Charles Llenza December 5, 2013 commercial_refrigeration_equipment@ee.doe.gov 

## Commercial Refrigeration Equipment Notice of Proposed Rulemaking Public Meeting on Test Procedures2 

## Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record

– there will be a complete transcript of this meeting.

– Be concise

– share the “air

- time.”

– Keep the focus here

– cell phones on silent; limit sidebar conversations.

– Webinar participants turn phone on mute; “raise your hand” to be recognized to speak.



### • Housekeeping Items

• Agenda Review

• Opening Remarks3 

## Listening Via the Webcast

• The U.S. Department of Energy (DOE) is broadcasting this meeting live over the Internet.

• DOE is providing the webcast to accommodate stakeholders who are unable to attend the public meeting in person.

• The web broadcast allows stakeholder to listen in and view the slides.

• All stakeholders are encouraged to submit written comments after the public meeting.4 

## Opening Remarks5 

## Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure
5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information6 

## Agenda

9:00 – 9:30 am Welcome, Introductions, Opening Remarks 9:30 – 9:45 am Rulemaking History & Timeline 9:45 – 10:30 am Test Procedure Scope & Definitions 10:30 – 10:45 am Break 10:45 – 12:00 pm Clarifications to the Test Procedure 12:00 – 12:15 pm Break 12:15 – 12:30 pm Other Test Procedure Issues 12:30 – 12:45 pm Burden of Testing & Regulatory Review 12:45 – 1:00 pm Closing Remarks 1:00 pm Adjourn7 

## Purpose of this Public Meeting

• Purpose

– To present DOE’s proposed test procedure (TP) amendments for commercial refrigeration equipment (CRE).

– To answer questions about DOE’s proposed approach.



### • Comments from Participants

– Participants are invited to provide summary comments or statements and raise additional issues for discussion.

– Notice of proposed rulemaking (NOPR) comment period closes on January 13, 2014.8 

## Issue “Boxes” for Discussion

• Issue “boxes” correspond to the list of issues for which the Department seeks comments.

• A list of issues are in the NOPR document, available at: http ://www.regulations.gov/#!documentDetail;D=EERE

- 2013

- BT

- TP

- 0025 Issue Box: In the test procedure NOPR for commercial refrigeration equipment, DOE welcomes comment. Throughout this presentation, specific issues will be raised for discussion on slides such as this, with identifying numbers corresponding to those in the test procedure NOPR document. In addition, DOE has added questions that are not in the NOPR document. These questions are identified by a letter.9 

## How to Submit Written Comments

• In all correspondence, please refer to the CRE Test Procedure rulemaking by:

– Commercial Refrigeration Equipment Test Procedure Rulemaking,

– Docket Number EERE

- 2013

- BT

- TP

- 0025 , and

– Regulatory Identification Number (RIN) 1904

- AC99.

• Email : CRE2013TP0025@ee.doe.gov

• Comment period closes: January 13, 2014 , 11:59 PM EST10 

## Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure

5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information11 

## CRE Test Procedure Regulatory History

• EPCA , as amended, directs that:

– Test procedures for commercial refrigerators, freezers, and refrigerator

- freezers must be:

1) the test procedures determined to be generally accepted industry testing procedures; or 2) rating procedures developed or recognized by ASHRAE or by ANSI. (42 U.S.C. 6314(a)(6)(A)( i ))

– The initial test procedures for self

- contained refrigerators, freezers, and refrigerator

- freezers with doors shall be the ASHRAE 117 test procedures that went into effect January 1, 2005. (42 U.S.C. 6314(a)(6)(A)(ii))12 

## Authority to Amend CRE Test Procedure

• EPCA states that:

– If ASHRAE 117 is amended, the Secretary must, by rule, amend the DOE test procedure to ensure consistency with the amended ASHRAE 117 unless certain findings are made by clear and convincing evidence. (42 U.S.C. 6314(a)(6)(E))

– If a test procedure other than ASHRAE 117 is approved by ANSI, the Secretary must review the relative strengths and weaknesses of the new test procedure relative to the ASHRAE 117 test procedure and, based on that review, adopt one new test procedure for use in the standards program. (42 U.S.C. 6314(a)(6)(F))

– At least once every 7 years DOE must conduct an evaluation of each class of covered equipment to determine whether to, among other things, amend the test procedures for such equipment. (42 U.S.C. 6314(a)(2))13 

## Current CRE Test Procedure

• On December 8, 2006, DOE established a test procedure for commercial refrigeration equipment, which references the Air

Conditioning and Refrigeration Institute (ARI) Standard 1200

- 2006.

