.0028H 7.28 – 0.0027H 7.28 – 0.0027H 6.53 – 0.0024H

SCU-W-Large-C 5.7 5.2 4.9 4.9 4.4

SCU-A-Large-C 6.6 6.0 5.7 5.7 5.1

In developing TSLs, DOE analyzed each equipment class separately, and 

attributed a percentage reduction with each portion of the standard curve 

(small/medium/large). To ensure that the standard curve remained connected (no gaps at 

the breakpoints), DOE developed a method for expressing the consumption standards that 

relied on pivoting the low-capacity equipment classes about a representative point. DOE 

was able to use the same methodology for most equipment classes, with exceptions for 

IMH-W-B, IMH-A-B, and RCU-RC equipment classes.

In drawing a relationship between the harvest capacity (lb ice/24 hours) and the 

maximum allowed energy usage (kilowatt-hours per 100 lb of ice), DOE first took the 

large-capacity equipment class (which is set at a constant value for all equipment types 

except IMH-A) and applied the allocated percentage reduction (percentage reduction 

associated with the TSL for that equipment class). For example, for IMH-W-Large-B, the 

baseline level is set at 4.0. If the TSL allocated a 10-percent reduction for IMH-W-LargeB, then the next level was set at 4.0 × (1-10 percent) = 3.6 kWh/100 lb of ice.

258
Then, for the small equipment classes, DOE applied the allocated percentage 

reduction at a designated median capacity in that harvest rate range. The medium 

capacity was selected based on shipment levels, and where the median fell within the 

shipments data. For example, if the median capacity for the small equipment class was at 

300 lb ice/24 hours, DOE would calculate the baseline energy usage and then apply the 

allocated percentage reduction to obtain a point at 300 lb ice/24 hours. DOE would then 

draw a line between the start of the large equipment class and this median capacity point 

to obtain the equation for the small equipment class, ensuring that there were no gaps 

between small and large-capacity.

For the IMH-W-B equipment classes, this equipment type has small, medium, and 

large equipment classes. In this case, for the small equipment class, DOE applied the 

allocated percentage reduction to the whole equation. So if the percentage reduction was 

10 percent, the new equation for the small equipment class would be (1-10 percent) ×

(7.80 – 0.0055H) = 7.02 – 0.00495H. DOE would then draw a line between the end of the 

small equipment class and the start of the large equipment class, to obtain the equation 

for the medium equipment class.

For the IMH-A-B equipment classes, DOE sought to obtain a constant efficiency 

level for the largest equipment classes. This calculation is discussed in section IV.B.1.b.

For the RCU-RC-B and RCU-RC-C equipment classes, DOE simply took the 

standard levels calculated for the large RCU-NRC-B and RCU-NRC-C equipment 

259
classes, respectively, and subtracted the 0.2 kWh/100 lb of ice differential discussed in 

section IV.B.1.e, to arrive at the standard levels. For the small RCU classes, the remote 

compressor standards were developed such that no gap exists at the harvest rate 

breakpoints.

Using the typical unit size for directly analyzed equipment classes, the potential 

standards shown on Table V.4Table V.3, DOE estimates energy usage for equipment 

within each class to be as shown on Table V.7Table V.6.

Table V.7 Energy Consumption by TSL for the Representative Automatic 

Commercial Ice Maker Units

Equipment Class

Representative 

Harvest Rate

lb ice/24 hours

Energy Consumption of the 

Representative Automatic Commercial 

Ice Maker Unit

kWh/100 lb

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 300 5.5 5.2 4.6 4.6 4.3

IMH-W-Med-B 850 4.2 4.0 3.7 3.6 3.5

IMH-W-Large-B-1 1500 3.6 3.6 3.6 3.4 3.3

IMH-W-Large-B-2 2600 3.6 3.6 3.6 3.4 3.3

IMH-A-Small-B 300 6.9 6.5 5.8 5.4 5.3

IMH-A-Large-B-1 800 5.4 5.1 4.5 4.2 4.1

IMH-A-Large-B-2 1500 3.7 4.7 4.5 4.2 4.2

RCU-Large-B-1 1500 4.6 4.6 4.3 4.1 4.1

RCU-Large-B-2 2400 4.6 4.6 4.3 4.1 4.1

SCU-W-Large-B 300 7.1 6.5 5.7 5.3 5.3

SCU-A-Small-B 110 11.9 10.3 9.0 7.8 7.8

SCU-A-Large-B 200 9.1 7.8 6.9 6.4 6.4

IMH-A-Small-C 310 8.1 7.7 7.3 6.9 6.2

IMH-A-Large-C 820 5.9 5.6 5.0 4.6 4.6

SCU-A-Small-C 110 10.1 9.2 8.7 8.7 7.8

260
B. Economic Justification and Energy Savings

1. Economic Impacts on Commercial Customers

a. Life-Cycle Cost and Payback Period

Customers affected by new or amended standards usually incur higher purchase 

prices and lower operating costs. DOE evaluates these impacts on individual customers

by calculating changes in LCC and the PBP associated with the TSLs. The results of the 

LCC analysis for each TSL were obtained by comparing the installed and operating costs 

of the equipment in the base-case scenario (scenario with no amended energy 

conservation standards) against the standards-case scenarios at each TSL. The energy 

consumption values for both the base-case and standards-case scenarios were calculated 

based on the DOE test procedure conditions specified in the 2012 test procedure final 

rule, which adopts an industry-accepted test method. Using the approach described in 

section IV.G, DOE calculated the LCC savings and PBPs for the TSLs considered in this 

NOPR. The LCC analysis is carried out in the form of Monte Carlo simulations. 

Consequently, the results of LCC analysis are distributed over a range of values, as 

opposed to a single deterministic value. DOE presents the mean or median values, as 

appropriate, calculated from the distributions of results.

Table V.8Table V.7 through Table V.25Table V.24 show the results of the LCC 

analysis for each equipment class. Each table presents the results of the LCC analysis,

including mean LCC, mean LCC savings, median PBP, and distribution of customer

261
impacts in the form of percentages of customers who experience net cost, no impact, or 

net benefit.

Only two equipment classes have negative LCC savings values at TSL 5: SCU-ASmall-C and IMH-A-Small-C. Negative average LCC savings imply that, on average, 

customers experience an increase in LCC of the equipment as a consequence of buying 

equipment associated with that particular TSL. In many cases, the TSL 5 level is not 

negative, but the LCC savings are sharply lower than the TSL 3 levels. For IMH-WSmall-B, SCU-W-Large-B, and SCU-A-Small-B, the TSL 5 LCC savings are less than 

one-third the TSL 3 savings. In other cases, such as IMH-W-Large-B2, IMH-A-Small-B, 

SCU-A-Large-B, and IMH-A-Large-C, the TSL 5 LCC savings are roughly one-half of 

the TSL 3 LCC savings or less. All of these results indicate the cost increments 

associated with the max-tech design option are high, and the increase in LCC (and 

corresponding decrease in LCC savings) indicates that this design option may result in 

negative customer impacts. TSL 5 is associated with the max-tech level for all the 

equipment classes. Drain water heat exchanger technology is the design option associated 

with the max-tech efficiency levels for batch equipment classes. For continuous 

equipment classes, the max-tech design options are auger motors using permanent 

magnets.

The mean LCC savings associated with TSL 4 are all positive values for all 

equipment classes. The mean LCC savings at all lower TSL levels are also positive. The 

trend is generally an increase in LCC savings for TSL 1 through 3, with LCC savings

262
either remaining constant or declining at TSL 4. In three cases, the highest LCC savings 

are at TSL 2: IMH-A-Large-B2, RCU-Large-B2, and SCU-A-Large-B. The drop-off in 

LCC savings at TSL 4 is generally associated with the relatively large cost for the maxtech design options, the savings for which frequently span the last two efficiency levels. 

As described in section IV.H.2, DOE used a “roll-up” scenario in this rulemaking. 

Under the roll-up scenario, DOE assumes that the market shares of the efficiency levels 

(in the base case) that do not meet the standard level under consideration would be 

“rolled up” into (meaning “added to”) the market share of the efficiency level at the 

standard level under consideration, and the market shares of efficiency levels that are 

above the standard level under consideration would remain unaffected. Customers, in the 

base-case scenario, who buy the equipment at or above the TSL under consideration,

would be unaffected if the amended standard were to be set at that TSL. Customers, in 

the base-case scenario, who buy equipment below the TSL under consideration would be

affected if the amended standard were to be set at that TSL. Among these affected 

customers, some may benefit from lower LCC of the equipment and some may incur net 

cost due to higher LCC, depending on the inputs to LCC analysis such as electricity 

prices, discount rates, installation costs, and markups. DOE’s results indicate that, with 

one exception, customers either benefit or are unaffected by setting standards at TSLs 1, 

2, or 3, and at TSL 4 in the case of SCU-A-Small-C. Customers either benefit or are 

unaffected at all 5 TSLs in the case of IMH-W-Large-B1. In the case of IMH-W-SmallB, 3 percent of customers are projected to experience a net cost at TSL 3. A large 

percentage of customers in batch equipment classes are unaffected by a standard set at 

263
TSL 1 given the equivalence to ENERGY STAR and the prevalence of ENERGY STAR 

qualifying equipment in those classes. At the other end of the range, in almost all cases, a 

portion of the market would experience net costs starting with TSL 4, although generally 

the portion experiencing a net cost is fairly low. At TSL 5, the range is wide, with all 

customers either unaffected or with a net benefit for the IMH-W-Large-B1 typical unit at 

one extreme and 100 percent of customers with either a net cost or unaffected for SCUA-Small-C. In the cases of nine of the 18 equipment classes and/or typical unit sizes

modeled (12 classes plus 3 pairs of typical units for large, batch type equipment classes), 

20 percent or more of customers would experience a net cost at TSL 5. In the other nine

cases, the percent of customers experiencing a net cost at TSL 5 ranges from 0 to 16

percent, with the remaining customers either unaffected or experiencing a net benefit.

The median PBP values for TSLs 1 through 3 are all less than 2 years, except for 

IMH-W-Small-B where the TSL 3 PBP is 2.3 years. The median PBP values for TSL 4 

range from 1.9 years to 4.8 years. 

PBP values for TSL 5 range from 2.2 years to over 19 years. SCU-A-Small-C 

exhibits the longest PBP for TSL 5 at 19.1 years. IMH-A-Small-C has a PBP of nearly 7 

years, while IMH-W-Small-B has a PBP over 5 years. IMH-A-Small-B and SCU-ASmall-B both PBPs at or above 4 years for TSL 5.

Table V.8 Summary LCC and PBP Results for IMH-W-Small-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

% of Customers that 

Experience

Net No Net

264
Savings

2012$

Cost

%

Impact

%

Benefit

%

1 3,052 2,425 10,862 13,286 199 0 61 39 1.1 

2 2,884 2,451 10,740 13,191 215 0 35 65 1.3 

3 2,547 2,614 10,369 12,982 328 3 0 97 2.3 

4 2,547 2,614 10,369 12,982 328 3 0 97 2.3 

5 2,400 2,999 10,262 13,261 49 45 0 55 5.4 

Table V.9 Summary LCC and PBP Results for IMH-W-Med-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 6,507 4,241 24,859 29,100 464 0 31 69 0.6 

2 6,507 4,241 24,859 29,100 464 0 31 69 0.6 

3 6,147 4,286 24,601 28,887 587 0 14 86 0.9 

4 5,786 4,656 24,341 28,997 405 15 2 83 3.3

5 5,691 4,671 24,272 28,943 460 11 2 87 3.2

Table V.10 Summary LCC and PBP Results for IMH-W-Large-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 11,585 6,243 49,854 56,097 833 0 38 62 0.7 

2 11,585 6,243 49,854 56,097 833 0 38 62 0.7 

3 11,585 6,243 49,854 56,097 833 0 38 62 0.7 

4 10,943 6,813 49,390 56,202 550 8 26 66 3.6 

5 10,783 6,868 49,274 56,142 582 7 22 71 3.6 

Table V.11 Summary LCC and PBP Results for IMH-W-Large-B1 Equipment 

Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 9,877 5,132 42,919 48,051 701 0 29 71 0.7 

2 9,877 5,132 42,919 48,051 701 0 29 71 0.7 

3 9,877 5,132 42,919 48,051 701 0 29 71 0.7 

4 9,329 5,646 42,523 48,170 583 0 29 71 3.7 

5 9,147 5,717 42,392 48,109 607 0 24 76 3.8 

265
Table V.12 Summary LCC and PBP Results for IMH-W-Large-B2 Equipment 

Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 17,104 9,833 72,254 82,087 1,260 0 67 33 0.6 

2 17,104 9,833 72,254 82,087 1,260 0 67 33 0.6 

3 17,104 9,833 72,254 82,087 1,260 0 67 33 0.6 

4 16,155 10,581 71,569 82,150 442 35 17 48 3.1

5 16,067 10,587 71,506 82,093 500 29 17 54 3.0

Table V.13 Summary LCC and PBP Results for IMH-A-Small-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 3,806 2,475 9,046 11,521 254 0 63 37 1.1 

2 3,596 2,506 8,894 11,400 259 0 32 68 1.2 

3 3,176 2,574 8,601 11,174 396 0 0 100 1.4 

4 2,965 2,951 8,449 11,400 170 27 0 73 4.3

5 2,909 2,964 8,408 11,372 198 22 0 78 4.2

Table V.14 Summary LCC and PBP Results for IMH-A-Large-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 8,704 4,179 16,075 20,254 648 0 60 40 0.5 

2 8,334 4,199 15,813 20,013 633 0 23 77 0.5 

3 7,482 4,335 15,017 19,352 1,127 0 6 94 0.8 

4 7,041 4,739 14,703 19,442 994 4 2 94 2.2 

5 7,041 4,739 14,703 19,442 994 4 2 94 2.2 

Table V.15 Summary LCC and PBP Results for IMH-A-Large-B1 Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

266
1 7,919 4,119 15,303 19,421 590 0 59 41 0.5 

2 7,480 4,143 14,993 19,135 572 0 15 85 0.5 

3 6,603 4,279 14,143 18,421 1,168 0 0 100 0.8 

4 6,213 4,663 13,865 18,528 1,062 1 0 99 2.1

5 6,213 4,663 13,865 18,528 1,062 1 0 99 2.1

Table V.16 Summary LCC and PBP Results for IMH-A-Large-B2 Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 12,932 4,505 20,234 24,739 960 0 67 33 0.4 

2 12,932 4,505 20,234 24,739 960 0 67 33 0.4 

3 12,215 4,641 19,725 24,366 908 0 40 60 0.9

4 11,498 5,151 19,217 24,368 627 16 13 70 2.6 

5 11,498 5,151 19,217 24,368 627 16 13 70 2.6 

Table V.17 Summary LCC and PBP Results for RCU-Large-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 13,205 6,321 16,686 23,007 875 0 58 42 0.4 

2 13,205 6,321 16,686 23,007 875 0 58 42 0.4 

3 12,335 6,406 16,063 22,469 983 0 18 82 0.6 

4 11,611 6,934 15,551 22,485 870 6 10 85 2.4 

5 11,526 6,968 15,490 22,458 897 5 10 85 2.4 

Table V.18 Summary LCC and PBP Results for RCU-Large-B1 Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 12,727 6,135 16,214 22,349 847 0 57 43 0.4 

2 12,727 6,135 16,214 22,349 847 0 57 43 0.4 

3 11,889 6,214 15,614 21,828 963 0 18 82 0.6 

4 11,191 6,722 15,119 21,840 857 6 9 85 2.4 

5 11,108 6,756 15,059 21,815 882 5 9 86 2.4 

Table V.19 Summary LCC and PBP Results for RCU-Large-B2 Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings Payback 

Period, 

Median 

years

Installed

Cost Discounted LCC AffectedCustomers'

% of Customers that 

Experience

267
Operating

Cost

Average

Savings

2012$

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 20,349 9,105 23,743 32,847 1,298 0 73 27 0.8 

2 20,349 9,105 23,743 32,847 1,298 0 73 27 0.8 

3 19,009 9,283 22,775 32,058 1,277 0 27 73 1.0 

4 17,892 10,108 22,017 32,124 1,070 7 18 75 2.7 

5 17,779 10,137 21,935 32,072 1,123 6 18 76 2.7

Table V.20 Summary LCC and PBP Results for SCU-W-Large-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 3,892 3,501 12,082 15,583 483 0 71 29 0.7 

2 3,559 3,530 11,849 15,379 687 0 71 29 0.8 

3 3,143 3,596 11,548 15,144 694 0 57 43 1.0 

4 2,935 3,950 11,398 15,348 143 49 14 36 3.0 

5 2,925 3,951 11,391 15,342 149 49 14 37 3.0

Table V.21 Summary LCC and PBP Results for SCU-A-Small-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 2,419 2,772 7,548 10,321 103 0 83 17 1.4 

2 2,084 2,821 7,320 10,141 198 0 37 63 1.5 

3 1,826 2,896 6,979 9,875 396 0 11 89 1.6 

4 1,585 3,306 6,813 10,119 106 32 0 68 4.8 

5 1,585 3,306 6,813 10,119 106 32 0 68 4.8 

Table V.22 Summary LCC and PBP Results for SCU-A-Large-B Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 3,349 3,243 10,645 13,888 140 0 71 29 1.4 

2 2,884 3,324 10,105 13,429 522 0 36 64 1.2 

3 2,526 3,405 9,857 13,262 502 0 7 93 1.5 

4 2,351 3,758 9,731 13,489 240 34 0 66 3.7 

5 2,351 3,758 9,731 13,489 240 34 0 66 3.7 

268
Table V.23 Summary LCC and PBP Results for IMH-A-Small-C Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$*

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 4,630 6,644 9,390 16,034 315 0 77 23 0.9 

2 4,374 6,666 9,212 15,877 314 0 54 46 0.9 

3 4,118 6,694 9,031 15,726 391 0 40 60 1.0 

4 3,862 6,913 8,848 15,761 307 8 31 61 2.6 

5 3,555 7,461 8,789 16,251 (237) 73 11 16 6.8

* Values in parentheses are negative values.

Table V.24 Summary LCC and PBP Results for IMH-A-Large-C Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 8,911 5,518 15,462 20,980 660 0 65 35 0.5 

2 8,417 5,543 15,113 20,656 744 0 45 55 0.5 

3 7,430 5,630 14,426 20,055 1,026 0 15 85 0.7 

4 6,936 6,288 14,269 20,557 524 21 15 64 3.2 

5 6,912 6,289 14,262 20,552 500 21 10 69 3.2 

Table V.25 Summary LCC and PBP Results for SCU-A-Small-C Equipment Class

TSL

Energy 

Usage 

kWh/yr

Life-Cycle Cost, All Customers 

2012$ Life-Cycle Cost Savings

Payback 

Period, 

Median 

years

Installed

Cost

Discounted

Operating

Cost

LCC

Affected

Customers'

Average

Savings

2012$*

% of Customers that 

Experience

Net

Cost

%

No 

Impact

%

Net

Benefit

%

1 2,040 3,603 7,243 10,846 93 0 73 27 1.1 

2 1,866 3,632 7,127 10,760 140 0 53 47 1.5 

3 1,758 3,659 7,057 10,717 146 0 37 63 1.9 

4 1,758 3,659 7,057 10,717 146 0 37 63 1.9 

5 1,580 4,196 7,099 11,295 (441) 80 20 0 19.1 

* Values in parentheses are negative values.

b. Life-Cycle Cost Subgroup Analysis

As described in section IV.I, DOE estimated the impact of amended energy 

conservation standards for automatic commercial ice makers, at each TSL, on two 

customer subgroups—the foodservice sector and the lodging sector. For the automatic 

269
commercial ice makers, DOE has not distinguished between subsectors of the foodservice 

industry. In other words, DOE has been treating it as one sector as opposed to modeling 

limited or full service restaurants and other types of foodservice firms separately. 

Foodservice was chosen as one representative subgroup because of the large percentage 

of the industry represented by family or locally owned restaurants. Likewise, lodging was 

chosen due to the large percentage of the industry represented by locally owned, or 

franchisee-owned hotels. DOE carried out two LCC subgroup analyses, one each for 

restaurants and lodging, by using the LCC spreadsheet described in chapter 8 of the 

NOPR, but with certain modifications. The input for business type was fixed to the 

identified subgroup, which ensured that the discount rates and electricity price rates 

associated with only that subgroup were selected in the Monte Carlo simulations (see 

chapter 8 of the NOPR TSD). Another major change from the LCC analysis was an 

added assumption that the subgroups do not have access to national capital markets, 

which results in higher discount rates for the subgroups. The higher discount rates lead

the subgroups valuing more highly upfront equipment purchase costs relative to the 

future operating cost savings. The LCC subgroup analysis is described in chapter 8 of the 

NOPR TSD.

Table V.26Table V.25 presents the comparison of mean LCC savings for the 

small business subgroup in foodservice sector with the national average values (LCC 

savings results from chapter 8 of the NOPR TSD). For almost all TSLs in all equipment 

classes, the LCC savings for the small business subgroup are lower than the national 

average values. The exception is the TSL 5 result for SCU-A-Small-C. Table V.27Table 

270
V.26 presents the percentage change in LCC savings compared to national average 

values. DOE modeled all equipment classes in this analysis, although DOE believes it is 

likely that the very large equipment classes are not commonly used in foodservice 

establishments. For TSLs 1 through 3, the differences range from -2 percent to -6 percent. 

