Energy Conservation Standards for 

Commercial Refrigeration Equipment 

ANOPR Public Meeting 

NOPR Analyses and Next Steps 

Building Technologies Program 

Office of Energy Efficiency and Renewable Energy 

U.S. Department of Energy 

August 23, 2007 

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

NOPR Analyses Flow Diagram

Impact 

Utility 

Impact 

Trial Standard Levels 

Revise ANOPR 

Assessme

Impact 

Manufacturer 

Analyses Analysis Analysis 

Environme

Employment Analysis 

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

ANOPR Issues for Public Comment 

 Selection of Candidate Standard Levels for Post-ANOPR A

(Issue #13) 

 Approach to Characterizing Energy Conservation Standar

(Issue #14) 

 Standards for Commercial Refrigerator-Freezers (Issue #1

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

Revise ANOPR Analyses

ANOPR Analysis Action 

Engineering Analysis • Consider ANOPR comments 

• Revise using latest data 

Life-Cycle Cost and Payback • Consider ANOPR comments 

Period Analyses 

• Revise using latest data • Conduct LCC Sub-Group Analysis 

National Impacts Analysis • Consider ANOPR comments 

• Revise using latest data 

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

Selection of Candidate Standard Levels for Post-ANO

(Issue #13) 

 DOE selects Candidate Standard Levels (CSLs) for individual equ

based on the broader set of levels analyzed in the ANOPR. 

 DOE identified four efficiency levels plus the baseline level in eac

based on levels showing: 

• maximum LCC savings • maximum energy savings, • highest efficiency level with less than 3 year payback. • DOE also included additional levels between the baseline and these levels 

CSLs 

DOE invites comments on the candidate standard levels selefuture analysis. 

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

Proposed Candidate Standard Levels

Equipment 

Class 

Test 

Metric 

Candidate Standard Level in Order of 

Efficiency 

Candidate Standard 

Equipment Analyzed 

Terms of the Test 

Baseline CSL1 CSL2 CSL3 CSL4 Baseline CSL1 CSL2 

VOP.RC.M CDEC/TDA 

kWh/day/ft2 Level 1 Level 4 Level 6 Level 7 Level 8 1.08 0.90 0.75 

VOP.RC.L CDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 4 Level 5 Level 6 2.93 2.61 2.47 

VOP.SC.M TDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 5 Level 7 Level 8 2.55 2.23 2.07 

VCT.RC.M CDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 5 Level 6 Level 7 0.54 0.42 0.38 

VCT.RC.L CDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 5 Level 7 Level 8 1.06 0.90 0.75 

VCT.SC.I TDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 6 Level 7 Level 8 1.58 1.24 0.77 

VCS.SC.I TDEC/V 

kWh/day/ft3 Level 1 Level 5 Level 6 Level 7 Level 8 0.27 0.19 0.18 

SVO.RC.M CDEC/TDA 

kWh/day/ft2 Level 1 Level 2 Level 4 Level 6 Level 7 1.05 1.00 0.90 

SVO.SC.M TDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 5 Level 7 Level 8 2.24 1.99 1.87 

SOC.RC.M CDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 4 Level 5 Level 7 0.95 0.76 0.74 

HZO.RC.M CDEC/TDA 

kWh/day/ft2 Level 1 Level 1 Level 2 Level 3 Level 4 0.16 0.16 0.14 

HZO.RC.L CDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 4 Level 5 Level 6 0.83 0.75 0.70 

HZO.SC.M TDEC/TDA 

kWh/day/ft2 Level 1 Level 4 Level 6 Level 7 Level 8 0.78 0.61 0.56 

HZO.SC.L TDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 6 Level 7 Level 8 2.05 1.80 1.52 

HCT.SC.I TDEC/TDA 

kWh/day/ft2 Level 1 Level 3 Level 4 Level 5 Level 6 1.63 1.28 0.73 

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

Approach to Characterizing Energy Conservation S

(Issue #14) 

 Standards will be based on the CDEC or TDEC as calculated by th

procedure

 DOE proposes the use of Total Display Area (TDA) as a normalizin

for

• for remote condensing commercial equipment with transparent doors or with• commercial ice-cream freezers with transparent doors • self-contained commercial equipment without doors 

 DOE proposes the use of Refrigerated Volume (V) as a normalizin

• remote condensing commercial refrigerators, commercial freezers, and com

refrigerators-freezers with solid doors 

• commercial ice-cream freezers with solid doors 

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

Approach to Characterizing Energy Conservation S

(Issue #14) 

 For equipment using TDA as the normalizing factor, DOE propose

Maximum Energy Consumption Standards be described as

MECSC = ASC x TDA (self-contained equipment)

MECRC = ARC x TDA (remote condensing equipment)

• ARC, ASC are expressed in terms of kWh/day/ft2 of rated volume 

 For equipment using V as the normalizing factor, DOE proposes t

Maximum Energy Consumption Standards be described as

Maximum Energy Consumption (M) (kWh/yr) = B x V + K 

• B is expressed in terms of kWh/day/ft3 of rated volume, • V is the adjusted volume (ft3) calculated for the equipment class, and • K is an offset factor expressed in kWh/day. 