• ARI 1200

- 2006 references American Society of Heating, Refrigerating and Air

Conditioning Engineers (ASHRAE) Standard 72

- 2005 as the method of test.

• DOE adopted Association of Home Appliance Manufacturers (AHAM) Standard HRF

- 1

- 2004 for measuring refrigerated compartment volume. 71 FR 71370 (Dec. 8, 2006).14 

## 2012 CRE Test Procedure Amendments

• On February 21, 2012, DOE issued a test procedure final rule for commercial refrigeration equipment , amending the procedure previously established in 2006. 77 FR 10292; 10318

- 21 (Feb. 21, 2012 ).

• The 2012 test procedure final rule made a number of amendments and updates, including:

- updating references to industry test procedures to their current versions,

- incorporating methods to evaluate the energy impacts resulting from the use of night curtains and lighting occupancy sensors and controls, and

- allowing commercial refrigeration equipment which cannot achieve the specified rating temperature to instead be tested at the lowest temperature at which it is able to operate.15 

## Proposed Test Procedure Revisions

• Since publication of the 2012 CRE test procedure final rule, DOE has received several inquiries from interested parties regarding:

– t he applicability of DOE’s test procedure and current Federal energy conservation standards to various equipment types and features,

– t he definition of certain terms pertinent to commercial refrigeration equipment,

– t he proper configuration and use of certain components and features of commercial refrigeration equipment when testing according to the DOE test procedure,

– t he proper application of certain test procedure provisions, and

– t he compliance date of certain provisions specified in the DOE test procedure final rule published on February 21, 2012.

• The NOPR proposes a number of test procedure revisions in response to these inquiries.16 

## Proposed Test Procedure Revisions, Continued

• During the summer of 2013, DOE initiated a negotiated rulemaking process for certification of commercial heating, ventilation, air conditioning, refrigeration, and water heating equipment (Docket No. EERE

- 2013

- BT

- NOC

0023).

• During the negotiated rulemaking meetings, discussions were held on the treatment of certain features or product attributes specific to commercial refrigeration equipment under the DOE test procedure.

• Consensus was reached regarding treatment of these features and it was agreed that these clarifications would be codified in a future rulemaking.

• This test procedure NOPR contains proposals reflecting these positions agreed upon through the negotiated rulemaking.17 

## CRE Test Procedure NOPR

NOPR Final Rule

• The NOPR document and materials from today’s public meeting will be available online : http://www.regulations.gov/#!docketDetail;D=EERE

- 2013

- BT

- TP

- 002518 

## CRE Test Procedure Rulemaking Timeline

2014 2015

TP NOPR Public Meeting Dec. 5, 2013 Proposed Final Rule Effective Date (30 days after the publication of any Final Rule)19 

## Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure
5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information20 

## Scope of Commercial Refrigeration Equipment

• EPCA defines covered commercial refrigeration equipment broadly as refrigeration equipment that:

– is not a consumer product;

– is not designed and marketed exclusively for medical, scientific, or research purposes;

– operates at a chilled, frozen, combination chilled and frozen, or variable temperature;

– displays or stores merchandise and other perishable materials horizontally, semivertically , or vertically;

– has transparent or solid doors, sliding or hinged doors, a combination of hinged, sliding, transparent, or solid doors, or no doors;

– is designed for pull

- down temperature applications or holding temperature applications; and

– is connected to a self

- contained condensing unit or to a remote condensing unit. 

### 42 U.S.C. 6311(9)(A)21 cannot be tested with DOE TP can be tested with DOE TP 

## Scope of CRE Test Procedure

• DOE’s CRE test procedure is applicable to all equipment for which DOE has established energy conservation standards, as well as to some equipment types for which DOE has not yet established energy conservation standards, such as chef bases and griddle stands.

• The current DOE test procedure is not applicable to salad bars, prep tables, and refrigerated buffet tables.

• For equipment to which it applies, the DOE test procedure must be used for making representations of energy consumption.

c

ommercial r efrigeration equipment that is not currently covered by energy conservation standards22 

## Scope of CRE Energy Conservation Standards

• DOE has only established standards for certain types of commercial refrigeration equipment.