For all but three equipment classes in Table V.27Table V.26, the percentage decrease in 

LCC savings is less than 10 percent for all TSLs. For SCU-W-Large-B, the TSL 4 and 5 

differences were -11 percent. SCU-A-Small-B, the TSL 4 and 5 differences were -17

percent. For IMH-W-Small-B, the TSL 5 difference is -37 percent.

Table V.28Table V.27 presents the comparison of median PBPs for the small 

business subgroup in foodservice sector with national median values (median PBPs from 

chapter 8 of the NOPR TSD). The PBP values are shorter for the small business subgroup 

in all cases. This arises because the first-year operating cost savings—which are used for 

payback period—are higher leading to a shorter payback, but given their higher discount 

rates, these customers value future savings less, leading to lower LCC savings. First-year 

savings are higher because the foodservice electricity prices are higher than the average 

of all classes.

Table V.29Table V.28 presents the comparison of mean LCC savings for the 

small business subgroup in lodging sector (hotels and casinos) with the national average 

values (LCC savings results from chapter 8 of the NOPR TSD). Table V.30Table V.29

presents the percentage change in LCC savings of the lodging sector customer subgroup 

to national average values. For lodging sector small business, LCC savings are lower 

271
across the board. For TSLs 1 through 3, the lodging subgroup LCC savings range from 9

to 13 percent lower. The reason for this is that the energy price for lodging is slightly 

lower than the average of all commercial business types (97 percent of the average). This 

combined with a higher discount rate reduces the nominal value of future operating and 

maintenance benefits as well as the present value of the benefits, thus resulting in lower

LCC savings.

Table V.31Table V.30 presents the comparison of median PBPs for small 

business subgroup in the lodging sector with national median values (median PBPs from 

chapter 8 of the NOPR TSD). The PBP values are slightly higher in the lodging small 

business subgroup in all instances. As noted above, the energy savings would be lower in 

nominal terms than a national average Thus, the slightly lower median PBP appears to be 

a result of a narrower electricity saving results distribution that is close to but below the 

national average.

Table V.26 Comparison of Mean LCC Savings for the Foodservice Sector Small 

Business Subgroup with the National Average Values

Equipment Class Category

Mean LCC Savings 

2012$*

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B Small Business 195 210 312 312 31 

All Business Types 199 215 328 328 49 

IMH-W-Med-B Small Business 455 455 575 390 443 

All Business Types 464 464 587 405 460 

IMH-W-Large-B Small Business 816 816 816 528 559 

All Business Types 833 833 833 550 582 

 IMH-W-Large-B1 Small Business 687 687 687 561 585 

All Business Types 701 701 701 583 607 

 IMH-W-Large-B2 Small Business 1,233 1,233 1,233 419 476 

All Business Types 1,260 1,260 1,260 442 500 

IMH-A-Small-B Small Business 249 253 387 159 185 

All Business Types 254 259 396 170 198 

IMH-A-Large-B Small Business 635 621 1,094 956 956 

All Business Types 648 633 1,127 994 994 

 IMH-A-Large-B1 Small Business 578 561 1,132 1,021 1,021 

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All Business Types 590 572 1,168 1,062 1,062 

 IMH-A-Large-B2 Small Business 941 941 888 604 604 

All Business Types 960 960 908 627 627 

RCU-Large-B Small Business 858 858 963 843 869 

All Business Types 875 875 983 870 897 

 RCU-Large-B1 Small Business 830 830 944 831 855 

All Business Types 847 847 963 857 882 

 RCU-Large-B2 Small Business 1,270 1,270 1,249 1,032 1,084 

All Business Types 1,298 1,298 1,277 1,070 1,123 

SCU-W-Large-B Small Business 455 655 666 126 132 

All Business Types 483 687 694 143 149 

SCU-A-Small-B Small Business 100 194 378 88 88 

All Business Types 103 198 396 106 106 

SCU-A-Large-B Small Business 137 498 483 219 219 

All Business Types 140 522 502 240 240 

IMH-A-Small-C Small Business 308 307 383 296 (238)

All Business Types 315 314 391 307 (237)

IMH-A-Large-C Small Business 647 729 1,006 512 489 

All Business Types 660 744 1,026 524 500 

SCU-A-Small-C Small Business 91 137 143 143 (434)

All Business Types 93 140 146 146 (441)

*Values in parenthesis are negative numbers.

Table V.27 Percentage Change in Mean LCC Savings for the Foodservice Sector 

Small Business Subgroup Compared to National Average Values*

Equipment Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B (2%) (2%) (5%) (5%) (37%)

IMH-W-Med-B (2%) (2%) (2%) (4%) (4%)

IMH-W-Large-B (2%) (2%) (2%) (4%) (4%)

 IMH-W-Large-B1 (2%) (2%) (2%) (4%) (4%)

 IMH-W-Large-B2 (2%) (2%) (2%) (5%) (5%)

IMH-A-Small-B (2%) (2%) (2%) (7%) (6%)

IMH-A-Large-B (2%) (2%) (3%) (4%) (4%)

 IMH-A-Large-B1 (2%) (2%) (3%) (4%) (4%)

 IMH-A-Large-B2 (2%) (2%) (2%) (4%) (4%)

RCU-Large-B (2%) (2%) (2%) (3%) (3%)

 RCU-Large-B1 (2%) (2%) (2%) (3%) (3%)

 RCU-Large-B2 (2%) (2%) (2%) (3%) (3%)

SCU-W-Large-B (6%) (5%) (4%) (11%) (11%)

SCU-A-Small-B (2%) (2%) (5%) (17%) (17%)

SCU-A-Large-B (2%) (4%) (4%) (9%) (9%)

IMH-A-Small-C (2%) (2%) (2%) (3%) 0%

IMH-A-Large-C (2%) (2%) (2%) (2%) (2%)

SCU-A-Small-C (2%) (2%) (2%) (2%) 2%

* Values in parenthesis are negative numbers. Negative percentage values imply 

decrease in LCC savings and positive percentage values imply increase in LCC 

savings.

Table V.28 Comparison of Median Payback Periods for the Foodservice Sector 

Small Business Subgroup with National Median Values

Equipment Class Category

Median Payback Period 

years

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

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IMH-W-Small-B Small Business 1.02 1.20 2.16 2.16 5.14 

All Business Types 1.07 1.26 2.27 2.27 5.42 

IMH-W-Med-B Small Business 0.60 0.60 0.81 3.17 3.06 

All Business Types 0.63 0.63 0.85 3.33 3.22 

IMH-W-Large-B Small Business 0.65 0.65 0.65 3.42 3.42 

All Business Types 0.69 0.69 0.69 3.59 3.60 

 IMH-W-Large-B1 Small Business 0.68 0.68 0.68 3.57 3.59 

All Business Types 0.72 0.72 0.72 3.75 3.77 

 IMH-W-Large-B2 Small Business 0.55 0.55 0.55 2.95 2.88 

All Business Types 0.58 0.58 0.58 3.10 3.02 

IMH-A-Small-B Small Business 1.02 1.16 1.35 4.11 4.03 

All Business Types 1.07 1.22 1.42 4.32 4.24 

IMH-A-Large-B Small Business 0.44 0.47 0.80 2.06 2.06 

All Business Types 0.46 0.49 0.84 2.16 2.16 

 IMH-A-Large-B1 Small Business 0.44 0.48 0.78 1.99 1.99 

All Business Types 0.46 0.50 0.82 2.08 2.08 

 IMH-A-Large-B2 Small Business 0.40 0.40 0.90 2.45 2.45 

All Business Types 0.42 0.42 0.94 2.58 2.58 

RCU-Large-B Small Business 0.39 0.39 0.62 2.27 2.32 

All Business Types 0.41 0.41 0.65 2.39 2.44 

 RCU-Large-B1 Small Business 0.37 0.37 0.59 2.25 2.31 

All Business Types 0.38 0.38 0.62 2.37 2.42 

 RCU-Large-B2 Small Business 0.72 0.72 0.96 2.57 2.57 

All Business Types 0.75 0.75 1.00 2.70 2.70 

SCU-W-Large-B Small Business 0.65 0.73 0.96 2.87 2.86 

All Business Types 0.67 0.76 1.00 3.01 3.00 

SCU-A-Small-B Small Business 1.33 1.44 1.48 4.54 4.54 

All Business Types 1.40 1.52 1.56 4.79 4.79 

SCU-A-Large-B Small Business 1.29 1.11 1.42 3.54 3.54 

All Business Types 1.37 1.17 1.49 3.72 3.72 

IMH-A-Small-C Small Business 0.86 0.86 0.92 2.46 6.38 

All Business Types 0.90 0.90 0.97 2.59 6.83 

IMH-A-Large-C Small Business 0.50 0.50 0.65 3.06 3.05 

All Business Types 0.52 0.53 0.69 3.25 3.24 

SCU-A-Small-C Small Business 1.08 1.45 1.76 1.76 17.09 

All Business Types 1.13 1.53 1.85 1.85 19.12 

Table V.29 Comparison of LCC Savings for the Lodging Sector Small Business 

Subgroup with the National Average Values

Equipment Class Category

Mean LCC Savings 

2012$*

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B Small Business 179 192 285 285 (3)

All Business Types 199 215 328 328 49 

IMH-W-Med-B Small Business 421 421 531 334 382 

All Business Types 464 464 587 405 460 

IMH-W-Large-B Small Business 756 756 756 449 476 

All Business Types 833 833 833 550 582 

 IMH-W-Large-B1 Small Business 635 635 635 484 503 

All Business Types 701 701 701 583 607 

 IMH-W-Large-B2 Small Business 1,144 1,144 1,144 338 390 

All Business Types 1,260 1,260 1,260 442 500 

IMH-A-Small-B Small Business 229 232 354 115 139 

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All Business Types 254 259 396 170 198 

IMH-A-Large-B Small Business 589 575 1,018 862 862 

All Business Types 648 633 1,127 994 994 

 IMH-A-Large-B1 Small Business 536 520 1,056 926 926 

All Business Types 590 572 1,168 1,062 1,062 

 IMH-A-Large-B2 Small Business 873 873 816 521 521 

All Business Types 960 960 908 627 627 

RCU-Large-B Small Business 796 796 890 744 766 

All Business Types 875 875 983 870 897 

 RCU-Large-B1 Small Business 771 771 873 734 754 

All Business Types 847 847 963 857 882 

 RCU-Large-B2 Small Business 1,175 1,175 1,149 891 937 

All Business Types 1,298 1,298 1,277 1,070 1,123 

SCU-W-Large-B Small Business 440 624 626 96 102 

All Business Types 483 687 694 143 149 

SCU-A-Small-B Small Business 92 177 353 55 55 

All Business Types 103 198 396 106 106 

SCU-A-Large-B Small Business 126 470 448 179 179 

All Business Types 140 522 502 240 240 

IMH-A-Small-C Small Business 284 283 352 257 (281)

All Business Types 315 314 391 307 (237)

IMH-A-Large-C Small Business 600 676 929 412 394 

All Business Types 660 744 1,026 524 500 

SCU-A-Small-C Small Business 84 125 128 128 (452)

All Business Types 93 140 146 146 (441)

* Values in parentheses are negative numbers.

Table V.30 Percentage Change in Mean LCC Savings for the Lodging Sector Small 

Business Subgroup Compared to National Average Values*

Equipment Class TSL1 TSL2 TSL3 TSL4 TSL5

IMH-W-Small-B (10%) (10%) (13%) (13%) (107%)

IMH-W-Med-B (9%) (9%) (10%) (18%) (17%)

IMH-W-Large-B (9%) (9%) (9%) (18%) (18%)

 IMH-W-Large-B1 (9%) (9%) (9%) (17%) (17%)

 IMH-W-Large-B2 (9%) (9%) (9%) (24%) (22%)

IMH-A-Small-B (10%) (10%) (11%) (32%) (30%)

IMH-A-Large-B (9%) (9%) (10%) (13%) (13%)

 IMH-A-Large-B1 (9%) (9%) (10%) (13%) (13%)

 IMH-A-Large-B2 (9%) (9%) (10%) (17%) (17%)

RCU-Large-B (9%) (9%) (9%) (15%) (15%)

 RCU-Large-B1 (9%) (9%) (9%) (14%) (15%)

 RCU-Large-B2 (9%) (9%) (10%) (17%) (16%)

SCU-W-Large-B (9%) (9%) (10%) (33%) (32%)

SCU-A-Small-B (11%) (11%) (11%) (49%) (49%)

SCU-A-Large-B (10%) (10%) (11%) (25%) (25%)

IMH-A-Small-C (10%) (10%) (10%) (16%) (18%)

IMH-A-Large-C (9%) (9%) (9%) (21%) (21%)

SCU-A-Small-C (10%) (11%) (12%) (12%) (2%)

*Values in parentheses are negative numbers. Negative percentage values imply 

decrease in LCC savings and positive percentage values imply increase in LCC 

savings.

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Table V.31 Comparison of Median Payback Periods for the Lodging Sector Small 

Business Subgroup with the National Median Values

Equipment Class Category

Median Payback Period 

years

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B Small Business 1.09 1.28 2.27 2.27 5.42

All Business Types 1.07 1.26 2.27 2.27 5.42 

IMH-W-Med-B Small Business 0.64 0.64 0.86 3.38 3.26

All Business Types 0.63 0.63 0.85 3.33 3.22 

IMH-W-Large-B Small Business 0.70 0.70 0.70 3.65 3.65 

All Business Types 0.69 0.69 0.69 3.59 3.60 

 IMH-W-Large-B1 Small Business 0.73 0.73 0.73 3.80 3.83

All Business Types 0.72 0.72 0.72 3.75 3.77 

 IMH-W-Large-B2 Small Business 0.58 0.58 0.58 3.14 3.07

All Business Types 0.58 0.58 0.58 3.10 3.02 

IMH-A-Small-B Small Business 1.08 1.24 1.44 4.39 4.30

All Business Types 1.07 1.22 1.42 4.32 4.24 

IMH-A-Large-B Small Business 0.46 0.50 0.85 2.19 2.19 

All Business Types 0.46 0.49 0.84 2.16 2.16 

 IMH-A-Large-B1 Small Business 0.47 0.51 0.83 2.11 2.11

All Business Types 0.46 0.50 0.82 2.08 2.08 

 IMH-A-Large-B2 Small Business 0.43 0.43 0.96 2.61 2.61

All Business Types 0.42 0.42 0.94 2.58 2.58 

RCU-Large-B Small Business 0.41 0.41 0.66 2.42 2.48 

All Business Types 0.41 0.41 0.65 2.39 2.44 

 RCU-Large-B1 Small Business 0.39 0.39 0.63 2.40 2.46

All Business Types 0.38 0.38 0.62 2.37 2.42 

 RCU-Large-B2 Small Business 0.77 0.77 1.02 2.74 2.74

All Business Types 0.75 0.75 1.00 2.70 2.70 

SCU-W-Large-B Small Business 0.67 0.75 1.01 3.01 3.00

All Business Types 0.67 0.76 1.00 3.01 3.00 

SCU-A-Small-B Small Business 1.42 1.54 1.56 4.79 4.79

All Business Types 1.40 1.52 1.56 4.79 4.79 

SCU-A-Large-B Small Business 1.38 1.17 1.49 3.72 3.72

All Business Types 1.37 1.17 1.49 3.72 3.72 

IMH-A-Small-C Small Business 0.92 0.92 0.99 2.63 6.88

All Business Types 0.90 0.90 0.97 2.59 6.83 

IMH-A-Large-C Small Business 0.53 0.53 0.70 3.28 3.28

All Business Types 0.52 0.53 0.69 3.25 3.24 

SCU-A-Small-C Small Business 1.15 1.55 1.88 1.88 19.13

All Business Types 1.13 1.53 1.85 1.85 19.12 

2. Economic Impacts on Manufacturers

DOE performed an MIA to estimate the impact of amended energy conservation 

standards on manufacturers of automatic commercial ice makers. The following section 

describes the expected impacts on manufacturers at each TSL. Chapter 12 of the NOPR 

TSD explains the analysis in further detail.

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a. Industry Cash Flow Analysis Results

The following tables depict the financial impacts (represented by changes in 

INPV) of amended energy conservation standards on manufacturers of automatic 

commercial ice makers as well as the conversion costs that DOE estimates manufacturers 

would incur for all equipment classes at each TSL. To evaluate the range of cash flow 

impacts on the commercial ice maker industry, DOE used two different markup 

assumptions to model scenarios that correspond to the range of anticipated market 

responses to new and amended energy conservation standards. 

To assess the lower (less severe) end of the range of potential impacts, DOE 

modeled a preservation of gross margin percentage markup scenario, in which a uniform 

“gross margin percentage” markup is applied across all efficiency levels. In this scenario, 

DOE assumed that a manufacturer’s absolute dollar markup would increase as production 

costs increase in the amended energy conservation standards case. Manufacturers have 

indicated that it is optimistic to assume that they would be able to maintain the same 

gross margin percentage markup as their production costs increase in response to a new 

or amended energy conservation standard, particularly at higher TSLs. 

To assess the higher (more severe) end of the range of potential impacts, DOE 

modeled the preservation of the EBIT markup scenario, which assumes that 

manufacturers would not be able to preserve the same overall gross margin, but instead 

cut their markup for marginally compliant products to maintain a cost competitive 

277
product offering and keep the same overall level of EBIT as in the base case. The two 

tables below show the range of potential INPV impacts for manufacturers of automatic 

commercial ice makers. The first table reflects the lower bound of impacts (higher 

profitability) and the second represents the upper bound of impacts (lower profitability).

Each scenario results in a unique set of cash flows and corresponding industry 

values at each TSL. In the following discussion, the INPV results refer to the sum of 

discounted cash flows through 2047, the difference in INPV between the base case and 

each standards case, and the total industry conversion costs required for each standards 

case. 

Table V.32 Manufacturer Impact Analysis for Automatic Commercial Ice Makers -

Preservation of Gross Margin Percentage Markup Scenario*

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV 2012$ Millions $101.8 $93.4 $89.0 $80.9 $82.2 $81.9

Change in INPV 2012$ Millions - $(8.4) $(12.8) $(20.9) $(19.6) $(19.9)

(%) - (8.2)% (12.6)% (20.5)% (19.2)% (19.5)%

Product 

Conversion Costs 2012$ Millions - $17.0 $25.4 $38.3 $44.8 $46.9

Capital 

Conversion Costs 2012$ Millions - $0.4 $1.2 $3.9 $6.4 $7.3

Total Conversion

Costs 2012$ Millions - $17.4 $26.6 $42.2 $51.2 $54.2

* Values in parentheses are negative numbers.

Table V.33 Manufacturer Impact Analysis for Automatic Commercial Ice Makers -

Preservation of EBIT Markup Scenario*

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV 2012$ Millions $101.8 $93.1 $88.2 $77.9 $71.3 $69.2

Change in INPV 2012$ Millions - $(8.7) $(13.6) $(23.9) $(30.5) $(32.6)

(%) - (8.5)% (13.4)% (23.5)% (30.0)% (32.0)%

Product 

Conversion Costs 2012$ Millions - $17.0 $25.4 $38.3 $44.8 $46.9

Capital 

Conversion Costs 2012$ Millions - $0.4 $1.2 $3.9 $6.4 $7.3

Total Conversion 

Costs 2012$ Millions - $17.4 $26.6 $42.2 $51.2 $54.2

* Values in parentheses are negative numbers.

278
Beyond impacts on INPV, DOE includes a comparison of free cash flow between 

the base case and the standards case at each TSL in the year before amended standards 

take effect to provide perspective on the short-run cash flow impacts in the discussion of 

the results below.

At TSL 1, DOE estimates impacts on INPV for manufacturers of automatic 

commercial ice makers to range from -$8.4 million to -$8.7 million, or a change in INPV 

of -8.2 percent to -8.5 percent. At this TSL, industry free cash flow is estimated to 

decrease by approximately 61 percent to $3.3 million, compared to the base-case value of 

$8.4 million in the year before the compliance date (2017).

DOE estimates that approximately 40 percent of all batch commercial ice makers 

and 30 percent of all continuous commercial ice makers on the market will require 

redesign to meet standards at TSL 1. Additionally, for both batch and continuous 

products, the number of products requiring redesign at this TSL is commensurate with 

each manufacturer’s estimated market share. Twelve manufacturers, including three

small businesses, produce equipment that complies with the efficiency levels specified at 

TSL 1.

At TSL 1, the majority of efficiency gains could be made through swapping 

purchased components for higher efficiency equivalents. It is expected that very few 

evaporators and condensers are affected at TSL 1, leading to very low expected industry 

279
capital conversion costs totaling only $0.4 million. However, moderate product 

conversion costs of $17.0 million are expected, as redesigned units will require low levels 

of engineering design labor, as well as testing for equipment certification.

At TSL 2, DOE estimates impacts on INPV for manufacturers of automatic 

commercial ice makers to range from -$12.8 million to -$13.6 million, or a change in 

INPV of -12.6 percent to -13.4 percent. At this TSL, industry free cash flow is estimated 

to decrease by approximately 97 percent to $0.2 million, compared to the base-case value 

of $8.4 million in the year before the compliance date (2017).

At TSL 2, total conversion costs increase to $26.6 million, 53 percent higher than 

those incurred by industry at TSL 1. DOE estimates that approximately 58 percent of all 

units on the market will require redesign to meet the standards outlined at TSL 2. As with 

TSL 1, for batch and continuous commercial ice makers, the number of products 

requiring redesign at this TSL is largely commensurate with each manufacturer’s 

estimated market share. Ten manufacturers, including three small businesses, produce 

equipment that complies with the efficiency levels specified at TSL 2.