DOE invites comments on its approach for characterizing eneconservation standards as discussed in section III of the ANOhow it could develop appropriate offset factors. 

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

Standards for Commercial Refrigerator-Freez

(Issue #15) 

 For remote-condensing refrigerator-freezers with independent rem

condensing units for refrigerator and freezer compartments 

• Determine the maximum allowable energy consumption for each compartm

individually based on each compartment’s respective equipment class and T

Volume 

• Maximum allowable energy consumption for a display case is based on the 

maximum allowable consumption for each compartment calculated separate

 Self-contained refrigerator-freezers w/o doors but with separate 

compressor/condensers for refrigerator and freezer compartment 

similarly using TDEC for each compartment 

 EE-2006-STD-0126 COMMENT 13.7
Revise AN

Standards for Commercial Refrigerator-Freez

(Issue #15) 

 For remote condensing refrigerator freezers where a single conde

serves both refrigerator and freezer compartments 

• Measure total refrigeration load according to ASHRAE 72 for all compartme• Use ARI 1200-2006 and calculate CEC using lowest evaporator temperatur• Determine CDEC as sum of CEC, FEC, LEC, AEC, DEC, and PEC for case • Determine maximum-allowable energy consumption as the maximum allow

normalized energy consumption (MEC/ TDA or MEC / V) for the compartmelower evaporator temperature times total case refrigerator TDA or volume a

 Self-contained refrigerator-freezers with a single condensing unit 

both refrigerator and freezer compartment treated similarly using compartment with the lowest temperature 

DOE invites comments on this approach to implementing stacommercial refrigerator-freezers. 

 EE-2006-STD-0126 COMMENT 13.7
Trial S

NOPR Analyses Flow Diagram

Impact 

Utility 

Impact 

Trial Standard Levels 

Revise ANOPR 

Assessme

Impact 

Manufacturer 

Analyses Analysis Analysis 

Environme

Employment Analysis 

 EE-2006-STD-0126 COMMENT 13.7
Trial S

Selection of Trial Standard Levels 

 Purpose 

• To develop a list of standard levels from which impacts are weighed 

proposed standard level is selected 

– Each trial standard level consists of a set of potential minimum effic

covering all equipment classes, and may vary between equipment 

– NOPR analyses assess impacts for trial standard levels (not equipm

 Method 

• Trial standard levels are assembled from the equipment classes ide

ANOPR 

– Candidate standard levels cover a range of efficiencies and can inc

 Most energy efficient level (max tech)  Efficiency level with the lowest life-cycle cost  Efficiency level with a payback period of three years or less 

 Efficiency levels with noteworthy technologies 

 Efficiency levels that fill in large gaps between candidate standard 

– Each trial standard level consists of the candidate standard level fro

equipment class that meets one of the above criteria 

 EE-2006-STD-0126 COMMENT 13.7
Trial S

Trial Standard Level Criteria 

 A critical part of the NOPR analysis on which DOE is seek

guidance and input. 

• Trial standard levels are created from combinations of candid

standard levels at an equipment class level. 

• Based around a consistent theme, such as lowest life-cycle c

payback in 3-years or less. 

DOE invites comments on the criteria for selecting trial standa

 EE-2006-STD-0126 COMMENT 13.7
Manufacturer I

NOPR Analyses Flow Diagram

Impact 

Utility 

Impact 

Trial Standard Levels 

Revise ANOPR 

Assessme

Impact 

Manufacturer 

Analyses Analysis Analysis 

Environme

Employment Analysis 

 EE-2006-STD-0126 COMMENT 13.7
Manufacturer I

Manufacturer Impact Analysis 

 Purpose 

• To assess the impacts of standards on commercial refrigeration equi

manufacturers 

• To identify and estimate impacts on manufacturer sub-groups that m

severely impacted than the industry as a whole 

• To examine the impact of cumulative regulatory burdens on the indus

 Method 

• Analyze industry cash flow and net present value through use of the 

Regulatory Impact Model (GRIM) 

• Interview manufacturers to refine inputs to the GRIM, develop sub-gr

and address qualitative issues 

 Output 

• Industry Net Present Value impacts • Sub-group Net Present Value impacts • Other impacts 

 EE-2006-STD-0126 COMMENT 13.7
Manufacturer I

Manufacturer Impact Analysis Process 

 The MIA consists of three phases 

Phase 1 Phase 2 Phase 3

profile 

Develop straw-man GRIM* 

Develop guide 

wide /

subgroup 

Assess direct competition,cumulative burden 

Industry interview 

Interviews 

& industryanalyses employment, 

* Government Regulatory Impact Model (GRIM) 