– These standards are specified at 10 CFR 431.66 and are applicable to all new equipment distributed in commerce. 76 FR 12422, 12426 and 12437 (March 7, 2011).

– DOE’s standards are not applicable to rebuilt or refurbished equipment. Id.



### • There are also several types of equipment for which DOE has not yet established energy conservation standards



### .

– These include, for example, buffet tables, salad bars, prep tables, and griddle stands.

– This notice includes proposed regulatory text to clarify this point.23 

## Definition of “Chef Base or Griddle Stand”

• To clearly differentiate “chef bases” and “griddle stands” from conventional types of commercial refrigeration equipment, DOE proposes to establish a new definition for chef base or griddle stand as follows: Chef base or griddle stand means commercial refrigeration equipment that is designed and marketed for the express purpose of having a griddle or other cooking equipment placed on top of it that is capable of reaching temperatures hot enough to cook food.

Issue 1: DOE requests comment on the proposed definition for “chef base or griddle stand .”24 

## Cases Shipped with Doors as After
- Market Additions

• A basic model of commercial refrigeration equipment is tested, rated, and subject to standards based on the equipment class( es ) to which that basic model belongs.

• For equipment that is offered for sale with doors as an optional accessory, regardless of how the unit is shipped, such unit must be t ested and certified as equivalent to a basic model shipped with doors pre

- installed.25 

## Classification of CRE Basic Models

• DOE currently categorizes commercial refrigeration equipment by equipment classes based on the following general characteristics:

– geometry of the case ( i.e. , vertical, horizontal, or semi

- vertical);

– presence of doors (closed equipment) or no doors (open equipment);

– door type, if applicable (transparent or solid);

– condensing unit configuration (self

- contained or remote condensing);

– holding temperature application or pull

- down temperature application; and

– operating temperature (refrigerator, freezer, or ice

- cream freezer).26 

## Commercial Refrigeration Equipment with Drawers

• DOE interprets the term “door” to mean any movable component of the CRE unit that:

– when closed, separates the interior refrigerated space from the ambient air; and

– when opened, provides access to the refrigerated products inside the CRE unit.



### • DOE considers drawers to be doors for purposes of DOE’s regulatory program

.

• Compliance for equipment with drawers is determined based on the standard level for the equivalent equipment class with doors as tested in accordance with the DOE test procedure.27 

## Definition of “Door”

• To clarify how DOE’s regulatory scheme applies to basic models of CRE units with drawers, DOE proposes to add a definition of a door , to read as follows: Door means a movable panel that :

(1) separates the interior volume of a unit of commercial refrigeration equipment from the ambient environment, (2) is designed to facilitate access to the refrigerated space for the purpose of loading and unloading product, and (3) is affixed such that it is not removable without the use of tools. This includes hinged doors, sliding doors, and drawers.

Issue 2: DOE requests comment on its proposed definition of “door,” and, in particular, its specification that the term is inclusive of drawers.28 

## Determination of Transparency

• DOE prefers a quantifiable method to determine light transmittance.

• DOE proposes that ASTM E 1084

- 86 (Reapproved 2009), “Standard Test Method for Solar Transmittance (Terrestrial) of Sheet Materials Using Sunlight,” is widely applicable to transparent materials that would be used to construct commercial refrigeration equipment.

– ASTM E 1084

- 86 (Reapproved 2009) is the basis for other industry

standard test methods for determining visible transmittance of fenestration products (e.g., ASTM E 972

- 96 and NFRC 202

- 2012).29 

## Definition of “Transparent”

• DOE proposes to establish a definition for “transparent” as follows:

Transparent means greater than or equal to 65 percent light transmittance, as determined in accordance with ASTM Standard E 1084

- 86 (Reapproved 2009), “Standard Test Method for Solar Transmittance (Terrestrial) of Sheet Materials Using Sunlight , ” at normal incidence.

Issue 3: DOE requests comments from interested parties on the proposal to define “transparent” based on the optical properties of the material, as determined by ASTM E 1084

- 86 (Reapproved 2009) as incorporated by reference.30 

## Definition of “Closed Solid” and “Closed Transparent”

• At 10 CFR 431.66, DOE refers to equipment families using the terms “closed solid” and “closed transparent” (for example vertical closed solid (VCS) and vertical closed transparent (VCT)).