The majority of redesigns still rely on switching to higher efficiency components, 

but a limited number of units are expected to require more complex system redesigns 

including the evaporator and condenser. The increased, but moderate, complexity of these 

redesigns causes product conversion costs to grow at a slightly higher rate than the 

additional number of units requiring redesign, resulting in industry-wide product 

280
conversion costs totaling $25.4 million. Capital conversion costs continue to remain 

relatively low at $1.2 million, as most design options considered at TSL 2 can be 

integrated into production without changes to manufacturing capital.

At TSL 3, DOE estimates impacts on INPV for manufacturers of automatic 

commercial ice makers to range from -$20.9 million to -$23.9 million, or a change in 

INPV of -20.5 percent to -23.5 percent. At this TSL, industry free cash flow is estimated 

to decrease by approximately 180 percent to -$6.7 million, compared to the base-case 

value of $8.4 million in the year before the compliance date (2017).

At TSL 3, total conversion costs grow significantly to $42.2 million, an increase 

of 59 percent over those incurred by manufacturers at TSL 2. DOE estimates that 

approximately 88 percent of all batch products and 75 percent of all continuous products 

on the market will require redesign to meet this TSL. Six of the 12 manufacturers of 

batch equipment currently produce batch commercial ice makers that comply with the 

efficiency levels specified at TSL 3. This includes one small business manufacturer. In 

contrast, all six manufacturers of continuous commercial ice makers identified produce 

products that comply with the efficiency levels specified at TSL 3.

The majority of redesigns necessary to meet the standards at TSL 3 involve more 

complex changes to the evaporator and condenser systems. These complex redesigns 

result in product conversion costs increasing at a rate higher than simply the additional 

number of units that require redesign. At TSL 3, the resulting industry product 

281
conversion costs total $38.3 million. Additionally, capital conversion costs jump 

significantly to $3.9 million, as evaporator and condenser redesigns spur investments in 

tooling for both of these components and the surrounding enclosure.

At TSL 4, DOE estimates impacts on INPV for manufacturers of automatic 

commercial ice makers to range from -$19.6 million to -$30.5 million, or a change in 

INPV of -19.2 percent to -30.0 percent. At this TSL, industry free cash flow is estimated 

to decrease by approximately 227 percent to -$10.7 million, compared to the base-case 

value of $8.4 million in the year before the compliance date (2017).

At TSL 4, total conversion costs grow to $51.2 million. Relative to the change 

between TSLs 2 and 3, the increases in conversion costs at TSL 4 are smaller as the 

percentage of batch and continuous units requiring redesign grows to 96 percent and 77 

percent, respectively. These fractions are up from 88 percent and 75 percent, respectively, 

at TSL 3. Only two manufacturers, including one small business manufacturer, currently 

produce batch commercial ice makers that comply with the efficiency levels specified at 

TSL 4. In contrast, all six manufacturers of continuous commercial ice makers identified 

produce products that comply with the efficiency levels specified at TSL 4.

With very few additional units needing redesigns, costs incurred are mainly 

incremental, and account for the increasing complexity of condenser and evaporator 

redesigns. Product conversion costs grow to $44.8 million, 17 percent above those at TSL

3. However, the increasing complexity of redesign does incur greater capital conversion 

282
costs, which grow to $6.4 million as additional capital investments are required to modify 

production lines to manufacture these more complex designs.

At TSL 5, DOE estimates impacts on INPV for manufacturers of automatic 

commercial ice makers to range from -$19.9 million to -$32.6 million, or a change in 

INPV of -19.5 percent to -32.0 percent. At this TSL, industry free cash flow is estimated 

to decrease by approximately 243 percent to -$12.0 million, compared to the base-case 

value of $8.4 million in the year before the compliance date (2017).

As with TSL 4, only two manufacturers, including one small business 

manufacturer, currently produce batch commercial ice makers that comply with the 

efficiency levels specified at TSL 5. For manufacturers of continuous commercial ice 

makers, this number drops from six to four. As compared to the previous increases in 

required efficiency between TSLs, the changes between TSL 4 and TSL 5 are minimal.

As a result, total conversion costs grow only slightly, rising 6 percent to $54.2 million.

This consists of $46.9 million in product conversion costs and $7.3 million in capital 

conversion costs.

b. Impacts on Direct Employment

DOE used the GRIM to estimate the domestic labor expenditures and number of 

domestic production workers in the base case and at each TSL from 2013 to 2047. DOE 

used statistical data from the most recent U.S Census Bureau’s “Annual Survey of 

Manufactures,” the results of the engineering analysis, and interviews with manufacturers 

283
to determine the inputs necessary to calculate industry-wide labor expenditures and 

domestic employment levels. Labor expenditures for the manufacture of a product are a 

function of the labor intensity of the product, the sales volume, and an assumption that 

wages in real terms remain constant.

In the GRIM, DOE used the labor content of each product and the manufacturing 

production costs from the engineering analysis to estimate the annual labor expenditures 

in the automatic commercial ice maker industry. DOE used information gained through 

interviews with manufacturers to estimate the portion of the total labor expenditures that 

is attributable to domestic labor.

The production worker estimates in this section cover workers only up to the linesupervisor level who are directly involved in fabricating and assembling automatic 

commercial ice makers within an original equipment manufacturer (OEM) facility. 

Workers performing services that are closely associated with production operations, such 

as material handling with a forklift, are also included as production labor. 

The employment impacts shown in Table V.34Table V.33 represent the potential 

production employment that could result following new and amended energy 

conservation standards. The upper end of the results in this table estimates the total 

potential increase in the number of production workers after amended energy 

conservation standards. To calculate the total potential increase, DOE assumed that 

manufacturers continue to produce the same scope of covered products in domestic 

284
production facilities and domestic production is not shifted to lower-labor-cost countries. 

Because there is a risk of manufacturers evaluating sourcing decisions in response to 

amended energy conservation standards, the lower end of the range of employment 

results in Table V.34Table V.33 includes the estimated total number of U.S. production 

workers in the industry who could lose their jobs if all existing production were moved 

outside of the United States. While the results present a range of employment impacts 

following the compliance date of amended energy conservation standards, the discussion 

below also includes a qualitative discussion of the likelihood of negative employment 

impacts at the various TSLs. Finally, the employment impacts shown are independent of 

the employment impacts from the broader U.S. economy, which are documented in 

chapter 13 of the NOPR TSD.

DOE estimates that in the absence of amended energy conservation standards, 

there would be 268 domestic production workers involved in manufacturing automatic 

commercial ice makers in 2018. Using 2011 Census Bureau data and interviews with 

manufacturers, DOE estimates that approximately 84 percent of automatic commercial 

ice makers sold in the United States are manufactured domestically. Table V.34Table 

V.33 shows the range of the impacts of potential amended energy conservation standards 

on U.S. production workers in the automatic commercial ice maker industry.

285
Table V.34 Potential Changes in the Total Number of Domestic Automatic 

Commercial Ice Maker Production Workers in 2018

Base 

Case 1 2 3 4 5

Total Number of 

Domestic Production 

Workers in 2018 

(without changes in 

production locations)

268 268 268 269 269 269

Potential Changes in 

Domestic Production 

Workers in 2018*

- 0 - (268) 0 - (268) 1 - (268) 1 - (268) 1 - (268)

*DOE presents a range of potential employment impacts. Values in parentheses are negative numbers. 

All examined TSLs show relatively minor impacts on domestic employment 

levels relative to total industry employment. At all TSLs, most of the design options 

analyzed by DOE do not greatly alter the labor content of the final product. For example, 

the use of a higher efficiency compressors or fan motors involve one-time changes to the 

final product, but do not significantly change the number of steps required for the final 

assembly. One manufacturer suggested that their domestic production employment levels 

would only change if market demand contracted following higher overall prices. 

However, more than one manufacturer suggested that where they already have overseas 

manufacturing capabilities, they would consider moving additional manufacturing to 

those facilities if they felt the need to offset a significant rise in materials costs. Provided 

the changes in materials costs do not support the relocation of manufacturing facilities,

one would expect only modest changes to domestic manufacturing employment 

balancing additional requirements for assembly labor with the effects of price elasticity.

c. Impacts on Manufacturing Capacity 

According to the majority of automatic commercial ice maker manufacturers 

interviewed, amended energy conservation standards that require modest changes to 

286
product efficiency will not significantly affect manufacturers’ production capacities. Any 

redesign of automatic commercial ice makers would not change the fundamental 

assembly of the equipment, but manufacturers do anticipate some potential for additional 

lead time immediately following standards associated with changes in sourcing of higher 

efficiency components, which may be supply constrained.

One manufacturer cited the possibility of a 3- to 6-month shutdown in the event 

that amended standards were set high enough to require retooling of their entire product 

line. Most of the design options being evaluated are already available on the market as 

product options. Thus, DOE believes that short of widespread retooling, manufacturers 

would be able to maintain manufacturing capacity levels and continue to meet market 

demand under amended energy conservation standards.

d. Impacts on Subgroups of Manufacturers

Small business, low volume, and niche equipment manufacturers, and 

manufacturers exhibiting a cost structure substantially different from the industry average 

could be affected disproportionately. As discussed in section IV.J, using average cost 

assumptions to develop an industry cash flow estimate is inadequate to assess differential 

impacts among manufacturer subgroups. 

For automatic commercial ice makers, DOE identified and evaluated the impact 

of amended energy conservation standards on one subgroup: small manufacturers. The 

SBA defines a “small business” as having 750 employees or less for NAICS 333415, 

287
“Air-Conditioning and Warm Air Heating Equipment and Commercial and Industrial 

Refrigeration Equipment Manufacturing,” which includes ice-making machinery 

manufacturing. Based on this definition, DOE identified seven manufacturers in the 

automatic commercial ice makers industry that are small businesses.

For a discussion of the impacts on the small manufacturer subgroup, see the 

regulatory flexibility analysis in section VI.B of this notice and chapter 12 of the NOPR 

TSD. 

e. Cumulative Regulatory Burden

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of recent or impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or an entire industry. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. In addition 

to energy conservation standards, other regulations can significantly affect 

manufacturers’ financial operations. Multiple regulations affecting the same 

manufacturer can strain profits and lead companies to abandon product lines or markets 

with lower expected future returns than competing products. For these reasons, DOE 

conducts an analysis of cumulative regulatory burden as part of its rulemakings 

pertaining to equipment efficiency. 

During previous stages of this rulemaking, DOE identified a number of 

requirements in addition to amended energy conservation standards for automatic 

288
commercial ice makers. The following section briefly addresses comments DOE received 

with respect to cumulative regulatory burden and summarizes other key related concerns 

that manufacturers raised during interviews.

Existing Federal Standards for Automatic Commercial Ice Makers

Several manufacturers commented that they had made substantial investments in 

order to comply with the previous Federal energy conservation standards for batch style 

automatic commercial ice makers, which took effect in January 2010. While DOE 

acknowledges the significant investment on the part of industry, because the proposed 

compliance date for new and amended standards is 2018, there should be no direct 

overlap of compliance costs from either standard. The residual financial impact of the 

previous energy conservation standards manifest themselves in the 2018 standards MIA 

as the prevailing industry conditions absent new or amended energy conservation 

standards. This serves as the basis for the base-case INPV. 

Certification, Compliance, and Enforcement (CC&E) Rule

Multiple manufacturers expressed concerns about the burden CC&E would 

impose on the automatic commercial ice maker industry. CC&E requires testing and 

compliance for a wide array of equipment offerings. One manufacturer cited the increase 

in testing burden associated with the DOE’s new definition of “basic” model, which has 

contributed significantly to the number of models considered to be basic. Manufacturers 

worry that testing each variation would present a significant testing burden, especially for 

small business manufacturers. 

289
In addition to costs associated with DOE CC&E requirements, manufacturers 

cited an array of other certifications as being an additional and substantial burden. Such 

certifications include codes and standards developed by American Society of Mechanical 

Engineers (ASME), which include standards for compressors, fasteners, flow 

measurement, nuclear, environmental control, piping, pressure vessels, pumps, storage 

tanks, and more.68 Other critical certification programs for manufacturers of automatic 

commercial ice makers include those of National Sanitation Foundation (NSF), 

Underwriters Laboratories (UL), NRCan, and CEC. A new energy efficiency standard put 

forth by the DOE that requires a complete product redesign will necessitate recertification 

from the above-mentioned programs. Manufacturers are concerned about the cumulative 

testing burden associated with such re-certifications.

DOE understands that testing and certification requirements may have a 

significant impact on manufacturers, and the CC&E burden is identified as a key issue in 

the MIA. DOE also understands that CC&E requirements can be particularly onerous for 

manufacturers producing low volume or highly customized equipment. Regarding other 

certification programs, the DOE again acknowledges the potential burden associated with 

recertification. However, DOE also recognizes that these programs are voluntary.

EPA and ENERGY STAR

68 Information about ASME codes and standards can be obtained at: www.asme.org/kb/standards/standards.

290

 
Some manufacturers expressed concerns regarding potential conflicts with the 

ENERGY STAR certification program. Manitowoc publicly commented that certification 

by the ENERGY STAR program is very important to their customers for a variety of 

reasons including the potential for utility rebates and LEED certification. Manitowoc 

went on to say that if DOE’s energy efficiency standard level is raised to the max-tech 

level, there would be no room for the ENERGY STAR classification and that this could 

be highly disruptive to the industry (Manitowoc, No. 42 at pp. 15-16). Due to the clear 

market value of the ENERGY STAR program, manufacturers expressed concern about 

the additional testing burdens associated with having to re-certify products, or 

alternatively, having to forfeit market share by offering products that are not ENERGY 

STAR certified.

DOE realizes that the cumulative effect of several regulations on an industry may 

significantly increase the burden faced by manufacturers that need to comply with 

multiple regulations and certification programs from different organizations and levels of 

government. However, DOE notes that certain standards, such as ENERGY STAR, are 

optional for manufacturers. 

Other Federal Regulations

Manufacturers also expressed concerns regarding the additional burden caused by 

other Federal regulations, including the upcoming amended energy conservation 

standards for residential refrigerators and freezers, commercial refrigeration equipment, 

291
walk-in coolers and freezers, miscellaneous residential refrigeration products, and 

cooking products. 

DOE recognizes the additional burden faced by manufacturers that produce both 

automatic commercial ice makers in combination with one or many of the abovementioned products. Companies that produce a wide range of regulated equipment may 

be faced with more capital and equipment design development expenditures than 

competitors with a narrower scope of production. DOE does attempt to quantify the 

cumulative burden of Federal energy conservation standards on manufacturers in its 

manufacturer impact analysis (see chapter 12 of TSD). However, DOE cannot consider 

the quantitative impacts of amended standards that have not yet been finalized, such as 

those for walk-in coolers and walk-in freezers. 

State Regulations

Relating to the CEC codes and standards, one manufacturer noted California’s 

2020 energy policy goals, including the reduction of greenhouse gas emissions to 1990 

levels, as a source of additional burden for automatic commercial ice maker

manufacturers. Manufacturers also added that the lead limit guidelines (see, for example, 

section 4-101.13(C) of the Food Code 201369) put forth by the U.S. Food and Drug 

Administration (FDA), and adopted as code by all 50 states70, carry associated 

69 http://www.fda.gov/Food/GuidanceRegulation/RetailFoodProtection/FoodCode/ucm374275.htm) 70

http://www.fda.gov/downloads/Food/GuidanceRegulation/RetailFoodProtection/FederalStateCooperativePr

ograms/UCM230336.pdf

292

 
compliance costs. The levels specified by these guidelines have remained unchanged for 

at least 15 years.

International Regulations

Finally, one manufacturer noted additional burden associated with the European 

Union (EU) Restriction on Hazardous Substances Directive (RoHS), which restricts the 

use of six hazardous materials, including lead, mercury, and cadmium, in the manufacture 

of various types of electronic and electrical equipment.71

DOE discusses these and other requirements, and includes the full details of the 

cumulative regulatory burden analysis, in chapter 12 of the NOPR TSD.

3. National Impact Analysis

a. Amount and Significance of Energy Savings

DOE estimated the NES by calculating the difference in annual energy 

consumption for the base-case scenario and standards-case scenario at each TSL for each 

equipment class and summing up the annual energy savings for the automatic commercial 

ice maker equipment purchased during the 30-year 2018 to 2047 analysis period. Energy 

impacts include the 30-year period, plus the life of equipment purchased in the last year 

of the analysis, or roughly 2018 to 2057. The energy consumption calculated in the NIA 

is full-fuel-cycle (FFC) energy, which quantifies savings beginning at the source of 

energy production. DOE also reports primary or source energy that takes into account 

71 Information on EU RoHS can be found at: www.bis.gov.uk/nmo/enforcement/rohs-home.

293

 
losses in the generation and transmission of electricity. FFC and primary energy are

discussed in section IV.H.

Table V.35Table V.34 presents the source NES for all equipment classes at each 

TSL and the sum total of NES for each TSL. Table V.36Table V.35 presents the energy 

savings at each TSL for each equipment class in the form of percentage of the cumulative 

energy use of the equipment stock in the base-case scenario. 

Table V.35 Cumulative National Energy Savings at Source for Equipment 

Purchased in 2018–2047

Equipment Class Standard Level*,

**

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 0.002 0.004 0.010 0.010 0.013

IMH-W-Med-B 0.006 0.006 0.009 0.013 0.014 

IMH-W-Large-B*** 0.001 0.001 0.001 0.002 0.003

 IMH-W-Large-B1 0.001 0.001 0.001 0.002 0.002 

 IMH-W-Large-B2 0.000 0.000 0.000 0.001 0.001 

IMH-A-Small-B 0.017 0.032 0.076 0.099 0.105

IMH-A-Large-B*** 0.024 0.045 0.095 0.122 0.122

 IMH-A-Large-B1 0.020 0.040 0.086 0.107 0.107

 IMH-A-Large-B2 0.005 0.005 0.009 0.015 0.015 

RCU-Large-B*** 0.013 0.013 0.030 0.046 0.047

 RCU-Large-B1 0.012 0.012 0.028 0.043 0.045

 RCU-Large-B2 0.001 0.001 0.002 0.003 0.003 

SCU-W-Large-B 0.000 0.000 0.000 0.000 0.000 

SCU-A-Small-B 0.002 0.013 0.024 0.037 0.037

SCU-A-Large-B 0.002 0.010 0.017 0.022 0.022

IMH-A-Small-C 0.002 0.003 0.005 0.008 0.012

IMH-A-Large-C 0.001 0.003 0.006 0.008 0.008 

SCU-A-Small-C 0.001 0.004 0.007 0.007 0.011 

Total 0.072 0.134 0.281 0.374 0.395

*A value equal to 0.000 means the NES rounds to less than 0.001 quads.

**Numbers may not add to totals due to rounding.

***IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for 

the 2 typical units denoted by B1 and B2.

Table V.36 Cumulative Energy Savings by TSL as a Percentage of Cumulative 

Baseline Energy Usage of Automatic Commercial Ice Maker Equipment Purchased 

in 2018-2047

Equipment Class

Base Case

Energy 

Usage

TSL Savings as Percent of Baseline Usage

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 0.062 4% 7% 16% 16% 21%

IMH-W-Med-B 0.089 6% 6% 10% 15% 16%

294
IMH-W-Large-B* 0.026 6% 6% 6% 9% 10%

 IMH-W-Large-B1 0.017 7% 7% 7% 10% 11%

 IMH-W-Large-B2 0.009 3% 3% 3% 7% 8%

IMH-A-Small-B 0.463 4% 7% 16% 21% 23%

IMH-A-Large-B* 0.635 4% 7% 15% 19% 19%

 IMH-A-Large-B1 0.490 4% 8% 17% 22% 22%

 IMH-A-Large-B2 0.145 3% 3% 6% 11% 11%

RCU-Large-B* 0.357 4% 4% 8% 13% 13%

 RCU-Large-B1 0.333 4% 4% 8% 13% 13%

 RCU-Large-B2 0.024 2% 2% 7% 11% 11%

SCU-W-Large-B 0.003 2% 5% 9% 14% 14%

SCU-A-Small-B 0.138 1% 9% 18% 27% 27%

SCU-A-Large-B 0.092 2% 10% 19% 24% 24%

IMH-A-Small-C 0.068 2% 5% 8% 12% 17%

IMH-A-Large-C 0.041 4% 6% 14% 19% 19%

SCU-A-Small-C 0.073 2% 6% 9% 9% 16%

Total 2.047 4% 7% 14% 18% 19%

*IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the 2 typical 

units denoted by B1 and B2.

Table V.37Table V.36 presents energy savings at each TSL for each equipment 

class with the FFC adjustment. The NES increases from 0.073 quads at TSL 1 to 0.401

quads at TSL 5.

Table V.37 Cumulative National Energy Savings including Full-Fuel-Cycle for 

Equipment Purchased in 2018-2047

Equipment Class Standard Level*,

**

TSL 1 TSL 2 TSL 3 TSL 4 TS L5

IMH-W-Small-B 0.002 0.004 0.010 0.010 0.013 

IMH-W-Med-B 0.006 0.006 0.009 0.014 0.015

IMH-W-Large-B*** 0.001 0.001 0.001 0.002 0.003 

 IMH-W-Large-B1 0.001 0.001 0.001 0.002 0.002 

 IMH-W-Large-B2 0.000 0.000 0.000 0.001 0.001 

IMH-A-Small-B 0.017 0.033 0.077 0.100 0.107

IMH-A-Large-B*** 0.025 0.045 0.096 0.124 0.124

 IMH-A-Large-B1 0.020 0.041 0.087 0.108 0.108

 IMH-A-Large-B2 0.005 0.005 0.009 0.016 0.016

RCU-Large-B*** 0.013 0.013 0.030 0.046 0.048

 RCU-Large-B1 0.013 0.013 0.029 0.044 0.045

 RCU-Large-B2 0.001 0.001 0.002 0.003 0.003 

SCU-W-Large-B 0.000 0.000 0.000 0.000 0.000 

SCU-A-Small-B 0.002 0.013 0.025 0.038 0.038

SCU-A-Large-B 0.002 0.010 0.018 0.022 0.022

IMH-A-Small-C 0.002 0.003 0.006 0.008 0.012

IMH-A-Large-C 0.001 0.003 0.006 0.008 0.008 

SCU-A-Small-C 0.001 0.004 0.007 0.007 0.012

Total 0.073 0.136 0.286 0.380 0.401

*A value equal to 0.000 means the NES rounds to less than 0.001 quads.