 EE-2006-STD-0126 COMMENT 13.7
Utility Im

NOPR Analyses Flow Diagram

Impact 

Utility 

Impact 

Trial Standard Levels 

Revise ANOPR 

Assessme

Impact 

Manufacturer 

Analyses Analysis Analysis 

Environme

Employment Analysis 

 EE-2006-STD-0126 COMMENT 13.7
Utility Im

Utility Impact Analysis 

 Purpose 

• To investigate the effects on utilities from reduced energy sales and 

demand due to potential standards 

 Method 

• Uses national energy savings results • Uses the Energy Information Administration’s National Energy Mode

(NEMS) tailored for DOE’s Building Technologies Program (NEMS-B

 Output 

• Change in electricity sales and price by region • Change in the mix of electricity generation • Change in new capacity construction 

 EE-2006-STD-0126 COMMENT 13.7
Employment I

NOPR Analyses Flow Diagram

Impact 

Utility 

Impact 

Trial Standard Levels 

Revise ANOPR 

Assessme

Impact 

Manufacturer 

Analyses Analysis Analysis 

Environme

Employment Analysis 

 EE-2006-STD-0126 COMMENT 13.7
Employment I

Employment Impact Analysis 

 Purpose 

• To report net jobs created or eliminated nationally as a consequence 

energy efficiency standards 

 Method 

• Uses the IMSET tool, a buildings-sector version of the IMPLAN natio

output model 

• Changes in equipment and energy expenditures taken from the Natio

Savings Analysis 

• Direct employment impacts taken from the Manufacturer Impact Ana

 Output 

• Change in employment by sector as a consequence of new standard

 EE-2006-STD-0126 COMMENT 13.7
Environment

NOPR Analyses Flow Diagram

Impact 

Utility 

Impact 

Trial Standard Levels 

Revise ANOPR 

Impact 

Manufacturer 

Analyses Analysis Analysis 

EnvironmeAssessme

Employment Analysis 

 EE-2006-STD-0126 COMMENT 13.7
Environment

Environmental Assessment 

 Purpose 

• To report environmental impacts as a consequence of new energy e

standards, including changes in power plant emissions 

 Method 

• Energy savings results taken from the National Energy Savings Anal• Energy Information Administration’s National Energy Modeling Syste

provides power-plant emissions 

 Output 

• Estimate of national emission reductions of SO2, NOx, CO2 and Merc

 EE-2006-STD-0126 COMMENT 13.7
Regulatory Im

NOPR Analyses Flow Diagram

Impact 

Utility 

Impact 

Trial Standard Levels 

Revise ANOPR 

Assessme

Impact 

Manufacturer 

Analyses Analysis Analysis 

Environme

Employment Analysis 

 EE-2006-STD-0126 COMMENT 13.7
Regulatory Im

Regulatory Impact Analysis 

 Purpose 

• To investigate the national impacts due to non-regulatory alternati

with mandatory energy efficiency standards 

• The non-regulatory alternatives that may be considered: 

– No new regulatory action; early replacement; prescriptive standards; c

credits; manufacturer tax credits; customer rebates; voluntary efficienc

government procurement 

 Method 

• Modify NES spreadsheet model to consider scenarios. Changes m

energy prices and escalation factors; implicit market discount ratepurchase price, operating cost, and income elasticities; and equipdata 

 Output 

• National Energy Savings and Net Present Value of the non-regula

alternatives 

• Impact of non-regulatory alternatives on purchase price and use o

efficient equipment 

 EE-2006-STD-0126 COMMENT 13.7
The Energy Policy and Conservation Act (EPCA) direct

consider seven factors when setting energy conservation 

Factor Analysis 

1. Economic impact on consumers and Life-cycle cost analysis 

manufacturers Manufacturer impacts ana

2. Lifetime operating cost savings Life-cycle cost analysis 3. Total projected energy savings National impact analysis 4. Impact on utility or performance Screening analysis 

Engineering analysis 

5. Impact of any lessening of Manufacturer impacts ana

competition 

6. Need for national energy National impact analysis 

conservation 

7. Other factors the Secretary Environmental assessmen

considers relevant Utility impact analysis 

Employment impact analy

 EE-2006-STD-0126 COMMENT 13.7
How to Submit Comments... 

 Public Meeting – oral comments will be captured in the transcr

become part of the public record. 

 Written comments – ANOPR comment period open until Octob

Reference docket #: EE-2006-STD-0126 and/or RIN #: 1904-A

Email: commercialrefrigeration.rulemaking@ee.doe.gov Mail: Ms. Brenda Edwards-Jones 

U.S. Department of EnergyBuilding Technologies Program, Mail stop EE-2J 

ANOPR for Commercial Refrigeration Equipment EE-2006-STD-0126 1000 Independence Avenue, SWWashington DC, 20585-0121 

Courier: Ms. Brenda Edwards-Jones 

U.S. Department of EnergyBuilding Technologies Program, 1J-0181000 Independence Avenue, SW Washington DC, 20585-0121 

 EE-2006-STD-0126 COMMENT 13.7