• DOE proposes to establish a definition for “closed solid” and “closed transparent” as follows:
Closed solid means equipment with doors, and in which more than 25 percent of the outer surface area of all doors on a unit is not transparent. Closed transparent means equipment with doors, and in which 75 percent or more of the outer surface area of all doors on the unit is transparent.

Issue 4: DOE requests comment on its proposed definitions of the terms “closed solid” and “closed transparent.”31 

## Hybrid Equipment and Commercial Refrigerator
- Freezers

• DOE’s regulations currently cover commercial hybrid refrigerators, freezers, and refrigerator

- freezers in addition to non - hybrid commercial refrigerators, freezers, and refrigerator

- freezers.

• There appears to be some confusion regarding the differentiation of hybrid equipment from non

- hybrid commercial refrigerator

- freezers.

• At 10 CFR 431.62, DOE defines a “ commercial hybrid refrigerator, freezer, or refrigerator

- freezer ” as having two or more chilled and/or frozen compartments that are in two or more different equipment families, contained in one cabinet, and sold as a single unit.32 

## Definitions Concerning Commercial Hybrid Equipment

• To clarify the relationship between commercial hybrid equipment and non

- hybrid commercial refrigerator

- freezers, DOE proposes to remove DOE’s existing definition of “commercial hybrid refrigerator, freezer, or refrigerator

freezer” and establish new definitions for “commercial hybrid” and “commercial refrigerator

- freezer” as follows: Commercial hybrid means a unit of commercial refrigeration equipment

(1) Consisting of two or more refrigerated compartments that are in two or more different equipment families , and (2) Which is sold as a single unit.
Commercial refrigerator

- freezer means a unit of commercial refrigeration equipment consisting of two or more refrigerated compartments where at least one refrigerated compartment is capable of operating at or above 32 ° F and at least one refrigerated compartment is capable of operating below 32 ° F

.33 

## Difference Between Hybrid and Non
- Hybrid Equipment
Commercial Refrigerator
Freezer Commercial Hybrid Refrigerator Commercial Hybrid Refrigerator
- Freezer A model with one compartment ≥32 ° F and one compartment <32 ° F from the same equipment family A model with two compartments ≥32 ° F from different equipment families A model with one compartment ≥32 ° F and one compartment <32 ° F from different equipment families Meets definition of commercial refrigerator

- freezer, but not commercial hybrid Meets definition of commercial hybrid , but not commercial refrigerator

- freezer Meets definition of commercial refrigerator

- freezer and commercial hybrid

0 F 38 F 38 F 38 F 38 F 0 F

Issue 5: DOE requests comment on the clarity and sufficiency of the proposed definitions for “commercial hybrid” and “commercial refrigerator

freezer.”34 

## Rating, Operating, and Integrated Average Temperatures
Term Rating Temperature Operating Temperature Integrated Average Temperature (IAT) Location 10 CFR 431.66(d)(1) 10 CFR 431.66(d)(1) 10 CFR 431.64(b)(3) Use Describing the IAT at which a model of commercial refrigeration equipment should be evaluated in accordance with the DOE test procedure. Refers to the range of IATs at which the unit of commercial refrigeration equipment is capable of operating. The average refrigerated compartment temperature as determined as a result of testing a given model of commercial refrigeration equipment. Definition at 10 CFR 431.62 The integrated average temperature a unit must maintain during testing. The range of integrated average temperatures at which a commercial refrigeration unit is capable of operating. The average of all the test package temperature measurements taken over the course of the test. 

### New proposed definitions35 

## Defining DOE’s Temperature Classifications

• DOE uses the operating temperature range of the equipment to establish the appropriate equipment class for CRE basic models based on the standards table at 10 CFR 431.66(d)(1).

Term Commercial Refrigerator Commercial Freezer Commercial Refrigerator

- Freezer Ice Cream Freezer

Operating Temperature ≥ 32 ° F < 32 ° F ≥ 32 ° F and < 32 ° F ≤

- 5 ° F

Definition at 10 CFR 431.62 A unit of commercial refrigeration equipment in which all refrigerated compartments in the unit are capable of operating at or above 32 ° F. A unit of commercial refrigeration equipment in which all refrigerated compartments in the unit are capable of operating below 32 ° F. As stated on previous slide

. A commercial freezer that is designed to operate at or below

- 5 ° F and that the manufacturer designs, markets, or intends for the storing, displaying, or dispensing of ice cream. 