**Numbers may not add to totals due to rounding.

***IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results 

for the 2 typical units denoted by B1 and B2.

295
Circular A-4 requires agencies to present analytical results, including separate 

schedules of the monetized benefits and costs that show the type and timing of benefits 

and costs. Circular A-4 also directs agencies to consider the variability of key elements 

underlying the estimates of benefits and costs. For this rulemaking, DOE undertook a 

sensitivity analysis using 9 rather than 30 years of product shipments. The choice of a 9-

year period is a proxy for the timeline in EPCA for the review of certain energy 

conservation standards and potential revision of and compliance with such revised 

standards.72 ThisWe would note that the review timeframe mayestablished in EPCA 

generally does not be statistically relevantoverlap with regard to the product lifetime, 

product manufacturing cycles or other factors specific to automatic commercial ice 

makers. Thus, this information is presented for informational purposes only and is not 

indicative of any change in DOE’s analytical methodology. The NES results based on a 

9-year analysis period are presented in Table V.38Table V.37. The impacts are counted 

over the lifetime of equipment purchased in 2018–2026

Table V.38 National Full-Fuel-Cycle Energy Savings for 9-year Analysis Period for 

Equipment Purchased in 2018–2026

Equipment Class Standard Level*,

**

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 0.001 0.001 0.003 0.003 0.004 

IMH-W-Med-B 0.002 0.002 0.003 0.004 0.004 

IMH-W-Large-B*** 0.000 0.000 0.000 0.001 0.001 

 IMH-W-Large-B1 0.000 0.000 0.000 0.000 0.001 

 IMH-W-Large-B2 0.000 0.000 0.000 0.000 0.000 

72 For automatic commercial ice makers, DOE is required to review standards at least every five years after 

the effective date of any amended standards. (42 U.S.C. 6313(d)(3)(B)) If new standards are promulgated, 

EPCA requires DOE to provide manufacturers a minimum of 3 and a maximum of 5 years to comply with 

the standards. (42 U.S.C. 6313(d)(3)(C)) In addition, for certain other types of commercial equipment that 

are not specified in 42 U.S.C. 6311(1)(B)-(G), EPCA requires DOE to review its standards at least once 

every 6 years (42 U.S.C. 6295(m)(1) and 6316(a)), and either a 3-year or a 5-year period after any new 

standard is promulgated before compliance is required. (42 U.S.C. 6295(m)(4) and 6316(a)) As a result, 

DOE’s standards for automatic commercial ice makers can be expected to be in effect for 8 to 10 years 

between compliance dates, and its standards governing certain other commercial equipment, the period is 9 

to 11 years. A 9-year analysis was selected as representative of the time between standard revisions.

Comment [fp28]: Change requested by OIRA

Comment [fp29]: Change requested by OIRA.

296

 
IMH-A-Small-B 0.005 0.009 0.021 0.028 0.029

IMH-A-Large-B*** 0.007 0.012 0.026 0.034 0.034

 IMH-A-Large-B1 0.005 0.011 0.024 0.030 0.030

 IMH-A-Large-B2 0.001 0.001 0.003 0.004 0.004 

RCU-Large-B*** 0.004 0.004 0.008 0.013 0.013

 RCU-Large-B1 0.003 0.003 0.008 0.012 0.012

 RCU-Large-B2 0.000 0.000 0.000 0.001 0.001 

SCU-W-Large-B 0.000 0.000 0.000 0.000 0.000 

SCU-A-Small-B 0.000 0.004 0.007 0.010 0.010

SCU-A-Large-B 0.001 0.003 0.005 0.006 0.006 

IMH-A-Small-C 0.000 0.001 0.002 0.002 0.003 

IMH-A-Large-C 0.000 0.001 0.002 0.002 0.002 

SCU-A-Small-C 0.000 0.001 0.002 0.002 0.003 

Total 0.020 0.037 0.079 0.104 0.110

*A value equal to 0.000 means the NES rounds to less than 0.001 quads.

**Numbers may not add to totals due to rounding.

***IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for the 

2 typical units denoted by B1 and B2.

b. Net Present Value of Customer Costs and Benefits

DOE estimated the cumulative NPV to the Nation of the total savings for the 

customers that would result from potential standards at each TSL. In accordance with 

OMB guidelines on regulatory analysis (OMB Circular A-4, section E, September 17, 

2003), DOE calculated NPV using both a 7-percent and a 3-percent real discount rate. 

The 7-percent rate is an estimate of the average before-tax rate of return on private capital 

in the U.S. economy, and reflects the returns on real estate and small business capital, 

including corporate capital. DOE used this discount rate to approximate the opportunity 

cost of capital in the private sector, because recent OMB analysis has found the average 

rate of return on capital to be near this rate. In addition, DOE used the 3-percent rate to 

capture the potential effects of amended standards on private consumption. This rate 

represents the rate at which society discounts future consumption flows to their present 

value. It can be approximated by the real rate of return on long-term government debt 

(i.e., yield on Treasury notes minus annual rate of change in the CPI), which has 

averaged about 3 percent on a pre-tax basis for the last 30 years.

297
Table V.39Table V.38 and Table V.40Table V.39 show the customer NPV results 

for each of the TSLs DOE considered for automatic commercial ice makers at both 7-

percent and 3-percent discount rates. In each case, the impacts cover the expected 

lifetime of equipment purchased from 2018–2047. Detailed NPV results are presented in 

chapter 10 of the NOPR TSD.

The NPV results at a 7-percent discount rate for TSL 5 were negative for three 

equipment classes and significantly lower than the TSL 3 results for several other classes. 

This is consistent with the results of LCC analysis results for TSL 5, which showed 

significant increase in LCC and significantly higher PBPs that were in some cases greater 

than the average equipment lifetimes. Efficiency levels for TSL 4 were chosen to 

correspond to the highest efficiency level with a positive NPV for all classes at a 7-

percent discount rate. Similarly, the criteria for choice of efficiency levels for TSL 3, 

TSL 2, and TSL 1 were such that the NPV values for all the equipment classes show 

positive values. The criterion for TSL 3 was to select efficiency levels with the highest 

NPV at a 7-percent discount rate. Consequently, the total NPV for automatic commercial 

ice makers was highest for TSL 3, with a value of $0.791 billion (2012$) at a 7-percent 

discount rate. TSL 4 showed the second highest total NPV, with a value of $0.484 billion

(2012$) at a 7-percent discount rate. TSL 1, TSL 2 and TSL 5 have a total NPV lower 

than TSL 3 or 4.

Table V.39 Net Present Value at a 7-percent Discount Rate for Equipment 

Purchased in 2018-2047 (2012$)

Equipment Class Standard Level*

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

298
IMH-W-Small-B 0.006 0.011 0.025 0.025 (0.002)

IMH-W-Med-B 0.016 0.016 0.025 0.017 0.019

IMH-W-Large-B** 0.004 0.004 0.004 0.003 0.003

 IMH-W-Large-B1 0.003 0.003 0.003 0.002 0.002

 IMH-W-Large-B2 0.001 0.001 0.001 0.001 0.001

IMH-A-Small-B 0.043 0.080 0.177 0.046 0.058

IMH-A-Large-B** 0.070 0.127 0.297 0.256 0.256

 IMH-A-Large-B1 0.057 0.113 0.274 0.236 0.236

 IMH-A-Large-B2 0.014 0.014 0.023 0.020 0.020

RCU-Large-B** 0.038 0.038 0.082 0.073 0.075

 RCU-Large-B1 0.036 0.036 0.078 0.070 0.072

 RCU-Large-B2 0.002 0.002 0.004 0.004 0.004

SCU-W-Large-B 0.001 0.001 0.001 0.000 0.000

SCU-A-Small-B 0.004 0.029 0.085 0.012 0.012

SCU-A-Large-B 0.004 0.039 0.052 0.021 0.021

IMH-A-Small-C 0.004 0.009 0.014 0.011 (0.018)

IMH-A-Large-C 0.004 0.007 0.016 0.007 0.007

SCU-A-Small-C 0.004 0.009 0.013 0.013 (0.062)

Total 0.198 0.368 0.791 0.484 0.370

*A value equal to 0.000 means the NPV rounds to less than $0.001 (2012$). Values in 

parentheses are negative numbers.

**IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for 

the 2 typical units denoted by B1 and B2.

Table V.40 Net Present Value at a 3-percent Discount Rate for Equipment 

Purchased in 2018-2047 (2012$)

Equipment Class Standard Level*

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 0.013 0.023 0.057 0.057 0.010

IMH-W-Med-B 0.034 0.034 0.054 0.042 0.047

IMH-W-Large-B** 0.009 0.009 0.009 0.007 0.008

 IMH-W-Large-B1 0.007 0.007 0.007 0.006 0.006 

 IMH-W-Large-B2 0.002 0.002 0.002 0.001 0.002

IMH-A-Small-B 0.094 0.176 0.394 0.163 0.190

IMH-A-Large-B** 0.152 0.275 0.653 0.596 0.596

 IMH-A-Large-B1 0.123 0.245 0.602 0.546 0.546

 IMH-A-Large-B2 0.030 0.030 0.051 0.050 0.050

RCU-Large-B** 0.081 0.081 0.178 0.174 0.179

 RCU-Large-B1 0.078 0.078 0.169 0.165 0.170

 RCU-Large-B2 0.004 0.004 0.009 0.009 0.009

SCU-W-Large-B 0.001 0.002 0.002 0.001 0.001 

SCU-A-Small-B 0.009 0.064 0.190 0.062 0.062

SCU-A-Large-B 0.010 0.086 0.118 0.062 0.062

IMH-A-Small-C 0.009 0.019 0.031 0.027 (0.028)

IMH-A-Large-C 0.009 0.016 0.034 0.018 0.018

SCU-A-Small-C 0.008 0.021 0.030 0.030 (0.114)

Total 0.430 0.806 1.751 1.238 1.032

*A value equal to 0.000 means the NPV rounds to less than $0.001 (2012$). Values in 

parentheses are negative numbers.

**IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B results are the sum of the results for 

the 2 typical units denoted by B1 and B2.

299
The NPV results based on the aforementioned 9-year analysis period are 

presented in Table V.41Table V.40 and Table V.42Table V.41. The impacts are counted 

over the lifetime of equipment purchased in 2018–2026. As mentioned previously, this 

information is presented for informational purposes only and is not indicative of any 

change in DOE’s analytical methodology or decision criteria.

Table V.41 Net Present Value at a 7-percent Discount Rate for 9-Year Analysis 

Period for Equipment Purchased in 2018–2026

Equipment Class Standard Level*

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 0.003 0.005 0.012 0.012 (0.001)

IMH-W-Med-B 0.008 0.008 0.012 0.008 0.009

IMH-W-Large-B 0.002 0.002 0.002 0.001 0.002 

 IMH-W-Large-B-1 0.002 0.002 0.002 0.001 0.001

 IMH-W-Large-B-2 0.000 0.000 0.000 0.000 0.000

IMH-A-Small-B 0.021 0.039 0.086 0.023 0.029

IMH-A-Large-B 0.034 0.062 0.143 0.123 0.123

 IMH-A-Large-B-1 0.028 0.055 0.132 0.113 0.113

 IMH-A-Large-B-2 0.007 0.007 0.011 0.010 0.010

RCU-Large-B 0.018 0.018 0.040 0.036 0.037 

 RCU-Large-B-1 0.017 0.017 0.038 0.034 0.035 

 RCU-Large-B-2 0.001 0.001 0.002 0.002 0.002

SCU-W-Large-B 0.000 0.000 0.001 0.000 0.000

SCU-A-Small-B 0.002 0.014 0.040 0.005 0.005

SCU-A-Large-B 0.002 0.018 0.025 0.010 0.010

IMH-A-Small-C 0.002 0.004 0.007 0.005 (0.009)

IMH-A-Large-C 0.002 0.004 0.008 0.003 0.003

SCU-A-Small-C 0.002 0.005 0.006 0.006 (0.031)

Total 0.096 0.179 0.381 0.233 0.177

*A value equal to 0.000 means the NPV rounds to less than $0.001 (2012$). Values in 

parentheses are negative numbers.

Table V.42 Net Present Value at a 3-percent Discount Rate for 9-Year Analysis 

Period for Equipment Purchased in 2018–2026

Equipment Class Standard Level*

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 0.005 0.008 0.020 0.020 0.003

IMH-W-Med-B 0.012 0.012 0.019 0.015 0.017 

IMH-W-Large-B 0.003 0.003 0.003 0.003 0.003 

 IMH-W-Large-B-1 0.002 0.002 0.002 0.002 0.002 

 IMH-W-Large-B-2 0.001 0.001 0.001 0.001 0.001 

IMH-A-Small-B 0.034 0.063 0.141 0.058 0.068

IMH-A-Large-B 0.054 0.098 0.230 0.209 0.209

 IMH-A-Large-B-1 0.044 0.088 0.211 0.191 0.191

 IMH-A-Large-B-2 0.011 0.011 0.018 0.018 0.018 

300
RCU-Large-B 0.029 0.029 0.064 0.062 0.064

 RCU-Large-B-1 0.028 0.028 0.060 0.059 0.061

 RCU-Large-B-2 0.001 0.001 0.003 0.003 0.003 

SCU-W-Large-B 0.000 0.001 0.001 0.000 0.000 

SCU-A-Small-B 0.003 0.023 0.065 0.020 0.020

SCU-A-Large-B 0.003 0.030 0.041 0.021 0.021

IMH-A-Small-C 0.003 0.007 0.011 0.010 (0.010)

IMH-A-Large-C 0.003 0.006 0.012 0.006 0.006 

SCU-A-Small-C 0.003 0.007 0.010 0.010 (0.042)

Total 0.153 0.287 0.617 0.434 0.359

*A value equal to 0.000 means the NPV rounds to less than $0.001 (2012$). Values in 

parentheses are negative numbers.

c. Water Savings

In analyzing energy-saving design options for batch type ice makers, one option 

had the additional impact of reducing potable water usage for some types of batch type 

ice makers. The potable water savings are identified on Table V.43Table V.42. 

Table V.43 Potable Water Savings

Equipment Class National Water Savings by Standard Level*,

**

million gallons

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

IMH-W-Small-B 0 0 3,699 3,699 3,699

IMH-W-Med-B 0 0 0 0 0

IMH-W-Large-B 0 0 0 0 0

 IMH-W-Large-B-1 0 0 0 0 0

 IMH-W-Large-B-2 0 0 0 0 0

IMH-A-Small-B 0 0 0 0 0

IMH-A-Large-B 0 0 20,753 20,753 20,753

 IMH-A-Large-B-1 0 0 20,753 20,753 20,753

 IMH-A-Large-B-2 0 0 0 0 0

RCU-***-Large-B 0 0 0 0 0

 RCU-***-Large-B-1 0 0 0 0 0

 RCU-***-Large-B-2 0 0 0 0 0

SCU-W-Large-B 141 141 141 141 141

SCU-A-Small-B 0 0 14,391 14,391 14,391

SCU-A-Large-B 0 6,424 6,424 6,424 6,424

IMH-A-Small-C 0 0 0 0 0

IMH-A-Large-C 0 0 0 0 0

SCU-A-Small-C 0 0 0 0 0

Total 141 6,565 45,407 45,407 45,407

301
d. Employment Impacts

In addition to the direct impacts on manufacturing employment discussed in 

section V.B.2, DOE develops general estimates of the indirect employment impacts of 

proposed standards on the economy. As discussed above, DOE expects amended energy 

conservation standards for automatic commercial ice makers to reduce energy bills for 

commercial customers, and the resulting net savings to be redirected to other forms of 

economic activity. DOE also realizes that these shifts in spending and economic activity 

by automatic commercial ice maker owners could affect the demand for labor. Thus, 

indirect employment impacts may result from expenditures shifting between goods (the 

substitution effect) and changes in income and overall expenditure levels (the income 

effect) that occur due to the imposition of amended standards. These impacts may affect a 

variety of businesses not directly involved in the decision to make, operate, or pay the 

utility bills for automatic commercial ice makers. To estimate these indirect economic 

effects, DOE used an input/output model of the U.S. economy using U.S. Department of 

Commerce, Bureau of Economic Analysis (BEA) and BLS data (as described in section 

IV.N of this notice; see chapter 16 of the NOPR TSD for more details).

In this input/output model, the dollars saved on utility bills from more-efficient 

automatic commercial ice makers are concentrated in economic sectors that create more 

jobs than are lost in electric and water utilities sectors when spending is shifted from 

electricity and/or water to other products and services. Thus, the proposed amended 

energy conservation standards for automatic commercial ice makers are likely to slightly 

increase the net demand for labor in the economy. However, the net increase in jobs 

302
might be offset by other, unanticipated effects on employment. Neither the BLS data nor 

the input/output model used by DOE includes the quality of jobs. As shown in Table 

V.44Table V.43, DOE estimates that net indirect employment impacts from a proposed 

automatic commercial ice makers amended standard are small relative to the national 

economy. 

Table V.44 Net Short-Term Change in Employment

Trial Standard Level 2018 2022

1 19 to 20 100 to 101

2 36 to 40 192 to 196

3 75 to 87 431 to 442

4 44 to 91 506 to 552

5 34 to 90 518 to 572

4. Impact on Utility or Performance of Equipment

In performing the engineering analysis, DOE considers design options that would 

not lessen the utility or performance of the individual classes of equipment. (42 U.S.C. 

6295(o)(2)(B)(i)(IV) and 6316(e)(1)) As presented in the screening analysis (chapter 4 of 

the NOPR TSD), DOE eliminates from consideration any design options that reduce the 

utility of the equipment. For this notice, DOE proposes that none of the TSLs considered

for automatic commercial ice makers reduce the utility or performance of the equipment. 

5. Impact of Any Lessening of Competition

EPCA directs DOE to consider any lessening of competition likely to result from 

amended standards. It directs the Attorney General of the United States (Attorney 

General) to determine in writing the impact, if any, of any lessening of competition likely 

to result from a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)(V) and 6313(d)(4)) To 

assist the Attorney General in making such a determination, DOE provided the DOJ with 

303
copies of this notice and the TSD for review. During MIA interviews, domestic 

manufacturers indicated that foreign manufacturers have begun to enter the automatic 

commercial ice maker industry, but not in significant numbers. Manufacturers also stated 

that consolidation has occurred among automatic commercial ice makers manufacturers 

in recent years. Interviewed manufacturers believe that these trends may continue in this 

market even in the absence of amended standards.

DOE does not believe that amended standards would result in domestic firms 

moving their production facilities outside the United States. The majority of automatic 

commercial ice makers are manufactured in the United States and, during interviews, 

manufacturers in general indicated they would modify their existing facilities to comply 

with amended energy conservation standards.

6. Need of the Nation to Conserve Energy

An improvement in the energy efficiency of the equipment subject to today’s 

NOPR is likely to improve the security of the Nation’s energy system by reducing overall 

demand for energy. Reduced electricity demand may also improve the reliability of the 

electricity system. As a measure of this reduced demand, chapter 15 in the NOPR TSD 

presents the estimated reduction in national generating capacity for the TSLs that DOE 

considered in this rulemaking.

Energy savings from amended standards for automatic commercial ice makers

could also produce environmental benefits in the form of reduced emissions of air 

304
pollutants and GHGs associated with electricity production. Table V.45Table V.44

provides DOE’s estimate of cumulative CO2, NOx, Hg, N2O, CH4 and SO2 emissions 

reductions projected to result from the TSLs considered in this rule. The table includes 

both power sector emissions and upstream emissions. The upstream emissions were 

calculated using the multipliers discussed in section IV.K. DOE reports annual emissions 

reductions for each TSL in chapter 13 of the NOPR TSD. 

Table V.45 Summary of Emissions Reduction Estimated for Automatic Commercial 

Ice Makers TSLs (Cumulative for Equipment Purchased in 2018–2047)

TSL

1 2 3 4 5

Power Sector and Site Emissions

CO2 (million metric tons) 3.50 6.52 13.68 18.19 19.19

NOx (thousand tons) -0.89 -1.66 -3.49 -4.64 -4.89

Hg (tons) 0.01 0.01 0.02 0.03 0.03

N2O (thousand tons) 0.08 0.15 0.31 0.41 0.43

CH4 (thousand tons) 0.47 0.88 1.84 2.45 2.58

SO2 (thousand tons) 5.31 9.89 20.76 27.60 29.12

Upstream Emissions

CO2 (million metric tons) 0.23 0.42 0.89 1.18 1.24

NOx (thousand tons) 3.11 5.80 12.18 16.19 17.08

Hg (tons) 0.000 0.000 0.000 0.001 0.001

N2O (thousand tons) 0.00 0.00 0.01 0.01 0.01

CH4 (thousand tons) 18.89 35.22 73.93 98.30 103.68

SO2 (thousand tons) 0.05 0.09 0.19 0.25 0.27

Total Emissions

CO2 (million metric tons) 3.72 6.94 14.57 19.37 20.43

NOx (thousand tons) 2.22 4.14 8.69 11.56 12.19

Hg (tons) 0.01 0.01 0.02 0.03 0.03

N2O (thousand tons) 0.08 0.15 0.32 0.42 0.45

CH4 (thousand tons) 19.36 36.09 75.77 100.75 106.27

SO2 (thousand tons) 5.35 9.98 20.95 27.86 29.38

As part of the analysis for this NOPR, DOE estimated monetary benefits likely to 

result from the reduced emissions of CO2 and NOx that DOE estimated for each of the 

TSLs considered. As discussed in section IV.L, DOE used values for the SCC developed 

by an interagency process. The interagency group selected four sets of SCC values for 

use in regulatory analyses. Three sets are based on the average SCC from three integrated 

305
assessment models, at discount rates of 2.5 percent, 3 percent, and 5 percent. The fourth 

set, which represents the 95th-percentile SCC estimate across all three models at a 3-

percent discount rate, is included to represent higher-than-expected impacts from 

temperature change further out in the tails of the SCC distribution. The four SCC values 

for CO2 emissions reductions in 2015, expressed in 2012$, are $11.8/ton, $39.7/ton, 

$61.2/ton, and $117.0/ton. These values for later years are higher due to increasing 

emissions-related costs as the magnitude of projected climate change is expected to 

increase. 

Table V.46Table V.45 presents the global value of CO2 emissions reductions at 

each TSL. DOE calculated domestic values as a range from 7 percent to 23 percent of the 

global values, and these results are presented in chapter 14 of the NOPR TSD.

Table V.46 Global Present Value of CO2 Emissions Reduction for Potential 

Standards for Automatic Commercial Ice Makers

TSL

SCC Scenario*

5% discount 

rate, 

average

3% discount 

rate, 

average

2.5% discount 

rate, average

3% 

discount rate, 

95th percentile

million 2012$

Power Sector and Site Emissions

1 24.6 111.2 176.2 342.8

2 45.9 207.3 328.5 639.0

3 96.3 435.2 689.5 1,341.5

4 128.0 578.6 916.8 1,783.6

5 135.1 610.3 967.0 1,881.4

Upstream Emissions

1 1.5 7.0 11.2 21.7

2 2.8 13.1 20.8 40.4

3 6.0 27.5 43.7 84.9

4 7.9 36.5 58.1 112.8

5 8.4 38.5 61.3 119.0

Total Emissions

1 26.1 118.2 187.4 364.5

2 48.7 220.4 349.3 679.5

3 102.3 462.6 733.2 1,426.3

4 136.0 615.1 974.9 1,896.4

5 143.4 648.8 1,028.3 2,000.4

306
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, 

$39.7, $61.2 and $117.0 per metric ton (2012$).

DOE is well aware that scientific and economic knowledge about the contribution 

of CO2 and other GHG emissions to changes in the future global climate and the potential 

resulting damages to the world economy continues to develop rapidly. Thus, any value 

placed in this NOPR on reducing CO2 emissions is subject to change. DOE, together with 

other Federal agencies, will continue to review various methodologies for estimating the 

monetary value of reductions in CO2 and other GHG emissions. This ongoing review will

consider the comments on this subject that are part of the public record for this NOPR 

and other rulemakings, as well as other methodological assumptions and issues. 

However, consistent with DOE’s legal obligations, and taking into account the 

uncertainty involved with this particular issue, DOE has included in this NOPR the most 

recent values and analyses resulting from the ongoing interagency review process.

DOE also estimated a range for the cumulative monetary value of the economic 

benefits associated with NOx emission reductions anticipated to result from amended 

automatic commercial ice makers standards. Table V.47Table V.46 presents the present 

value of cumulative NOx emissions reductions for each TSL calculated using the average 

dollar-per-ton values and 7-percent and 3-percent discount rates

307
Table V.47 Present Value of NOx Emissions Reduction for Potential Standards for 

Automatic Commercial Ice Makers

TSL 3% Discount Rate 7% Discount Rate

million 2012$

Power Sector and Site Emissions*

1 -1.8 -1.3

2 -3.4 -2.4

3 -7.2 -5.0

4 -9.5 -6.6

5 -10.1 -7.0

Upstream Emissions

1 4.3 2.1

2 8.0 3.8

3 16.8 8.0

4 22.3 10.7

5 23.6 11.3

Total Emissions

1 2.5 0.8

2 4.6 1.4

3 9.6 3.0

4 12.8 4.0

5 13.5 4.3

The NPV of the monetized benefits associated with emission reductions can be 

viewed as a complement to the NPV of the customer savings calculated for each TSL 

considered in this NOPR. Table V.48Table V.47 presents the NPV values that result from 

adding the estimates of the potential economic benefits resulting from reduced CO2 and 

NOx emissions in each of four valuation scenarios to the NPV of consumer savings 

calculated for each TSL considered in this rulemaking, at both a 7-percent and a 3-

percent discount rate. The CO2 values used in the table correspond to the four scenarios 

for the valuation of CO2 emission reductions presented in section IV.L.

308
Table V.48 Automatic Commercial Ice Makers TSLs: Net Present Value of 

Customer Savings Combined with Net Present Value of Monetized Benefits from 

CO2 and NOx Emissions Reductions

TSL

Consumer NPV at 3% Discount Rate added with:

SCC Value of 

$11.8/metric ton 

CO2

* and Medium

Value for NOx

**

SCC Value of 

$39.7/metric ton 

CO2

* and Medium 

Value for NOx

**

SCC Value of 

$61.2/metric ton 

CO2

* and Medium 

Value for NOx

**

SCC Value of 

$117.0/metric ton 

CO2

* and Medium

Value for NOx

**

billion 2012$

1 0.458 0.550 0.620 0.797

2 0.859 1.031 1.160 1.490

3 1.863 2.223 2.494 3.187

4 1.387 1.866 2.226 3.148

5 1.189 1.694 2.074 3.046

TSL

Consumer NPV at 7% Discount Rate added with:

SCC Value of 

$11.8/metric ton 

CO2

* and Medium

Value for NOx

**

SCC Value of 

$39.7/metric ton 

CO2

* and Medium 

Value for NOx

**

SCC Value of 

$61.2/metric ton 

CO2

* and Medium 

Value for NOx

**

SCC Value of 

$117.0/metric ton 

CO2

* and Medium

Value for NOx

**

billion 2012$

1 0.224 0.317 0.386 0.563

2 0.418 0.590 0.719 1.049

3 0.896 1.257 1.527 2.220

4 0.624 1.103 1.463 2.385

5 0.518 1.023 1.403 2.375

* These label values represent the global SCC in 2015, in 2012$. The present values have been calculated with 

scenario-consistent discount rates. For NOx emissions, each case uses the medium value, which corresponds to $2,639 

per ton.

Although adding the value of customer savings to the values of emission 

reductions provides a valuable perspective, the following should be considered: (1) the 

national customer savings are domestic U.S. customer monetary savings found in market 

transactions, while the values of emission reductions are based on estimates of marginal 

social costs, which, in the case of CO2, are based on a global value; and (2) the 

assessments of customer savings and emission-related benefits are performed with 

different computer models, leading to different time frames for analysis. For automatic 

commercial ice makers, the present value of national customer savings is measured for 

the period in which units shipped (2018–2047) continue to operate. However, the time 

frames of the benefits associated with the emission reductions differ. For example, the 

309
value of CO2 emission reductions in a given year reflects the present value of all future 

climate-related impacts due to emitting a ton of CO2 in that year, out to the year 2100.

7. Other Factors

EPCA allows the Secretary, in determining whether a proposed standard is 

economically justified, to consider any other factors that the Secretary deems to be 

relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII) and 6313(d)(4)) DOE considered LCC impacts 

on identifiable groups of customers, such as customers of different business types, who 

may be disproportionately affected by any amended national energy conservation 

standard level. DOE also considered the reduction in generation capacity that could result 

from the imposition of any amended national energy conservation standard level. 

DOE carried out a RIA, as described in the NOPR TSD chapter 17, to study the 

impact of certain non-regulatory alternatives that may encourage customers to purchase 

higher efficiency equipment and, thus, achieve NES. The two major alternatives 

identified by DOE are customer rebates and customer tax credits. DOE surveyed the 

various rebate programs available in the United States. Typically, rebates are offered for 

commercial sector businesses that purchase energy-efficient automatic commercial ice 

makers, typically, machines that qualify either for ENERGY STAR or CEE certification.

Rebates offered range from $40 to several hundred dollars, depending on the size and 

type of ice maker. Based on the incremental costs DOE estimated for TSL 1 (equivalent 

to the ENERGY STAR targets that were in existence until early in 2013), the rebates 

offered are sufficient to cover the incremental costs of meeting the ENERGY STAR 

310
levels. Given the range of rebates offered, DOE elected to model rebates of equivalent to 

60 percent of the full incremental cost of the upgrades.

For the tax credits scenario, DOE did not find a suitable program to model the 

scenario. From a consumer perspective, the most important difference between rebate and 

tax credit programs is that a rebate can be obtained relatively quickly, whereas receipt of 

tax credits is delayed until income taxes are filed or a tax refund is provided by the IRS.

As with consumer rebates, DOE assumed that consumer tax credits paid 60 percent of the 

incremental product price, but estimated a different response rate. The delay in 

reimbursement makes tax credits less attractive than rebates; consequently, DOE 

estimated a response rate that is 80 percent of that for rebate programs.

Table V.49Table V.48 and Table V.50Table V.49 show the NES and NPV, 

respectively, for the non-regulatory alternatives analyzed. For comparison, the table 

includes the results of the NES and NPV for TSL 3, the proposed energy conservation 

standard. Energy savings are expressed in quads in terms of primary or source energy, 

which includes generation and transmission losses from electricity utility sector. 

Table V.49 Cumulative NES of Non-Regulatory Alternatives Compared to the 

Proposed Standards for Automatic Commercial Ice Makers

Policy Alternatives Cumulative Primary NES

quads

No new regulatory action 0

Customer tax credits 0.145

Customer rebates 0.190

Voluntary energy efficiency targets 0

Early replacement 0

Proposed standards, primary energy (TSL 3) 0.281

311
Table V.50 Cumulative NPV of Non-Regulatory Alternatives Compared to the 

Proposed Standards for Automatic Commercial Ice Makers

Policy Alternatives

Cumulative Net Present Value

billion 2012$

7% Discount 3% Discount

No new regulatory action 0 0

Customer tax credits 0.520 1.011

Customer rebates 0.678 1.319

Voluntary energy efficiency targets 0 0

Early replacement 0 0

Proposed standards (TSL 3) 0.791 1.751

As shown above, none of the policy alternatives DOE examined would achieve 

close to the amount of energy or monetary savings that could be realized under the 

proposed amended standard. Also, implementing either tax credits or customer rebates 

would incur initial and/or administrative costs that were not considered in this analysis.

C. Proposed Standard

DOE recognizes that when it considers amendments to the standards, it is subject 

to the EPCA requirement that any new or amended energy conservation standard for any 

type (or class) of covered product be designed to achieve the maximum improvement in 

energy efficiency that the Secretary determines is technologically feasible and 

economically justified. (42 U.S.C. 6295(o)(2)(A) and 6313(d)(4)) In determining whether 

a proposed standard is economically justified, the Secretary must determine whether the 

benefits of the standard exceed its burdens to the greatest extent practicable, in light of 

the seven statutory factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i) and 

6313(d)(4)) The new or amended standard must also result in a significant conservation 

of energy. (42 U.S.C. 6295(o)(3)(B) and 6316(d)(4)) 

312
DOE considered the impacts of standards at each TSL, beginning with the 

maximum technologically feasible level, to determine whether that level met the 

evaluation criteria. If the max-tech level was not justified, DOE then considered the next 

most-efficient level and undertook the same evaluation until it reached the highest 

efficiency level that is both technologically feasible and economically justified and saves 

a significant amount of energy.

DOE discusses the benefits and/or burdens of each TSL in the following sections. 

DOE bases its discussion on quantitative analytical results for each TSL including NES, 

NPV (discounted at 7 and 3 percent), emission reductions, INPV, LCC, and customers’ 

installed price increases. Beyond the quantitative results, DOE also considers other 

burdens and benefits that affect economic justification, including how technological 

feasibility, manufacturer costs, and impacts on competition may affect the economic 

results presented. Table V.51Table V.50, Table V.52Table V.51, Table V.53Table V.52

and Table V.54Table V.53 present a summary of the results of DOE’s quantitative 

analysis for each TSL. Results in Table V.51Table V.50 are impacts from equipment 

purchased in the period from 2018 – 2047. In addition to the quantitative results 

presented in the tables, DOE also considers other burdens and benefits that affect 

economic justification of certain customer subgroups that are disproportionately affected 

by the proposed standards. Section V.B.7 presents the estimated impacts of each TSL for 

these subgroups.

Table V.51 Summary of Results for Automatic Commercial Ice Makers TSLs: 

National Impacts*

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL5

313
Cumulative National Energy Savings 2018 through 2047

quads

Undiscounted 

values 0.073 0.136 0.286 0.380 0.401

Cumulative National Water Savings 2018 through 2047

billion gallons

Undiscounted

values 0.1 6.6 45.4 45.4 45.4

Cumulative NPV of Customer Benefits 2018 through 2047

2012$ billion

3% discount rate 0.430 0.806 1.751 1.238 1.032 

7% discount rate 0.198 0.368 0.791 0.484 0.370

Industry Impacts

Change in 

Industry NPV 

(2012$ million)

(8.4) to (8.7) (12.8) to 

(13.6)

(20.9) to 

(23.9)

(19.6) to 

(30.5)

(19.9) to 

(32.6)

Change in 

Industry NPV 

(%)

(8.2) to (8.5) (12.6) to 

(13.4)

(20.5) to 

(23.5)

(19.2) to 

(30.0)

(19.5) to 

(32.0)

Cumulative Emissions Reductions 2018 through 2047**

CO2 (MMt) 3.72 6.94 14.57 19.37 20.43

NOx (kt) 2.22 4.14 8.69 11.56 12.19

Hg (t) 0.01 0.01 0.02 0.03 0.03

N2O (kt) 0.08 0.15 0.32 0.42 0.45

N2O (kt CO2eq) 24.28 45.26 95.01 126.32 133.25

CH4 (kt) 19.36 36.09 75.77 100.75 106.27

CH4 (kt CO2eq) 484.06 902.37 1894.29 2518.64 2656.69

SO2 (kt) 5.35 9.98 20.95 27.86 29.38

Monetary Value of Cumulative Emissions Reductions 2018 through 2047†

CO2 (2012$ 

billion)

0.026 to 

0.364

0.049 to 

0.679

0.102 to 

1.426

0.136 to 

1.896 0.143 to 2.0

NOx – 3% 

discount rate 

(2012$ million)

2.5 4.6 9.6 12.8 13.5

NOx – 7% 

discount rate 

(2012$ million)

0.8 1.4 3.0 4.0 4.3

Employment Impacts

Net Change in 

Indirect Domestic 

Jobs by 2022

100 to 101 192 to 196 431 to 442 506 to 552 518 to 572

* Values in parentheses are negative numbers.

** “MMt” stands for million metric tons; “kt” stands for kilotons; “t” stands for tons. CO2eq is the quantity of CO2

that would have the same global warming potential (GWP).

† Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2

emissions. Economic value of NOx reductions is based on estimates at $2,639/ton.

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Table V.52 Summary of Results for Automatic Commercial Ice Makers TSLs: Mean 

LCC Savings (2012$)

Equipment Class Standard Level

TSL1 TSL2 TSL3 TSL4 TSL5

IMH-W-Small-B $199 $215 $328 $328 $49 

IMH-W-Med-B $464 $464 $587 $405 $460 

IMH-W-Large-B* $833 $833 $833 $550 $582 

 IMH-W-Large-B1 $701 $701 $701 $583 $607 

 IMH-W-Large-B2 $1,260 $1,260 $1,260 $442 $500 

IMH-A-Small-B $254 $259 $396 $170 $198 

IMH-A-Large-B* $648 $633 $1,127 $994 $994 

 IMH-A-Large-B1 $590 $572 $1,168 $1,062 $1,062 

 IMH-A-Large-B2 $960 $960 $908 $627 $627 

RCU-Large-B* $875 $875 $983 $870 $897 

 RCU-Large-B1 $847 $847 $963 $857 $882 

 RCU-Large-B2 $1,298 $1,298 $1,277 $1,070 $1,123 

SCU-W-Large-B $483 $687 $694 $143 $149 

SCU-A-Small-B $103 $198 $396 $106 $106 

SCU-A-Large-B $140 $522 $502 $240 $240 

IMH-A-Small-C $315 $314 $391 $307 ($237)

IMH-A-Large-C $660 $744 $1,026 $524 $500 

SCU-A-Small-C $93 $140 $146 $146 ($441)

* LCC results for IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B are a weighted average of the two 

sub-equipment class level typical units shown on the table, using weights provided in TSD chapter 7.

Table V.53 Summary of Results for Automatic Commercial Ice Makers TSLs: 

Median Payback Period

Equipment Class

Standard Level

years

TSL1 TSL2 TSL3 TSL4 TSL5

IMH-W-Small-B 1.07 1.26 2.27 2.27 5.42

IMH-W-Med-B 0.63 0.63 0.85 3.33 3.22

IMH-W-Large-B* 0.69 0.69 0.69 3.59 3.60

 IMH-W-Large-B1 0.72 0.72 0.72 3.75 3.77

 IMH-W-Large-B2 0.58 0.58 0.58 3.10 3.02

IMH-A-Small-B 1.07 1.22 1.42 4.32 4.24

IMH-A-Large-B* 0.46 0.49 0.84 2.16 2.16

 IMH-A-Large-B1 0.46 0.50 0.82 2.08 2.08

 IMH-A-Large-B2 0.42 0.42 0.94 2.58 2.58

RCU-Large-B* 0.41 0.41 0.65 2.39 2.44

 RCU-Large-B1 0.38 0.38 0.62 2.37 2.42

 RCU-Large-B2 0.75 0.75 1.00 2.70 2.70

SCU-W-Large-B 0.67 0.76 1.00 3.01 3.00

SCU-A-Small-B 1.40 1.52 1.56 4.79 4.79

SCU-A-Large-B 1.37 1.17 1.49 3.72 3.72

IMH-A-Small-C 0.90 0.90 0.97 2.59 6.83

IMH-A-Large-C 0.52 0.53 0.69 3.25 3.24

SCU-A-Small-C 1.13 1.53 1.85 1.85 19.12

* PBP results for IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B are weighted averages of the 

results for the two sub-equipment class level typical units, using weights provided in TSD chapter 7.

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Table V.54 Summary of Results for Automatic Commercial Ice Maker TSLs: 

Distribution of Customer LCC Impacts

Category

Standard Level

percentage of customers (%)

TSL1 TSL2 TSL3 TSL4 TSL5

IMH-W-Small-B

Net Cost (%) 0.0 0.0 3.5 3.5 45.3

No Impact (%) 60.8 34.8 0.0 0.0 0.0

Net Benefit (%) 39.2 65.2 96.5 96.5 54.7

IMH-W- Med -B

Net Cost (%) 0.0 0.0 0.0 14.9 11.3

No Impact (%) 31.0 31.0 14.3 2.4 2.4

Net Benefit (%) 69.0 69.0 85.7 82.7 86.3

IMH-W-Large-B*

Net Cost (%) 0.0 0.0 0.0 8.4 7.1

No Impact (%) 37.6 37.6 37.6 25.8 22.1

Net Benefit (%) 62.4 62.4 62.4 65.8 70.8

 IMH-W-Large-B1

Net Cost (%) 0.0 0.0 0.0 0.1 0.2

No Impact (%) 28.6 28.6 28.6 28.6 23.8

Net Benefit (%) 71.4 71.4 71.4 71.3 76.0

 IMH-W-Large-B2

Net Cost (%) 0.0 0.0 0.0 35.2 29.4

No Impact (%) 66.6 66.6 66.6 16.7 16.7

Net Benefit (%) 33.4 33.4 33.4 48.1 53.9

IMH-A-Small-B

Net Cost (%) 0.0 0.0 0.0 27.0 22.4

No Impact (%) 62.9 31.5 0.0 0.0 0.0

Net Benefit (%) 37.1 68.5 100.0 73.0 77.6

IMH-A-Large-B*

Net Cost (%) 0.0 0.0 0.0 3.6 3.6

No Impact (%) 59.8 22.8 6.3 2.1 2.1

Net Benefit (%) 40.2 77.2 93.7 94.4 94.4

 IMH-A-Large-B1

Net Cost (%) 0.0 0.0 0.0 1.2 1.2

No Impact (%) 58.6 14.7 0.0 0.0 0.0

Net Benefit (%) 41.5 85.4 100.0 98.8 98.8

 IMH-A-Large-B2

Net Cost (%) 0.0 0.0 0.0 16.5 16.5

No Impact (%) 66.6 66.6 40.0 13.4 13.4

Net Benefit (%) 33.4 33.4 60.0 70.2 70.2

RCU-Large-B*

Net Cost (%) 0.0 0.0 0.0 5.9 5.2

No Impact (%) 58.1 58.1 18.5 9.5 9.5

Net Benefit (%) 41.9 41.9 81.5 84.6 85.3

 RCU-Large-B1

Net Cost (%) 0.0 0.0 0.0 5.8 5.1

No Impact (%) 57.2 57.2 17.9 9.0 9.0

Net Benefit (%) 42.8 42.8 82.1 85.3 85.9

 RCU-Large-B2

Net Cost (%) 0.0 0.0 0.0 7.1 6.2

No Impact (%) 72.7 72.7 27.3 18.2 18.2

Net Benefit (%) 27.3 27.3 72.7 74.7 75.7

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SCU-W-Large-B

Net Cost (%) 0.0 0.0 0.0 49.3 48.8

No Impact (%) 71.4 71.4 57.2 14.3 14.3

Net Benefit (%) 28.6 28.6 42.8 36.4 36.8

SCU-A-Small-B

Net Cost (%) 0.0 0.0 0.0 31.8 31.8

No Impact (%) 82.9 37.1 11.5 0.0 0.0

Net Benefit (%) 17.1 62.9 88.5 68.2 68.2

SCU-A-Large-B

Net Cost (%) 0.0 0.0 0.1 34.3 34.3

No Impact (%) 71.4 35.7 7.2 0.0 0.0

Net Benefit (%) 28.6 64.3 92.7 65.7 65.7

IMH-A-Small-C

Net Cost (%) 0.0 0.0 0.0 7.9 72.7

No Impact (%) 77.2 54.3 40.0 31.4 11.5

Net Benefit (%) 22.8 45.7 60.0 60.7 15.9

IMH-A-Large-C

Net Cost (%) 0.0 0.0 0.0 21.3 21.1

No Impact (%) 65.0 45.0 15.0 15.0 10.0

Net Benefit (%) 35.0 55.0 85.0 63.7 68.9

SCU-A-Small-C

Net Cost (%) 0.0 0.0 0.0 0.0 79.8

No Impact (%) 73.4 53.3 36.7 36.7 20.0

Net Benefit (%) 26.6 46.7 63.3 63.3 0.2

* LCC results for IMH-W-Large-B, IMH-A-Large-B, and RCU-Large-B are a weighted average of the two 

sub-equipment class level typical units shown on the table.