### New proposed definitions36 

## Variable Temperature Equipment

• S ome models feature operating temperature range s that cause the models to span multiple equipment classes. For example, a CRE model with an operating temperature range of >15 F and <36 F meets the definition of both a commercial refrigerator and a commercial freezer.

• DOE proposes that equipment capable of operating within multiple equipment classes would have to be tested and certified as each of these equipment classes to demonstrate compliance with DOE’s energy conservation standards.

• The CRE model described above would need to be tested and certified as both a commercial refrigerator and a commercial freezer.
Issue 6: DOE requests comment on its proposed definitions for “operating temperature” and “rating temperature,” and its proposal to clarify the relationship between integrated average temperature and rating temperature. DOE also requests comment on its proposed definitions of “commercial refrigerator” and “commercial freezer.”37 

## Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure
5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information38 

## Treatment of Equipment Features/Accessories

• During the 2013 negotiated rulemaking for certification of commercial heating, ventilation, air conditioning, refrigeration, and water heating equipment, issues were raised by stakeholders regarding the treatment during the DOE test procedure of specific features, components, and accessories which may be in place on certain basic models of commercial refrigeration equipment (Docket No. EERE

- 2013

- BT

- NOC

- 0023).

• The ensuing slides discuss specific features, components, and accessories, and present proposals on how these items should be treated under the existing and any amended DOE test procedure provisions . These proposals reflect positions previously agreed upon during the negotiations.39 

## Customer Display Signs/Lights

• Description: Some customers may wish to add additional exterior signage, outside of the body of the refrigerated cabinet, for the purposes of advertising the product inside. This lighting and signage is optional and is not integral to the cabinet. Further, this auxiliary signage does not serve to illuminate product inside the body of the cabinet.

• Proposal: Supplemental lighting that exists solely for the purposes of advertising or drawing attention to the case and is not integral to the case would not be operated during testing under the DOE test procedure.40 

## Condensate Pan Heaters and Pumps

• Description : In many types of equipment, defrost meltwater is collected in a pan beneath the unit. Some models of commercial refrigeration equipment come equipped with electric resistance heaters that evaporate this water out of the pan and into the ambient air. Other models may come equipped with pumps, which pump meltwater to an external drain.41 

## Condensate Pan Heaters and Pumps

• Proposal : Heaters and condensate pumps must be installed and operational during the entire test (per section 6.1.1, “Accessories,” of ASHRAE 72

- 2005).

– The “entire test” includes stabilization (including pull

- down), steady

state, and performance testing periods.

– Prior to the start of the stabilization period, as defined by ASHRAE 72

- 2005, the condensate pan should be dry.

– For the entire period of the test following the start of the stabilization period, any condensate moisture generated should be allowed to accumulate in the pan, as it would during normal operations.

– Water should not be manually added to or removed from the condensate pan at any time during the entire test.42 

## Anti
- Sweat Door Heaters

• Description: Many transparent

- door cases come equipped with anti

- sweat electric resistance heaters that serve to evaporate any water that condenses on the transparent surface of the door during operation. In some instances, manufacturers may equip their cases with higher

- powered anti

- sweat heaters in anticipation of potential adverse operating conditions.43 

## Anti
- Sweat Door Heaters

• Proposal : DOE proposes that anti

- sweat heaters should be operational during testing under the DOE test procedure.

– Models with a user

- selectable setting must be turned on and set to the maximum usage position.

– Models featuring an automatic, non - user - adjustable controller that turns on or off based on environmental conditions must be operating in the automatic state.

– If a unit is not shipped with a controller from the point of manufacture, and is intended to be used with a controller, the manufacturer must make representations of the basic model based upon the rated performance of that basic model as tested when equipped with an appropriate controller.44 

## Ultraviolet Lights

• Description: Some manufacturers equip certain models of commercial refrigeration equipment with ultraviolet lights, which can be operated by end users to neutralize pathogens and ensure case cleanliness.

• Proposal: Ultraviolet lights should not be turned on during the conduct of the test procedure.45 

## Illuminated Temperature Displays and Alarms

• Description: Manufacturers may equip some commercial refrigeration equipment models with illuminated displays that provide visual information to the equipment operator regarding, for example, the temperature inside the refrigerated case. Manufacturers may also offer alarms that notify operators if the case temperature falls outside of a specified range.