DOE also notes that the economics literature provides a wide-ranging discussion 

of how consumers trade-off upfront costs and energy savings in the absence of 

government intervention. Much of this literature attempts to explain why consumers 

appear to undervalue energy efficiency improvements. This undervaluation suggests that 

regulation that promotes energy efficiency can produce significant net private gains (as 

well as producing social gains by, for example, reducing pollution). There is evidence 

that consumers undervalue future energy savings as a result of (1) a lack of information;

(2) a lack of sufficient salience of the long-term or aggregate benefits; (3) a lack of 

sufficient savings to warrant delaying or altering purchases (e.g., an inefficient ventilation 

fan in a new building or the delayed replacement of a water pump); (4) excessive focus 

on the short term, in the form of inconsistent weighting of future energy cost savings 

317
relative to available returns on other investments; (5) computational or other difficulties 

associated with the evaluation of relevant tradeoffs; and (6) a divergence in incentives 

(e.g., renter versus building owner, builder versus home buyer). Other literature indicates 

that with less than perfect foresight and a high degree of uncertainty about the future, 

consumers may trade off these types of investments at a higher-than-expected rate 

between current consumption and uncertain future energy cost savings. 

While DOE is not prepared at present to provide a fuller quantifiable framework 

for estimating the benefits and costs of changes in consumer purchase decisions due to an 

amended energy conservation standard, DOE has posted a paper that discusses the issue 

of consumer welfare impacts of appliance energy efficiency standards, and potential 

enhancements to the methodology by which these impacts are defined and estimated in 

the regulatory process.73 DOE is committed to developing a framework that can support 

empirical quantitative tools for improved assessment of the consumer welfare impacts of 

appliance standards. DOE welcomes comments on information and methods to better 

assess the potential impact of energy conservation standards on consumer choice and 

methods to quantify this impact in its regulatory analysis in future rulemakings.

TSL 5 corresponds to the max-tech level for all the equipment classes and offers 

the potential for the highest cumulative energy savings through the analysis period from 

2018 to 2047. The estimated energy savings from TSL 5 is 0.401 quads of energy, and 

73 Sanstad, A. Notes on the Economics of Household Energy Consumption and Technology Choice. 2010. 

Lawrence Berkeley National Laboratory, Berkeley, CA. 

<www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf>

318

 
potable water savings are 45.4 billion gallons. DOE projects a net positive NPV for 

customers valued at $0.370 billion at a 7-percent discount rate. Estimated emissions 

reductions are 20.4 MMt of CO2, up to 12.2 kt of NOx and 0.03 tons of Hg. The CO2

emissions have a value of up to $2.0 billion and the NOx emissions have a value of up to 

$7.8 million at a 7-percent discount rate. 

For TSL 5, with the exception of equipment class IMH-A-Small-C and SCU-ASmall-C, the mean LCC savings for all equipment classes are positive, implying a 

decrease in LCC, with the decrease ranging from $49 for the IMH-W-Small-B equipment 

class to $945 for the IMH-A-Large-B equipment class.74 Although the mean LCC 

decreases indicate a savings potential for commercial ice makers as a whole, the results 

shown on Table V.54Table V.53 indicates a large fraction of customers would experience 

net LCC increases (i.e., LCC costs rather than savings) from adoption of TSL 5, with 30 

to nearly 80 percent of customers experiencing net LCC increases in six equipment 

classes. As shown on Table V.53Table V.52, customers in 10 equipment classes would 

experience payback periods of 3 years or longer.

At TSL 5, manufacturers may experience a loss of INPV due to large investments 

in product development and manufacturing capital as nearly all products will need 

substantial redesign and existing production lines will need to be adapted to produce 

evaporators and cabinets, among other components, for the newly compliant designs.

Where these designs may differ considerably from those currently available, this TSL 

74 Two of the typical units modeled for the three large batch classes have higher savings. For this section of 

the NOPR, the discussion is limited to results for full equipment classes.

319

 
also presents a significant testing burden. The projected change in INPV ranges from a 

decrease of $32.6 million to a decrease of $19.9 million depending on the chosen 

manufacturer markup scenario. The upper bound of a $19.9 million decrease in INPV is 

considered an optimistic scenario for manufacturers because it assumes they can maintain 

the same gross margin (as a percentage of revenue) on their sales. DOE recognizes the 

risk of large negative impacts on industry if manufacturers’ expectations concerning 

reduced profit margins are realized. TSL 5 could reduce the INPV for automatic 

commercial ice makers by up to 32.0 percent if impacts reach the lower bound of the 

range, which represents a scenario in which manufacturers cannot fully mark up the 

increased equipment costs, and therefore cannot maintain the same overall gross margins 

(as a percentage of revenue) they would have in the base case.

In addition to the estimated impacts on INPV, the impacts on manufacturing 

capacity and competition are of concern at TSL 5. While more than half of the 

manufacturers who produce continuous products, already offer at least one product that

complies with TSL 5, only two manufacturers currently produce batch commercial ice 

makers that comply with the efficiency levels specified at TSL 5. This includes one small 

business manufacturer whose niche products have among the very largest harvest 

capacities in their respective equipment classes and are sold in small quantities relative to 

the rest of the industry. In contrast to this small business manufacturer, the other 

manufacturer is Hoshizaki, which produces more mainstream batch products and 

commands substantial market share. 

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The concentration of current production of batch commercial ice makers at TSL 5 

presents two issues. Hoshizaki holds intellectual property covering the design of the 

evaporator used in their batch equipment, which limits the range of possible alternative 

paths to achieving the efficiency levels for batch equipment specified at TSL 5. While the 

engineering analysis identified other means to achieve these high efficiencies, given this 

limitation on design options, other manufacturers expressed significant doubts regarding 

their ability to do so. Further, DOE’s analysis indicates that these efficiency levels 

require the use of permanent magnet motors and, for batch equipment, drain water heat 

exchangers. DOE was able to identify only one supplier of the latter technology, whose 

design is patented. In addition, there is currently very limited use of permanent magnet 

motors in commercial ice makers; hence, motor suppliers would be required to develop 

and initiate production for a broad range of new motor designs suitable for automatic 

commercial ice makers. These needs could severely impact automatic commercial ice 

maker manufacturers’ ability to procure the required components in sufficient quantities 

to supply the market. 

Assuming the other paths to achieving these efficiency levels prove fruitful, TSL 

5 would still require that every other manufacturer retool their entire batch equipment

production lines. Further, DOE review of the efficiency levels of available equipment 

shows that only 13 percent of Hoshizaki’s batch products meet the TSL 5 efficiency 

levels, suggesting that the vast majority of their production lines would also require 

redesign and retooling. In confidential interviews, one manufacturer cited the possibility 

of a 3-month to 6-month shutdown in the event that amended standards were set high 

321
enough to require retooling of their entire product line. Compounding this effect across 

the industry could severely impact manufacturing capacity in the interim period between 

the announcement of the standards and the compliance date.

After carefully considering the analysis results and weighing the benefits and 

burdens of TSL 5, DOE finds that at TSL 5, the benefits to the Nation in the form of 

energy savings and emissions reductions plus an increase of $0.370 billion in customer

NPV are weighed against a decrease of up to 32.0 percent in INPV. While most 

individual customers purchasing automatic commercial ice makers built to TSL 5 

standards would be better off than in the base case, most would face payback periods in 

excess of 3 years. The limited number of manufacturers currently producing batch 

commercial ice makers that meet this efficiency level is cause for additional concern. 

After weighing the burdens of TSL 5 against the benefits, DOE finds TSL 5 not to be

economically justified.. DOE does not propose to adopt TSL 5 in this rulemaking.

TSL 4, the next highest efficiency level, corresponds to the highest efficiency 

level with a positive NPV at a 7-percent discount rate for all equipment classes. The 

estimated energy savings from 2018 to 2047 are 0.380 quads of energy and 45.4 billion 

gallons of potable water—amounts DOE deems significant. At TSL 4, DOE projects an 

increase in customer NPV of $0.484 billion (2012$) at a 7-percent discount rate;

estimated emissions reductions of 19.4 MMt of CO2, 11.6 kt of NOx, and 0.03 tons of Hg. 

The monetary value of these emissions was estimated to be up to $1.9 billion for CO2 and 

up to $7.4 million for NOx at a 7-percent discount rate. 

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At TSL 4, the mean LCC savings are positive for all equipment classes. As shown 

on Table V.52Table V.51, mean LCC savings vary from $106 for SCU-A-Small-B to 

$945 for IMH-A-Large-B, which implies that, on average, customers will experience an 

LCC benefit. However, as shown on Table V.54Table V.53, for 11 of the 12 classes, at 

least some fraction of the customers will experience net costs. Customers in 3 classes 

would experience net LCC costs of 30 percent or more, with the percentage ranging up to 

49 percent for one equipment class. Median payback periods range from 1.9 years up to 

4.8 years, with 7 of the 12 directly analyzed classes exhibiting payback periods over 3 

years.

At TSL 4, the projected change in INPV ranges from a decrease of $30.5 million 

to a decrease of $19.6 million. The impact on manufacturers at TSL 4 is not significantly 

different from that at TSL 5 as the individual efficiency levels for each equipment class at 

TSL 4 are on average not significantly different from those at TSL 5, and in several 

instances they are the same. DOE recognizes the risk of negative impacts at TSL 4 if 

manufacturers’ expectations concerning reduced profit margins are realized. If the lower 

bound of -$30.5 million is reached, as DOE expects, TSL 4 could result in a net loss of 

30.0 percent in INPV for manufacturers of automatic commercial ice makers.

The impacts on manufacturing capacity and competition are of concern at TSL 4. 

While every manufacturer who produces continuous equipment offers at least one 

product that complies with TSL 4, only two manufacturers currently produce batch 

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commercial ice makers that comply with the efficiency levels specified at TSL 4. This 

includes one small business manufacturer whose niche products have among the very 

largest harvest capacities in their respective equipment classes and are sold in small 

quantities relative to the rest of the industry. In contrast to this small business 

manufacturer, the other manufacturer is a larger manufacturer which produces more 

mainstream batch products and commands a substantial market share. 

The concentration of current production at TSL 4 presents two issues. One large 

manufacturer holds intellectual property covering the evaporator design used in their 

batch equipment, which in turn limits the range of possible alternative paths to achieving 

the efficiency levels specified at TSL 4. While the engineering analysis identified other 

means to achieve these high efficiencies, given this limitation on design options, other 

manufacturers expressed significant doubts regarding their ability to do so. Further, 

DOE’s analysis indicates that these efficiency levels require the use of permanent magnet 

motors and, for most batch equipment, drain water heat exchangers. DOE was able to 

identify only one supplier of the latter technology, whose design is patented. In addition, 

there is currently very limited use of permanent magnet motors in commercial ice 

makers; hence, motor suppliers would be required to develop and initiate production for a 

broad range of new motor designs suitable for automatic commercial ice makers. These 

needs could severely impact automatic commercial ice maker manufacturers’ ability to 

procure the required components in sufficient quantities to supply the market. 

324
Assuming other paths to achieving these efficiency levels prove fruitful, TSL 4 

would still require that every other manufacturer retool their entire batch equipment

production lines. As noted above, only 2 manufacturers currently produce equipment that 

meets TSL 4 efficiency levels, one of which is a large manufacturer. DOE’s review of the 

efficiency levels of available equipment shows that only 14 percent of the large

manufacturer’s batch products meet the TSL 4 efficiency levels, suggesting the vast 

majority of their production lines would also require redesign and retooling. In 

confidential interviews, another manufacturer cited the possibility of a 3-month to 6-

month shutdown in the event that amended standards were set high enough to require 

retooling of their entire product line. Compounding this effect across the industry could 

severely impact manufacturing capacity in the interim period between the announcement 

of the standards and the compliance date.

After carefully considering the analysis results and weighing the benefits and 

burdens of TSL 4, DOE finds that at TSL 4, the benefits to the Nation in the form of 

energy savings and emissions reductions plus an increase of $0.484 billion in customer 

NPV are weighed against a decrease of up to 30.0 percent in INPV. While most 

individual customers purchasing automatic commercial ice makers built to TSL 4

standards would be better off than in the base case, customers in 7 of 12 equipment 

classes would face payback periods in excess of 3 years. The limited number of 

manufacturers currently producing batch commercial ice makers that meet this efficiency 

level is cause for additional concern. After weighing the burdens of TSL 4 against the 

325
benefits, DOE finds TSL 4 not to be economically justified. DOE does not propose to 

adopt TSL 4 in this notice.

At TSL 3, the next highest efficiency level, estimated energy savings from 2018 

to 2047 are 0.286 quads of primary energy and water savings are 45.4 billion gallons—

amounts DOE considers significant. TSL 3 was defined as the set of efficiencies with the 

highest NPV for each analyzed equipment class. At TSL 3, DOE projects an increase in 

customer NPV of $0.791 billion at a 7-percent discount rate, and an increase of $1.751

billion at a 3-percent discount rate. Estimated emissions reductions are 14.6 MMt of CO2,

up to 8.7 kt of NOx and 0.02 tons of Hg at TSL 3. The monetary value of the CO2

emissions reductions was estimated to be up to $1.4 billion at TSL 3, while NOx emission 

reductions at a 7-percent discount rate were valued at up to $5.5 million.

At TSL 3, nearly all customers for all equipment classes are shown to experience 

positive LCC savings. As shown on Table V.54Table V.53, the percent of customers 

experiencing a net cost rounds to 0 in all but two classes -– SCU-A-Large-B with 0.1 

percent and IMH-W-Small-B with 3.5 percent of customers exhibiting a net cost. The 

payback period for IMH-W-Small-B is 2.3 years, while for all other equipment classes 

the median payback periods are 1.9 years or less. LCC savings range from $146 for SCUA-Small-C to over $1,100 for IMH-A-Large-B.

At TSL 3, the projected change in INPV ranges from a decrease of $23.9 million 

to a decrease of $20.9 million. The three largest manufacturers, who together represent an 

estimated 95 percent of the market, currently produce a combined 38 compliant batch 

326
products at TSL 3. Many of the gains in efficiency needed to meet the standards proposed 

at TSL 3 can be achieved using higher efficiency components as opposed to the redesign 

of systems manufactured in-house and as such require little change to existing 

manufacturing capital. The lack of green-field redevelopment or significant 

recapitalization mitigates the risk of disruption to manufacturing capacity in the interim 

period between announcement of the energy conservation standards and the compliance 

date. 

At TSL 3, the monetized CO2 emissions reduction values range from $0.102 to 

$1.426 billion. The monetized CO2 emissions reduction at $39.7 per ton in 2012$ is

$0.463 billion. The monetized NOx emissions reductions calculated at an intermediate 

value of $2,639 per ton in 2012$ are $3 million at a 7-percent discount rate and $9.6 

million at a 3-percent rate. These monetized emissions reduction values were added to the 

customer NPV at 3-percent and 7-percent discount rates to obtain values of $2.223 billion 

and 1.257 billion, respectively, at TSL 3. The total customer and emissions benefits are 

highest at TSL 3.

Nearly all customers are expected to experience net benefits from equipment built 

to TSL 3 levels. The payback periods for TSL 3 are expected to be 2.3 years, or less.

After carefully considering the analysis results and weighing the benefits and 

burdens of TSL 3, DOE believes that setting the standards for automatic commercial ice 

makers at TSL 3 represents the maximum improvement in energy efficiency that is 

327
technologically feasible and economically justified. TSL 3 is technologically feasible 

because the technologies required to achieve these levels already exist in the current 

market and are available from multiple manufacturers. TSL 3 is economically justified 

because the benefits to the Nation in the form of energy savings, customer NPV at 3 

percent and at 7 percent, and emissions reductions outweigh the costs associated with 

reduced INPV and potential effects of reduced manufacturing capacity.

Therefore, DOE proposes the adoption of amended energy conservation standards 

for automatic commercial ice makers at TSL 3. 

DOE specifically seeks comment on the magnitude of the estimated decline in 

INPV at TSL 3 compared to the baseline, and whether this impact could risk industry 

consolidation. DOE also specifically requests comment on whether DOE should adopt 

TSL 4 or 5 and why., DOE may reexamine the proposed level depending on the nature 

of the information it receives during the comment period and adjust its final levels in 

response to that information.

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 

FR 51735 (Oct. 4, 1993), requires each agency to identify the problem that it intends to 

address, including, where applicable, the failures of private markets or public institutions 

328
that warrant new agency action, as well as to assess the significance of that problem. The 

problems that today’s standards address are as follows: 

1. There is a lack of consumer information and/or information processing 

capability about energy efficiency opportunities in the automatic commercial 

ice maker market.

2. There is asymmetric information (one party to a transaction has more and 

better information than the other) and/or high transactions costs (costs of 

gathering information and effecting exchanges of goods and services).

3. There are external benefits resulting from improved energy efficiency of 

automatic commercial ice makers that are not captured by the users of such 

equipment. These benefits include externalities related to environmental 

protection and energy security that are not reflected in energy prices, such as 

reduced emissions of GHGs.

In addition, DOE has determined that today’s regulatory action is an 

“economically significant regulatory action” under section 3(f)(1) of Executive Order 

12866. Accordingly, section 6(a)(3) of the Executive Order requires that DOE prepare an

RIA on today’s rule and that OIRA in OMB review this rule. DOE presented to OIRA for 

review the draft rule and other documents prepared for this rulemaking, including the 

RIA. DOE has included these documents in the rulemaking record. The assessments 

prepared pursuant to Executive Order 12866 can be found in the TSD for this 

rulemaking.

329
DOE has also reviewed this regulation pursuant to Executive Order 13563, issued 

on January 18, 2011. 76 FR 3821 (Jan. 21, 2011). Executive Order 13563 is supplemental 

to and explicitly reaffirms the principles, structures, and definitions governing regulatory 

review established in Executive Order 12866. To the extent permitted by law, agencies 

are required by Executive Order 13563 to: (1) propose or adopt a regulation only upon a 

reasoned determination that its benefits justify its costs (recognizing that some benefits 

and costs are difficult to quantify); (2) tailor regulations to impose the least burden on 

society, consistent with obtaining regulatory objectives, taking into account, among other 

things, and to the extent practicable, the costs of cumulative regulations; (3) select, in 

choosing among alternative regulatory approaches, those approaches that maximize net 

benefits (including potential economic, environmental, public health and safety, and other

advantages; distributive impacts; and equity); (4) to the extent feasible, specify 

performance objectives, rather than specifying the behavior or manner of compliance that 

regulated entities must adopt; and (5) identify and assess available alternatives to direct 

regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can 

be made by the public.

DOE emphasizes as well that Executive Order 13563 requires agencies to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, ORIA has emphasized that such techniques may 

include identifying changing future compliance costs that might result from technological 

innovation or anticipated behavioral changes. For the reasons stated in the preamble, 

330
DOE believes that today’s NOPR is consistent with these principles, including the 

requirement that, to the extent permitted by law, benefits justify costs and that net 

benefits are maximized. 

B. Review Under the Regulatory Flexibility Act

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an 

initial regulatory flexibility analysis (IRFA) for any rule that by law must be proposed for 

public comment, unless the agency certifies that the rule, if promulgated, will not have a 

significant economic impact on a substantial number of small entities. As required by 

Executive Order 13272, “Proper Consideration of Small Entities in Agency Rulemaking” 

67 FR 53461 (Aug. 16, 2002), DOE published procedures and policies on February 19, 

2003 to ensure that the potential impacts of its rules on small entities are properly 

considered during the rulemaking process. 68 FR at 7990. DOE has made its procedures 

and policies available on the Office of the General Counsel’s website 

(http://energy.gov/gc/downloads/executive-order-13272-consideration-small-entitiesagency-rulemaking).