• Proposal: These items should be enabled during the test as they would be during normal field operation.46 

## Condenser Filters

• Description: Manufacturers may offer models equipped with non - permanent filters over a model's condenser coil to prevent particulates such as flour from blocking the condenser coil and reducing airflow.

• Proposal: Non

- permanent filters should be removed during the test.47 

## Refrigeration System Security Covers

• Description: Manufacturers may offer for sale with a basic model an option to include straps or other devices to secure the condensing unit and prevent theft or tampering.

• Proposal: Security devices should be removed during testing under the DOE test procedure.48 

## Grill Options

• Description : Manufacturers may offer for sale with a basic model optional grills that are used to direct airflow in unique applications, such as when a unit is mounted close to a rear wall and the airflow needs to be directed upwards.

• Proposal: If present, non

- standard grills should be removed during testing.49 

## Coated Coils

• Description: These coils, generally specified for use in units that will be subjected to environments in which acids or oxidizers are present, are treated with an additional coating (such as a layer of epoxy or polymer) as a barrier to protect the bare metal of the coil from deterioration through environmental contact.

• The existing test procedure accurately accounts for the performance of all types of coils, including coated coils.50 

## Misting or Humidification Systems

• Description : Manufacturers may offer for sale with a basic model optional misting or humidification systems, which dispense a water mist used to maintain the optimal quality of products. These are commonly used with cases containing, for example, fresh produce, meat, or seafood.

• Proposal: If present , these systems should be inactive during testing.51 

## Air Purifiers

• Description : Manufacturers may offer for sale purifying systems to remove contaminants from air recirculated within the interior of a refrigerated case.

• Proposal: Air purifiers should be inactive during testing under the DOE test procedure.52 

## General Purpose Outlets

• Description: Some commercial refrigeration equipment may be offered for sale with integrated general purpose electrical outlets, which may be used to power additional equipment such as scales or slicers.

• Proposal: While testing using the DOE test procedure, no external load should be connected to the general purpose outlets contained within a unit.53 

## Crankcase Heaters

• Description : Some models of self

- contained commercial refrigeration equipment feature electric resistance heaters designed to keep the compressor warm in order to maintain the refrigerant contained within at optimal conditions when the unit is operating at low ambient temperatures.

• Proposal: If present, crankcase heaters should be operational during the test. Under this proposal, if a control system, such as a thermostat or electronic controller, is used to modulate the operation of the crankcase heater, it should be used as intended according to the manufacturer's instructions.54 

## Use of Energy Management Systems During Testing

• DOE TP specifies that all devices that would normally be used in the field must be installed and operated in the same manner during the test unless this is inconsistent with any requirement of the test procedure

.

– This includes energy management systems

.



### • If normal field installation or operation would be inconsistent with any test procedure requirement, then the specific function that causes inconsistency must be disabled.

– Example:

• If EMS raises or lowers the cabinet temperature such that the applicable IAT cannot be maintained throughout the test.

• In this case the function of EMS that varies temperature must be disabled.

• Other functions may remain enabled, provided they do not violate TP.

• If functions cannot be controlled separately, all must be disabled.55 

## Use of Lighting During Testing

• The DOE test procedure specifies that all devices that would normally be used in the field must be installed and operated in the same manner during the test

.

– ARI Standard 1200

- 2006 and AHRI Standard 1200

- 2010 specify that the total daily energy consumption (TDEC) or calculated daily energy consumption (CDEC) for self

- contained or remote condensing cases shall include lighting loads.

– ASHRAE 72

- 2005 specifies in section 6.1.1, that “all standard components, such as...lights...shall be installed and used as recommended by the manufacturer .”

– These explicit references to case lighting indicate that the energy consumption associated with lights installed on a model of commercial refrigeration equipment is intended to be captured during testing.56 

## Use of Lighting During Testing

• In the 2012 TP final rule, DOE adopted specific provisions for the treatment of lighting occupancy sensors and scheduled controls.

– DOE established specific time periods during which these variable lights may be turned off or dimmed during the test.



### • DOE wishes to clarify that a mechanical light switch does not constitute an energy management system.

– Models of commercial refrigeration equipment with lighting installed on the case and no energy management system should be tested with lights on to their maximum illumination level for the duration of the test.