1. Description and Estimated Number of Small Entities Regulated 

For manufacturers of automatic commercial ice makers, the SBA has set a size 

threshold, which defines those entities classified as “small businesses” for the purposes of 

the statute. DOE used the SBA’s small business size standards to determine whether any

small entities would be subject to the requirements of the rule. 65 FR 30836, 30848 (May 

15, 2000), as amended at 65 FR 53533, 53544 (Sept. 5, 2000) and codified at 13 CFR 

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part 121. The size standards are listed by NAICS code and industry description and are 

available at: www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf

Manufacturing of automatic commercial ice makers is classified under NAICS 

333415, “Air-Conditioning and Warm Air Heating Equipment and Commercial and 

Industrial Refrigeration Equipment Manufacturing,” which includes ice-making 

machinery manufacturing. The SBA sets a threshold of 750 employees or less for an 

entity to be considered as a small business in this category.

During its market survey, DOE used available public information to identify 

potential small manufacturers. DOE’s research involved industry trade association 

membership directories (including AHRI), public databases (e.g., AHRI Directory,75 the 

SBA Database76), individual company websites, and market research tools (e.g., Hoovers 

reports77) to create a list of companies that manufacture or sell equipment covered by this 

rulemaking. DOE also asked stakeholders and industry representatives if they were aware 

of any other small manufacturers during manufacturer interviews and at DOE public 

meetings. DOE reviewed publicly available data and contacted select companies on its 

list, as necessary, to determine whether they met the SBA’s definition of a small business 

manufacturer of covered automatic commercial ice makers. DOE screened out companies 

that do not offer equipment covered by this rulemaking, do not meet the definition of a 

“small business,” or are foreign-owned. 

75 See www.ahridirectory.org/ahriDirectory/pages/home.aspx. 76 See http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm. 77 See www.hoovers.com/. 

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DOE identified seven small domestic businesses manufacturers of automatic 

commercial ice makers operating in the United States. DOE contacted each of these 

companies, but only one accepted the invitation to participate in a confidential 

manufacturer impact analysis interview with DOE contractors. 

2. Description and Estimate of Compliance Requirements 

DOE estimates that the seven small domestic manufacturers of automatic 

commercial ice makers identified by DOE account for approximately 5 percent of 

industry shipments. While small business manufacturers of automatic commercial ice 

makers have small overall market share, some hold substantial market share in specific 

equipment classes. Several of these smaller firms specialize in producing industrial ice 

machines and the covered equipment they manufacture are extensions of existing product 

lines that fall within the range of capacity covered by this rule. Others serve niche 

markets. Most have substantial portions of their business derived from equipment outside 

the scope of this rulemaking, but are still considered small businesses based on the SBA 

limits for number of employees. 

At the proposed level, small business manufacturers of automatic commercial ice 

makers are expected to face negative impacts on INPV that are more than three times as 

severe as those felt by the industry at large: a loss of 70.578.6 percent of INPV for small 

businesses alone as compared to a loss of 23.5 percent for the industry at large. Where 

conversion costs are driven by the number of platforms requiring redesign at a particular 

Comment [fp30]: OIRA requested change.

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standard level, small business manufacturers may be disproportionately affected. Product 

conversion costs including the investments made to redesign existing equipment to meet 

new or amended standards or to develop entirely new compliant equipment, as well as 

industry certification costs, do not scale with sales volume. As small manufacturers’ 

investments are spread over a much lower volume of shipments, recovering the cost of 

upfront investments is proportionately more difficult.

Similarly, capital conversion costs may disproportionately affect small business 

manufacturers of automatic commercial ice makers. Capital conversion costs are 

projected to be highest in the year preceding standards as manufacturers retrofit 

production lines to make compliant equipment. In this year, capital conversion costs are 

estimated to represent 9097 percent of typical capital expenditures for small businesses, 

as compared to 34 percent for the industry as a whole. Where the covered equipment

from several small manufacturers are adaptations of larger platforms with capacities 

above the 4,000 lb ice/24 hour threshold, it may not prove economical for them to retrofit 

an entire production line to meet standards that only affect one product.

In confidential interviews, manufacturers indicated that many design options 

evaluated in the engineering analysis (e.g., higher efficiency motors and compressors) 

would require them to purchase more expensive components. In many industries, small 

manufacturers typically pay higher prices for components due to smaller purchasing 

volumes while their large competitors receive volume discounts. However, this effect is 

diminished for the automatic commercial ice maker manufacturing industry for two 

Comment [fp31]: OIRA requested change.

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distinct reasons. One reason relates to the fact that the automatic commercial ice maker

industry as a whole is a low volume industry. In confidential interviews, manufacturers 

indicated that they have little influence over their suppliers, suggesting the volume of 

their component orders is similarly insufficient to receive substantial discounts. The 

second reason relates to the fact that, for most small businesses, the equipment covered 

by this rulemaking represents only a fraction of overall business. Where small businesses 

are ordering similar components for non-covered equipment, their purchase volumes may 

not be as low as is indicated by the total unit shipments for small businesses. For these 

reasons, it is expected that any volume discount for components enjoyed by large 

manufacturers would not be substantially different from the prices paid by small business 

manufacturers.

To estimate how small manufacturers would be potentially impacted, DOE 

developed specific small business inputs and scaling factors for the GRIM. These inputs 

were scaled from those used in the whole industry GRIM using information about the 

product portfolios of small businesses and the estimated market share of these businesses 

in each equipment class. DOE used this information in the GRIM to estimate the annual 

revenue, EBIT, R&D expense, and capital expenditures for a typical small manufacturer 

and to model the impact on INPV. DOE then compared these impacts to those modeled 

for the industry at large. The results are shown on Table VI.1Table VI.1 and Table 

VI.2Table VI.2.

Table VI.1 Comparison of Small Business Manufacturers of Automatic Commercial 

Ice Maker INPV to that of the Industry at Large by TSL under the Preservation of 

Gross Margin Markup Scenario*

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

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Industry at Large –

Impact on INPV 

($2012)

$(8.4) $(12.8) $(20.9) $(19.6) $(19.9)

Industry at Large –

Impact on INPV (%) (8.2)% (12.6)% (20.5)% (19.2)% (19.5)%

Small Businesses –

Impact on INPV 

($2012)

$(1.78) $(2.89) $(3.89) $(4.01) $(4.35)

Small Businesses –

Impact on INPV (%) (30.735.4)% (50.657.0)% (68.776.6)% (72.380.5)% (77.888.4)%

*Values in parentheses are negative numbers.

Table VI.2 Comparison of Small Business Manufacturers of Automatic Commercial 

Ice Maker INPV to that of the Industry at Large by TSL under the Preservation of 

EBIT Markup Scenario

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Industry at Large –

Impact on INPV 

($2012)

$(8.7) $(13.6) $(23.9) $(30.5) $(32.6)

Industry at Large –

Impact on INPV (%) (8.5)% (13.4)% (23.5)% (30.0)% (32.0)%

Small Businesses –

Impact on INPV 

($2012)

$(1.8) $(2.93.0) $(3.94.0) $(4.56) $(5.01)

Small Businesses –

Impact on INPV (%) (32.635.4)% (52.458.9)% (70.578.6)% (81.490.3)% (90.4100.2)%

*Values in parentheses are negative numbers.

3. Duplication, Overlap, and Conflict with Other Rules and Regulations 

DOE is not aware of any rules or regulations that duplicate, overlap, or conflict 

with the rule being promulgated today. 

4. Significant Alternatives to the Rule 

The primary alternatives to the proposed rule are the other TSLs besides the one 

being considered today, TSL 3. DOE explicitly considered the role of manufacturers, 

including small manufacturers, in its selection of TSL 3 rather than TSLs 4 or 5. Though 

higher TSLs result in greater energy savings for the country, they would place significant 

burdens on manufacturers. Chapter 12 of the NOPR TSD contains additional information 

about the impact of this rulemaking on manufacturers.

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In addition to the other TSLs being considered, chapter 17 of the NOPR TSD and 

Section V.B.7 include reports on a regulatory impact analysis (RIA). For automatic 

commercial ice makers, the RIA discusses the following policy alternatives: (1) no 

change in standard; (2) customer rebates; (3) customer tax credits; (4) manufacturer tax 

credits; and (5) early replacement. While these alternatives may mitigate to some varying 

extent the economic impacts on small entities compared to the amended standards, DOE 

determined that the energy savings of these regulatory alternatives could be 

approximately one-third to one-half less than the savings that would be expected to result 

from adoption of the amended standard levels. Because of the significantly lower savings, 

DOE rejected these alternatives and proposes to adopt the amended standards set forth in 

this rulemaking. 

However, DOE seeks comment and, in particular, data on the impacts of this 

rulemaking upon small businesses. (See Issue 10 under “Issues on Which DOE Seeks 

Comment” in section VII.E of this NOPR.)

C. Review Under the Paperwork Reduction Act

Manufacturers of automatic commercial ice makers must certify to DOE that their 

equipment comply with any applicable energy conservation standards. In certifying 

compliance, manufacturers must test their equipment according to the DOE test 

procedures for automatic commercial ice makers, including any amendments adopted for 

those test procedures. DOE has established regulations for the certification and 

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recordkeeping requirements for all covered consumer products and commercial/industrial

equipment, including automatic commercial ice makers. 76 FR 12422 (March 7, 2011). 

The collection-of-information requirement for the certification and recordkeeping is 

subject to review and approval by OMB under the Paperwork Reduction Act (PRA). This 

requirement has been approved by OMB under OMB Control Number 1910-1400. Public 

reporting burden for the certification is estimated to average 20 hours per response, 

including the time for reviewing instructions, searching existing data sources, gathering 

and maintaining the data needed, and completing and reviewing the collection of 

information. 

Notwithstanding any other provision of the law, no person is required to respond 

to, nor shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the PRA, unless that collection of information 

displays a currently valid OMB Control Number.

D. Review Under the National Environmental Policy Act of 1969

Pursuant to the National Environmental Policy Act (NEPA) of 1969, (42 U.S.C. 

4321 et seq.) DOE has determined that the proposed rule fits within the category of 

actions included in Categorical Exclusion (CX) B5.1 and otherwise meets the 

requirements for application of a CX. See 10 CFR part 1021, appendix B, B5.1(b); 

1021.410(b) and appendix B, B(1)-(5). The proposed rule fits within the category of 

actions because it is a rulemaking that establishes energy conservation standards for 

consumer products or industrial equipment, and for which none of the exceptions 

338
identified in CX B5.1(b) apply. Therefore, DOE has made a CX determination for this 

rulemaking, and DOE does not need to prepare an Environmental Assessment or 

Environmental Impact Statement for this proposed rule. DOE’s CX determination for this 

proposed rule is available at http://energy.gov/nepa/downloads/cx-008014-categoricalexclusion-determination.

E. Review Under Executive Order 13132

Executive Order 13132, “Federalism,” 64 FR 43255 (Aug. 10, 1999), imposes 

certain requirements on Federal agencies formulating and implementing policies or 

regulations that preempt State law or that have Federalism implications. The Executive 

Order requires agencies to examine the constitutional and statutory authority supporting 

any action that would limit the policymaking discretion of the States and to carefully 

assess the necessity for such actions. The Executive Order also requires agencies to have 

an accountable process to ensure meaningful and timely input by State and local officials 

in the development of regulatory policies that have Federalism implications. On March 

14, 2000, DOE published a statement of policy describing the intergovernmental 

consultation process it will follow in the development of such regulations. 65 FR at 

13735. EPCA governs and prescribes Federal preemption of State regulations as to 

energy conservation for the products that are the subject of today’s proposed rule. States 

can petition DOE for exemption from such preemption to the extent, and based on 

criteria, set forth in EPCA. (42 U.S.C. 6297) No further action is required by Executive 

Order 13132.

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F. Review Under Executive Order 12988

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, “Civil Justice Reform,” imposes on 

Federal agencies the general duty to adhere to the following requirements: (1) eliminate 

drafting errors and ambiguity; (2) write regulations to minimize litigation; and (3) 

provide a clear legal standard for affected conduct rather than a general standard and 

promote simplification and burden reduction. 61 FR 4729 (Feb. 7, 1996). Section 3(b) of 

Executive Order 12988 specifically requires that Executive agencies make every 

reasonable effort to ensure that the regulation: (1) clearly specifies the preemptive effect, 

if any; (2) clearly specifies any effect on existing Federal law or regulation; (3) provides 

a clear legal standard for affected conduct while promoting simplification and burden 

reduction; (4) specifies the retroactive effect, if any; (5) adequately defines key terms; 

and (6) addresses other important issues affecting clarity and general draftsmanship under 

any guidelines issued by the Attorney General. Section 3(c) of Executive Order 12988 

requires Executive agencies to review regulations in light of applicable standards in 

section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to 

meet one or more of them. DOE has completed the required review and determined that, 

to the extent permitted by law, this proposed rule meets the relevant standards of 

Executive Order 12988.

G. Review Under the Unfunded Mandates Reform Act of 1995

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each 

Federal agency to assess the effects of Federal regulatory actions on State, local, and 

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Tribal governments and the private sector. Pub. L. 104-4, sec. 201 (codified at 2 U.S.C. 

1531). For a proposed regulatory action likely to result in a rule that may cause the 

expenditure by State, local, and Tribal governments, in the aggregate, or by the private 

sector of $100 million or more in any one year (adjusted annually for inflation), section 

202 of UMRA requires a Federal agency to publish a written statement that estimates the 

resulting costs, benefits, and other effects on the national economy. (2 U.S.C. 

1532(a),(b)) The UMRA also requires a Federal agency to develop an effective process to 

permit timely input by elected officers of State, local, and Tribal governments on a 

proposed “significant intergovernmental mandate,” and requires an agency plan for 

giving notice and opportunity for timely input to potentially affected small governments 

before establishing any requirements that might significantly or uniquely affect small 

governments. On March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR at 12820. DOE’s policy statement is

also available at http://energy.gov/gc/downloads/unfunded-mandates-reform-actintergovernmental-consultation.

Although today’s proposed rule does not contain a Federal intergovernmental 

mandate, it may require expenditures of $100 million or more on the private sector. 

Specifically, the proposed rule will likely result in a final rule that could require 

expenditures of $100 million or more. Such expenditures may include: (1) investment in 

research and development and in capital expenditures by automatic commercial ice 

makers manufacturers in the years between the final rule and the compliance date for the 

new standards; and (2) incremental additional expenditures by customers to purchase 

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higher efficiency automatic commercial ice makers, starting at the compliance date for 

the applicable standard.

Section 202 of UMRA authorizes a Federal agency to respond to the content 

requirements of UMRA in any other statement or analysis that accompanies the proposed 

rule. (2 U.S.C. 1532(c)) The content requirements of section 202(b) of UMRA relevant to 

a private sector mandate substantially overlap the economic analysis requirements that 

apply under section 325(o) of EPCA and Executive Order 12866. The 

SUPPLEMENTARY INFORMATION section of this NOPR and the “Regulatory 

Impact Analysis” section of the NOPR TSD for this proposed rule respond to those 

requirements. 

Under section 205 of UMRA, DOE is obligated to identify and consider a 

reasonable number of regulatory alternatives before promulgating a rule for which a 

written statement under section 202 is required. (2 U.S.C. 1535(a)) DOE is required to 

select from those alternatives the most cost-effective and least burdensome alternative 

that achieves the objectives of the proposed rule unless DOE publishes an explanation for 

doing otherwise, or the selection of such an alternative is inconsistent with law. As 

required by 42 U.S.C. 6295 (o) and 6313(d), this proposed rule would establish energy 

conservation standards for automatic commercial ice makers that are designed to achieve 

the maximum improvement in energy efficiency that DOE has determined to be both 

technologically feasible and economically justified. A full discussion of the alternatives 

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considered by DOE is presented in the “Regulatory Impact Analysis” section of the TSD 

for today’s proposed rule.

H. Review Under the Treasury and General Government Appropriations Act, 1999

Section 654 of the Treasury and General Government Appropriations Act, 1999 

(Pub. L. 105-277) requires Federal agencies to issue a Family Policymaking Assessment 

for any rule that may affect family well-being. This rule would not have any impact on 

the autonomy or integrity of the family as an institution. Accordingly, DOE has 

concluded that it is not necessary to prepare a Family Policymaking Assessment.

I. Review Under Executive Order 12630

DOE has determined, under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights,” 53 FR 8859 (Mar. 18, 

1988), that this regulation would not result in any takings that might require 

compensation under the Fifth Amendment to the U.S. Constitution.

J. Review Under the Treasury and General Government Appropriations Act, 2001

Section 515 of the Treasury and General Government Appropriations Act, 2001 

(44 U.S.C. 3516, note) provides for Federal agencies to review most disseminations of 

information to the public under guidelines established by each agency pursuant to general 

guidelines issued by OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 

2002), and DOE’s guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has 

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reviewed today’s NOPR under the OMB and DOE guidelines and has concluded that it is 

consistent with applicable policies in those guidelines.

K. Review Under Executive Order 13211

Executive Order 13211, “Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use,” 66 FR 28355 (May 22, 2001), requires 

Federal agencies to prepare and submit to OIRA at OMB a Statement of Energy Effects 

for any proposed significant energy action. A “significant energy action” is defined as 

any action by an agency that promulgates or is expected to lead to promulgation of a final 

rule, and that: (1) is a significant regulatory action under Executive Order 12866, or any 

successor order; and (2) is likely to have a significant adverse effect on the supply, 

distribution, or use of energy, or (3) is designated by the Administrator of OIRA as a 

significant energy action. For any proposed significant energy action, the agency must 

give a detailed statement of any adverse effects on energy supply, distribution, or use 

should the proposal be implemented, and of reasonable alternatives to the action and their 

expected benefits on energy supply, distribution, and use. 

DOE has tentatively concluded that today’s regulatory action, which sets forth 

proposed energy conservation standards for automatic commercial ice makers, is not a 

significant energy action because the proposed standards are not likely to have a 

significant adverse effect on the supply, distribution, or use of energy, nor has it been 

designated as such by the Administrator at OIRA. Accordingly, DOE has not prepared a 

Statement of Energy Effects on the proposed rule.

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L. Review Under the Information Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in consultation with the Office of Science and 

Technology Policy (OSTP), issued its Final Information Quality Bulletin for Peer Review 

(the Bulletin). 70 FR 2664 (Jan. 14, 2005). The Bulletin establishes that certain scientific 

information shall be peer-reviewed by qualified specialists before it is disseminated by 

the Federal Government, including influential scientific information related to agency 

regulatory actions. The purpose of the Bulletin is to enhance the quality and credibility of 

the Government’s scientific information. Under the Bulletin, the energy conservation 

standards rulemaking analyses are “influential scientific information,” which the Bulletin 

defines as scientific information the agency reasonably can determine will have, or does 

have, a clear and substantial impact on important public policies or private sector 

decisions. 70 FR at 2667 (Jan. 14, 2005).

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews 

of the energy conservation standards development process and analyses and has prepared 

a Peer Review Report pertaining to the energy conservation standards rulemaking 

analyses. Generation of this report involved a rigorous, formal, and documented 

evaluation using objective criteria and qualified and independent reviewers to make a 

judgment as to the technical/scientific/business merit, the actual or anticipated results, 

and the productivity and management effectiveness of programs and/or projects. The 

“Energy Conservation Standards Rulemaking Peer Review Report,” dated February 

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2007, has been disseminated and is available at the following website: 

www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.

VII. Public Participation

A. Attendance at the Public Meeting

The time, date, and location of the public meeting are listed in the DATES and 

ADDRESSES sections at the beginning of this rulemaking. If you plan to attend the 

public meeting, please notify Ms. Brenda Edwards at (202) 586-2945 or 

Brenda.Edwards@ee.doe.gov. Please note that foreign nationals visiting DOE 

Headquarters are subject to advance security screening procedures. Any foreign national 

wishing to participate in the meeting should advise DOE as soon as possible by 

contacting Ms. Edwards to initiate the necessary procedures. Please also note that those 

wishing to bring laptops into the Forrestal Building will be required to obtain a property 

pass. Visitors should avoid bringing laptops, or allow an extra 45 minutes. Persons can 

attend the public meeting via webinar. 

Webinar registration information, participant instructions, and information about 

the capabilities available to webinar participants will be published on DOE’s website at:

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/29.

Participants are responsible for ensuring their systems are compatible with the 

webinar software.

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B. Procedure for Submitting Prepared General Statements for Distribution

Any person who has plans to present a prepared general statement may request 

that copies of his or her statement be made available at the public meeting. Such persons 

may submit requests, along with an advance electronic copy of their statement in PDF 

(preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to the 

appropriate address shown in the ADDRESSES section at the beginning of this notice. 

The request and advance copy of statements must be received at least one week before 

the public meeting and may be emailed, hand-delivered, or sent by mail. DOE prefers to 

receive requests and advance copies via email. Please include a telephone number to 

enable DOE staff to make follow-up contact, if needed.

C. Conduct of the Public Meeting

DOE will designate a DOE official to preside at the public meeting and may also 

use a professional facilitator to aid discussion. The meeting will not be a judicial or 

evidentiary-type public hearing, but DOE will conduct it in accordance with section 336 

of EPCA (42 U.S.C. 6306). A court reporter will be present to record the proceedings and 

prepare a transcript. DOE reserves the right to schedule the order of presentations and to 

establish the procedures governing the conduct of the public meeting. After the public 

meeting, interested parties may submit further comments on the proceedings as well as on 

any aspect of the rulemaking until the end of the comment period.