– Any lighting controls with a user

- selectable setting must be turned on and set to the maximum usage position.

– Exception: models with solid doors with lighting controls that automatically turn off internal case lighting when the door is closed.57 

## Use of Lighting During Testing

• The NOPR includes proposals to clarify lighting operation:

Appendix A • All lighting must be energized to the maximum illumination level throughout the whole test.

• An exception is proposed for closed solid

- door models that include

automatic controls that disable case lighting when the door is closed. Appendix B • All lighting shall be energized to its maximum illumination level, except for when a model is equipped with lighting occupancy sensors and/or scheduled controls, or when a model is outfitted with other permanently installed, automatic energy management systems that control lighting.

• If the unit includes an automatic lighting control system, it should be

enabled during test. If the unit is equipped with lighting occupancy sensors and controls, it should be tested in accordance with the provisions adopted in the 2012 test procedure final rule.58 

## Test Package Temperatures

• Stakeholders have inquired whether the DOE test procedure has specific temperature requirements for the test simulators and filler packages that must be met prior to loading the packages

• ASHRAE 72

- 2005 provides specific instruction as to the loading of test simulators and filler packages (section 6.2) and temperature stabilization (section 7.4).

– Unit must run until “steady state” conditions, as defined in section 3, are achieved.

– After steady

- state operation is reached, unit must operate for another period of 12 hours before it is deemed to be stabilized.



### • DOE does not believe the product simulators or test packages need to be a specified temperature prior to loading.59 

## Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure
5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information60 

## Rounding of Test Results & Certified Ratings

• The current DOE test procedure, which incorporates by reference provisions from ARI Standard 1200

- 2006 and AHRI Standard 1200

- 2010, requires that the energy consumption for covered commercial refrigeration equipment be expressed in terms of kilowatt

- hours (kWh) per day and must be stated in increments of 0.01 kWh per day.

• DOE is proposing clarifications to 10 CFR 431.64 that explicitly establish that all calculations must be carried out using raw, measured values, and the results from the testing of a single unit of a given basic model should be expressed in 0.01 kWh per day.

• T hese calculation and rounding requirements are also applicable to reporting certified ratings for a basic model at 10 CFR 429.42 , and DOE proposes to update the language commensurately

.

Issue 7: DOE requests comment on its proposed rounding provisions for commercial refrigeration equipment.61 

## 2012 Test Procedure LAPT Provisions

• In the 2012 test procedure final rule, DOE established provisions for testing equipment that is not capable of achieving the prescribed rating temperature for its respective equipment class at the lowest application product temperature (LAPT). 77 FR at 10320 (Feb. 21, 2012).

• DOE defines LAPT as follows:

10 CFR 431.62

Lowest application product temperature means the integrated average temperature closest to the specified rating temperature for a given piece of equipment achievable and repeatable, such that the integrated average temperature of a given unit is within ± 2 ° F of the average of all integrated average temperature values for that basic model.62 

## Testing at the Lowest Application Product Temperature

• If a certain basic model of commercial refrigeration equipment cannot be operated at the prescribed rating temperature for its given equipment class, the manufacturer must test the equipment at the LAPT.

– A ll o the r requirements of the DOE test procedure must be met , except that the rating temperature for this equipment will be the LAPT and the IAT measured during the test will be within 2 F of the LAPT instead of within 2 F of the prescribed rating temperature for that equipment class.63 

## Clarifying the Lowest Application Product Temperature

• The LAPT is the lowest temperature at which a given basic model is capable of operating.

– For example, if a basic model of freezer has an operating range from 8 to 28 F, and thus cannot operate at the prescribed rating temperature of 0 F, that basic model would be tested at its LAPT of 8 F.

– In this case, if DOE were to randomly select a representative unit of this model to test for compliance purposes, DOE should be able to test the unit such that an integrated average temperature between 6 and 10 F is maintained over the duration of the test procedure after setting the unit to maintain an internal refrigerated temperature of 8 F. The selected unit must not be able to operate at 0 F.

– For many cases this will be the lowest thermostat setting and will be achieved by turning the thermostat down all the way.