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The public meeting will be conducted in an informal, conference style. DOE will 

present summaries of comments received before the public meeting, allow time for 

prepared general statements by participants, and encourage all interested parties to share 

their views on issues affecting this rulemaking. Each participant will be allowed to make 

a general statement (within time limits determined by DOE), before the discussion of 

specific topics. DOE will allow, as time permits, other participants to comment briefly on 

any general statements. 

At the end of all prepared statements on a topic, DOE will permit participants to 

clarify their statements briefly and comment on statements made by others. Participants 

should be prepared to answer questions by DOE and by other participants concerning 

these issues. DOE representatives may also ask questions of participants concerning other 

matters relevant to this rulemaking. The official conducting the public meeting will 

accept additional comments or questions from those attending, as time permits. The 

presiding official will announce any further procedural rules or modification of the above 

procedures that may be needed for the proper conduct of the public meeting.

A transcript of the public meeting will be included in the docket, which can be

viewed as described in the Docket section at the beginning of this rulemaking. In 

addition, any person may buy a copy of the transcript from the transcribing reporter.

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D. Submission of Comments

DOE will accept comments, data, and information regarding this proposed rule 

before or after the public meeting, but no later than the date provided in the DATES 

section at the beginning of this proposed rule. Interested parties may submit comments, 

data, and other information using any of the methods described in the ADDRESSES 

section at the beginning of this notice.

Submitting comments via regulations.gov. The regulations.gov webpage will 

require you to provide your name and contact information. Your contact information will 

be viewable to DOE Building Technologies staff only. Your contact information will not 

be publicly viewable except for your first and last names, organization name (if any), and 

submitter representative name (if any). If your comment is not processed properly 

because of technical difficulties, DOE will use this information to contact you. If DOE 

cannot read your comment due to technical difficulties and cannot contact you for 

clarification, DOE may not be able to consider your comment.

However, your contact information will be publicly viewable if you include it in 

the comment itself or in any documents attached to your comment. Any information that 

you do not want to be publicly viewable should not be included in your comment, nor in 

any document attached to your comment. Otherwise, persons viewing comments will see 

only first and last names, organization names, correspondence containing comments, and 

any documents submitted with the comments. 

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Do not submit to regulations.gov information for which disclosure is restricted by 

statute, such as trade secrets and commercial or financial information (hereinafter 

referred to as Confidential Business Information (CBI)). Comments submitted through 

regulations.gov cannot be claimed as CBI. Comments received through the website will 

waive any CBI claims for the information submitted. For information on submitting CBI, 

see the Confidential Business Information section below.

DOE processes submissions made through regulations.gov before posting. 

Normally, comments will be posted within a few days of being submitted. However, if 

large volumes of comments are being processed simultaneously, your comment may not 

be viewable for up to several weeks. Please keep the comment tracking number that 

regulations.gov provides after you have successfully uploaded your comment. 

Submitting comments via email, hand delivery/courier, or mail. Comments and 

documents submitted via email, hand delivery, or mail also will be posted to 

regulations.gov. If you do not want your personal contact information to be publicly 

viewable, do not include it in your comment or any accompanying documents. Instead, 

provide your contact information in a cover letter. Include your first and last names, 

email address, telephone number, and optional mailing address. The cover letter will not 

be publicly viewable as long as it does not include any comments

Include contact information each time you submit comments, data, documents, 

and other information to DOE. If you submit via mail or hand delivery/courier, please 

350
provide all items on a CD, if feasible. It is not necessary to submit printed copies. No 

facsimiles (faxes) will be accepted.

Comments, data, and other information submitted to DOE electronically should 

be provided in PDF (preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) 

file format. Provide documents that are not secured, that are written in English, and that 

are free of any defects or viruses. Documents should not contain special characters or any 

form of encryption and, if possible, they should carry the electronic signature of the 

author.

Campaign form letters. Please submit campaign form letters by the originating 

organization in batches of between 50 to 500 form letters per PDF or as one form letter 

with a list of supporters’ names compiled into one or more PDFs. This reduces comment 

processing and posting time. 

Confidential Business Information. According to 10 CFR 1004.11, any person 

submitting information that he or she believes to be confidential and exempt by law from 

public disclosure should submit via email, postal mail, or hand delivery/courier two wellmarked copies: one copy of the document marked confidential including all the 

information believed to be confidential, and one copy of the document marked nonconfidential with the information believed to be confidential deleted. Submit these 

documents via email or on a CD, if feasible. DOE will make its own determination about 

the confidential status of the information and treat it according to its determination.

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Factors of interest to DOE when evaluating requests to treat submitted 

information as confidential include: (1) a description of the items; (2) whether and why 

such items are customarily treated as confidential within the industry; (3) whether the 

information is generally known by or available from other sources; (4) whether the 

information has previously been made available to others without obligation concerning 

its confidentiality; (5) an explanation of the competitive injury to the submitting person 

which would result from public disclosure; (6) when such information might lose its 

confidential character due to the passage of time; and (7) why disclosure of the 

information would be contrary to the public interest.

It is DOE’s policy that all comments may be included in the public docket, 

without change and as received, including any personal information provided in the 

comments (except information deemed to be exempt from public disclosure). 

E. Issues on Which DOE Seeks Comment

Although DOE welcomes comments on any aspect of this proposal, DOE is 

particularly interested in receiving comments and views of interested parties concerning 

the following issues.

1. Standards Compliance Dates

EPCA requires that the amended standards established in this rulemaking must

apply to equipment that is manufactured on or after 3 years after the final rule is 

352
published in the Federal Register unless DOE determines, by rule, that a 3-year period is 

inadequate, in which case DOE may extend the compliance date for that standard by an 

additional 2 years. (42 U.S.C. 6313(d)(3)(C)) 

For the NOPR analyses, DOE assumed a 3-year period to prepare for compliance.

DOE requests comments on the January 1, 2018 effective date., and whether a January 1, 

2018 effective date provides an inadequate period for compliance and what economic 

impacts would be mitigated by a later effective date.

DOE also requests comment on whether the 3-year period is adequate for 

manufacturers to obtain more efficient components from suppliers to meet proposed 

revisions of standards. More discussion on this topic can be found in Section IV.B.1.g of 

today’s NOPR.

2. Utilization Factors

The utilization factor represents the percent of time that an ice maker actively produces 

ice. Ice maker usage is measured in terms of kilowatt-hours per 100 lb/24 hours, whereas 

subsequent analyses require annual energy usage in kilowatt-hours. Thus, a usage factor 

is required to translate the potential energy usage into estimated annual usage. In the 

Framework document, the Department presented a series of factors for each type of 

building that represents an ice maker market segment, and all were set to 0.5, meaning all 

building types would be modeled with a utilization factor indicating that equipment runs 

one-half of the time. The Stakeholders pointed out that not all building segments should 

be at 0.5, but DOE did not receive any data or information that DOE can use to 

Comment [fp32]: OIRA requested change.

Comment [fp33]: OIRA requested change.

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differentiate the utilization factor by building type. DOE requests data for individual 

building types. More discussion on this topic can be found in Section IV.G.3 of today’s 

NOPR.

3. Baseline Efficiency

For this notice, DOE chose continuous machine baselines at sufficiently high energy use 

levels that they exclude almost no equipment. DOE based the baselines on online data 

from the AHRI database. DOE requests comments on the development of continuous

type equipment base efficiency levels and on the availability of data on which to create 

continuous machine baselines. More discussion on this topic can be found in Section 

IV.D.2.a.. of today’s NOPR.

4. Screening Analysis

DOE requests comment on the screening analysis and, specifically, the design 

options DOE screened out of the rulemaking analysis.

DOE considered whether design options were technologically feasible; 

practicable to manufacture, install, or service; had adverse impacts on product utility or 

product availability; or had adverse impacts on health or safety. See Section IV.CSee of 

today’s NOPR and chapter 4 of the NOPR TSD for further discussion of the screening 

analysis.

5. Maximum Technologically Feasible Levels

Comment [fp34]: OIRA requested change.

Comment [fp35]: OIRA requested change.

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DOE seeks comments on the Maximum Technologically Feasible levels proposed 

in Table III.2Table III.2 and Table III.3Table III.3 of today’s notice. More discussion 

on this topic can be found in Section IV.D.2.e of today’s NOPR.

6. Markups to Determine Price 

DOE identified three major distribution channels through which automatic 

commercial ice maker equipment is purchased by the end-user: (1) manufacturer to enduser (direct channel); (2) manufacturer to wholesale distributor to end-user (wholesaler 

channel); and (3) manufacturer to distributor to dealer or contractor to end-user 

(contractor channel). DOE currently uses mechanical contractor data to estimate the 

contribution of local dealers or contactors to end-user prices. DOE requests specific input 

to improve the cost estimation for the local dealer or contractor component of markups. 

More discussion on this topic can be found in Section IV.E of today’s NOPR.

7. Equipment Life

For the NOPR analyses, DOE used an 8.5 years average life for all equipment 

classes., with analyses based on a lifetime distribution averaging 8.5 years. (TSD chapter 

9 discusses the development of the distribution.) In comments on the preliminary 

analysis, one stakeholder stated that continuous machines might have shorter life spans. 

DOE requests specific information to determine whether continuous and batch types 

should be analyzed using different equipment life assumptions, and if so, what they 

would be. More discussion on this topic can be found in Section IV.G.8 of today’s 

NOPR.

Comment [fp36]: OIRA requests change.

Comment [fp37]: OIRA requested change.

Comment [fp38]: OIRA requested change.

Comment [fp39]: OIRA requested change.

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8. Installation Costs 

Stakeholders commented that higher efficiency equipment would incur additional 

installation costs when compared to the baseline equipment. DOE requests specificity 

with respect to this comment, with specific information on design options that will 

increase installation costs and specific information to enable DOE to adjust installation 

costs appropriately. More discussion on this topic can be found in Section IV.G.2.a of 

today’s NOPR.

9. Open- Versus Closed-Loop Installations

Stakeholders commented that some localities in the U.S. have instituted local 

ordinances or laws precluding installation of ice makers in open-loop configurations. 

DOE requests stakeholder assistance in quantifying the impact of local regulations on the 

prevalence of open-loop installations. More discussion on this topic can be found in 

Section IV.D.3.c of today’s NOPR.

10. Ice Maker Shipments by Type of Equipment

DOE’s shipments forecast is based on a single snapshot of shipments by the type 

of equipment. Stakeholders at the preliminary analysis phase suggested that the 

equipment mix may be changing over time. DOE requests additional data concerning 

shipment trends/forecasts. More discussion on this topic can be found in Section IV.H.1

of today’s NOPR.

Comment [fp40]: OIRA requested change.

Comment [fp41]: OIRA requested change.

Comment [fp42]: OIRA requested change.

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11. Intermittency of Manufacturer R&D and Impact of Standards

One manufacturer reported that a previous round of standards required nearly all 

of the company’s engineering resources for between 1 and 2 years. Where manufacturers 

may divert existing R&D resources to compliance related R&D efforts, DOE requests 

additional comment on the impact on innovation of compliance related R&D efforts. 

Specifically, DOE requests comment on how to quantify this impact on innovation. 

More discussion on this topic can be found in Section IV.J of today’s NOPR.

12. INPV Results and Impact of Standards

Based on weighing of data, DOE is recommending TSL 3 for the new and 

amended automatic commercial ice maker standards. DOE recognizes that new and 

amended standards will have impacts on industry net present value results. DOE 

specifically seeks comment on the magnitude of the estimated decline in INPV at TSL 3 

compared to the baseline, and what impact this may have on manufacturers. More 

discussion on this topic can be found in Section V.B.2 of today’s NOPR.

13. Small Businesses

During the Framework and February 2012 preliminary analysis public meetings, 

DOE received many comments regarding the potential impacts of amended energy 

conservation standards on small business manufacturers of automatic commercial ice 

makers. DOE incorporated this feedback into its analyses for the NOPR and has 

presented its results in this notice and the NOPR TSD. However, DOE seeks comment 

and, in particular, additional data, in its efforts to quantify the impacts of this rulemaking 

Comment [fp43]: OIRA requested change.

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on small businesses. More discussion on this topic can be found in Section IV.J.3.d of 

today’s NOPR.

14. Consumer Utility and Performance

DOE requests comment on whether there are features or attributes of the more 

energy-efficient automatic commercial ice makers, including any potential changes to the 

evaporator design that would result in changes to the ice style or changes in the chassis 

size, that manufacturers would produce to meet the standards in this proposed rule that 

might affect how they would be used by consumers. DOE requests comment 

specifically on how any such effects should be weighed in the choice of standards for the 

automatic commercial ice makers for the final rule. More discussion on this topic can 

be found in Section V.B.3 of today’s NOPR.

15. Analysis Period

For this rulemaking, DOE analyzed the effects of this proposal assuming that the 

automatic commercial ice makers would be available to purchase for 30 years and 

undertook a sensitivity analysis using 9 years rather than 30 years of product shipments. 

The choice of a 30-year period of shipments is consistent with the DOE analysis for other 

products and commercial equipment. The choice of a 9-year period is a proxy for the 

timeline in EPCA for the review of certain energy conservation standards and potential 

revision of and compliance with such revised standards. We are seeking input, 

information and data on whether there are ways to further refine the analytic timeline. 

More discussion on this topic can be found in Section IV.H.1 of today’s NOPR.

Comment [fp44]: OIRA requested change.

Comment [fp45]: OIRA requested change.

Comment [fp46]: OIRA requested change.

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16. Social Cost of Carbon

DOE solicits comment on the application of the new SCC values used to 

determine the social benefits of CO2 emissions reductions over the rulemaking analysis 

period. (The rulemaking analysis period covers from 2018 to 2047 plus the appropriated 

number of years to account for the lifetime of the equipment purchased between 2018 and 

2047.) In particular, the agency solicits comment on the agency’s derivation of SCC 

values after 2050 where the agency applied the average annual growth rate of the SCC 

estimates in 2040−2050 associated with each of the four sets of values. More discussion 

on this topic can be found in Section IV.L.1 of today’s NOPR.

17. Remote to Rack Equipment

In the preliminary analysis, DOE found that some high-capacity RCU-RC-LargeC ice makers are solely designed to be used with compressor racks and the racks’ 

associated condensers. DOE requests comment and supporting data on the overall 

market share of these units and any expected market trends. More discussion on this 

topic can be found in Section IV.B.1.f of today’s NOPR.

18. Design Options Associated with each TSL

Section V.A.1 of today’s NOPR discusses the design options associated with each 

TSL, for each analyzed product class. DOE requests comment and data related to the 

required equipment size increases associated with the design options at each TSL levels. 

Comment [fp47]: OIRA requested change.

Comment [fp48]: OIRA requested change.

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Chapter 5 of the NOPR TSD contains full descriptions of the design options and DOE’s 

analyses for the equipment size increase associated with the design options selected. 

DOE also requests comments and data on the efficiency gains associated with each set of 

design options. Chapter 5 of the NOPR TSD contains DOE’s analyses of the efficiency 

gains for each design option considered. Finally, DOE requests comment and data on 

any utility impacts associated with each set of design options, such as potential ice-style 

changes.

19. Standard Levels for Batch-Type Ice Makers over 2,500 lbs ice/24 hours

DOE requests comment and data on the viability of the proposed standard levels selected 

for batch-type ice makers with harvest capacities from 2,500 to 4,000 lb ice/24 hours. 

The proposed standard levels are discussed in Section V.A.2 of today’s NOPR, and prior 

comments on standards for batch-type ice makers with harvest capacities from 2,500 to 

4,000 lb ice/24 hours are discussed in Section IV.B.1.b of today’s NOPR.

Comment [fp49]: OIRA requested change.

Comment [fp50]: OIRA requested change.

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VIII. Approval of the Office of the Secretary

The Secretary of Energy has approved publication of today’s proposed rule.

List of Subjects in 10 CFR Part 431

Administrative practice and procedure, Confidential business information, Energy 

conservation, Commercial equipment, Imports, Intergovernmental relations, Reporting 

and recordkeeping requirements, Small businesses. 

Issued in Washington, DC, on 

________________________________

Kathleen B. Hogan

Deputy David Danielson

Assistant Secretary for Energy Efficiency

Energy Efficiency and Renewable Energy

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For the reasons set forth in the preamble, DOE proposes to amend part 431 of chapter II 

of title 10, of the Code of Federal Regulations, as set forth below: 

PART 431 – ENERGY EFFICIENCY PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL EQUIPMENT

1. The authority citation for part 431 continues to read as follows:

Authority: 42 U.S.C. 6291–6317.

2. Section 431.136 is revised to read as follows:

§ 431.136 Energy conservation standards and their effective dates.

(a) All basic models of commercial ice makers must be tested for performance 

using the applicable DOE test procedure in § 431.134, be compliant with the applicable 

standards set forth in paragraphs (b) through (d) of this section, and be certified to the 

Department of Energy under 10 CFR part 429.

(b) Each cube type automatic commercial ice maker with capacities between 50 

and 2,500 pounds per 24-hour period manufactured on or after January 1, 2010 and 

before [Insert date three years after publication of final rule], shall meet the following 

standard levels:

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Equipment Type Type of 

Cooling

Rated Harvest 

Rate

lb ice/24 hours

Maximum Energy 

Use

kWh/100 lb ice

Maximum Condenser 

Water Use*

gal/100 lb ice

Ice-Making Head

Water

<500 7.8-0.0055H** 200-0.022H

≥500 and <1,436 5.58-0.0011H 200-0.022H

≥1,436 4.0 200-0.022H

Air <450 10.26-0.0086H Not Applicable

≥450 6.89-0.0011H Not Applicable

Remote Condensing 

(but not remote 

compressor)

Air

<1,000 8.85-0.0038H Not Applicable

≥1,000 5.1 Not Applicable

Remote Condensing 

and Remote 

Compressor

Air

<934 8.85-0.0038H Not Applicable

≥934 5.3 Not Applicable

Self-Contained

Water <200 11.40-0.019H 191-0.0315H

≥200 7.6 191-0.0315H

Air <175 18.0-0.0469H Not Applicable

≥175 9.8 Not Applicable

* Water use is for the condenser only and does not include potable water used to make ice.

** H = rated harvest rate in pounds per 24 hours, indicating the water or energy use for a given rated harvest rate.

Source: 42 U.S.C. 6313(d).

(c) Each batch type automatic commercial ice maker with capacities between 50 

and 4,000 pounds per 24-hour period manufactured on or after [Insert date three years 

after publication of final rule], shall meet the following standard levels: 

Equipment Type Cooling 

Type

Rated Harvest Rate

lb ice / 24 hours

Maximum Energy 

Use

kWh/100 lb ice*

Maximum 

Condenser 

Water Use

gal/100 lb ice**

Ice-Making Head Water

<500 5.84 – 0.0041H 200-0.022H

≥ 500 and <1,436 3.88 – 0.0002H 200-0.022H

≥ 1,436 and <2,500 3.6 200-0.022H

≥ 2,500 and <4,000 3.6 145

Ice-Making Head Air

<450 7.70 – 0.0065H Not Applicable

≥450 and <875 5.17 – 0.0008H Not Applicable

≥875 and <2,210 4.5 Not Applicable

≥2,210 and <2,500 6.89 – 0.0011H Not Applicable

≥ 2,500 and <4,000 4.1 Not Applicable

Remote 

Condensing (but 

Not Remote 

Compressor)

Air

<1,000 7.52 – 0.0032H Not Applicable

≥1,000 and <4,000 4.3 Not Applicable

Remote 

Condensing and 

Remote 

Compressor

Air

<934 7.52 – 0.0032H Not Applicable

≥934 and <4,000 4.5 Not Applicable

Self-Contained Water <200 8.55 – 0.0143H 191-0.0315H

≥200 and <2,500 5.7 191-0.0315H

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≥2,500 and <4,000 5.7 112

Self-Contained Air <175 12.6 – 0.0328H Not Applicable

≥175 and <4,000 6.9 Not Applicable

*H = rated harvest rate in pounds per 24 hours, indicating the water or energy use for a given rated harvest rate.

Source: 42 U.S.C. 6313(d).

** Water use is for the condenser only and does not include potable water used to make ice.

(d) Each continuous type automatic commercial ice maker with capacities 

between 50 and 4,000 pounds per 24-hour period manufactured on or after [Insert date 

three years after publication of final rule], shall meet the following standard levels: 

Equipment Type Type of 

Cooling

Rated Harvest Rate

lb ice / 24 hours

Maximum 

Energy Use

kWh/100 lb 

ice*

Maximum 

Condenser 

Water Use**

gal/100 lb ice

Ice-Making Head Water

<900 6.08 – 0.0025H 160-0.0176H

≥900 and <2,500 3.8 160-0.0176H

≥ 2,500 and 4,000 3.8 116

Ice-Making Head Air <700 9.24 – 0.0061H Not Applicable

≥700 and <4,000 5.0 Not Applicable

Remote Condensing

(but Not Remote 

Compressor) Air

<850 7.50 – 0.0034H Not Applicable

≥850 and <4,000 4.6 Not Applicable

Remote Condensing 

and Remote 

Compressor

Air

<850 7.65 – 0.0034H Not Applicable

≥850 and <4,000 4.8 Not Applicable

Self-Contained Water

<900 7.28 – 0.0027H 153-0.0252H

≥900 and <2,500 4.9 153-0.0252H

≥2,500 and <4,000 4.9 90

Self-Contained Air <700 9.20 – 0.0050H Not Applicable

≥700 and <4,000 5.7 Not Applicable

* H = rated harvest rate in pounds per 24 hours, indicating the water or energy use for a given rated harvest rate.

Source: 42 U.S.C. 6313(d).

** Water use is for the condenser only and does not include potable water used to make ice.

364