– For cases without thermostats, DOE established specific provisions for establishing the LAPT. 77 FR 10304

- 5 (Feb. 21, 2013).64 

## Revised LAPT Definition

• To clarify the intent and application of the LAPT, DOE proposes to modify the definition of LAPT as follows:

• Due to the explicit reference of ASHRAE 72

- 2005, DOE proposes to incorporate by reference ASHRAE 72

- 2005 at 10 CFR 431.63.

Issue 8: DOE requests comment on its proposed modification to the LAPT definition and its proposal to incorporate by reference ASHRAE 72

- 2005.



### Lowest application product temperature means the lowest integrated average temperature at which a given basic model is capable of consistently operating (i.e., maintaining so as to comply with the steady

- state stabilization requirements specified in ASHRAE 72

- 2005 (as incorporated by reference, see § 431.63) for the purposes of testing under the DOE test procedure).65 

## AHRI Standard 1200
- 2010 Interpretations

• Since publication of the 2012 test procedure final rule, AHRI has published five interpretations to AHRI Standard 1200

- 2010.

– Interpretations 1 through 4 to AHRI Standard 1200

- 2010 were issued by AHRI to clarify the method for calculation of Total Display Area ( TDA )

.

– Interpretation 5 to AHRI Standard 1200

- 2010 clarifies the approach for testing commercial refrigeration equipment with two independent refrigeration sections.66 

## AHRI Standard 1200
- 2010 Interpretations

• G uidance developed and issued by industry regarding referenced industry standards can be helpful in identifying areas where DOE’s existing test procedures may be misinterpreted.

• However, it is not official guidance with respect to the DOE test procedure unless formally put forth by DOE.

• DOE has reviewed the AHRI i nterpretations and believes Interpretations 1, 3, 4, and 5 to the AHRI standard also apply to ARI Standard 1200

- 2006 and the DOE test procedure.

• Interpretation 2 is inconsistent with the way DOE determines TDA for the purposes of compliance with energy conservation standards.67 

## Measuring Total Display Area

• ARI Standard 1200

- 2006 , appendix D, as incorporated by reference by the DOE at 10 CFR 431.63, provides

– a definition for TDA as follows:

– and instructions on the calculation of TDA: 

### Total Display Area (TDA) is the sum of the projected area(s) for visible product
.

TDA = Dh*L + Ae , where Ae = Projected area from visible product through end walls Dh = Dimension of projected visible product L = Length of Commercial Refrigerated Display Merchandiser68 

## Scenario 1: Case Wall Flush with Visible Area

Boundary of refrigerated volume Boundary of refrigerated volume 

## A

B D C E

For the purposes of calculating TDA, should length “L” in AHRI 1200 be measured as:

– Length “A”

– inside wall to inside wall of refrigerated volume;

– Length “B”

– entire continuous length containing visible area (same as “A” here); or

– Lengths “C”+”D”+”E”

– sum of lengths of visible areas? Vertical case,

front view69 

## Scenario 2: Case Body Overhangs Refrigerated Volume

Boundary of refrigerated volume Boundary of refrigerated volume 

## A

B D C E

For the purposes of calculating TDA, should length “L” in AHRI 1200 be measured as:

– Length “A”

– inside wall to inside wall of refrigerated volume;

– Length “B”

– entire continuous length containing visible area; or

– Lengths “C”+”D”+”E”

– sum of lengths of visible areas? Vertical case,

front view70 

## Scenario 3: Case Body Overhangs Refrigerated Volume

Boundary of refrigerated volume Boundary of refrigerated volume 

## A

B C D

For the purposes of calculating TDA, should length “L” in AHRI 1200 be measured as:

– Length “A”

– inside wall to inside wall of refrigerated volume;

– Length “B”

– entire continuous length containing visible area; or

– Lengths “C”+”D”

– sum of lengths of visible areas? Vertical case,

front view71 

## Scenario 4: Visible Area Overhangs Case Body

Boundary of refrigerated volume Boundary of refrigerated volume 

## A

B D C E

For the purposes of calculating TDA, should length “L” in AHRI 1200 be measured as:

– Length “A”

– inside wall to inside wall of refrigerated volume;

– Length “B”

– entire continuous length containing visible area;

– Lengths “C”+”D”+”E”

– sum of lengths of visible areas; or

– Lengths “F”+”G”+”H”

– sum of lengths of visible areas overlooking refrigerated volume? 

## G F H Vertical case,

front view72 

## Compliance Date of Test Procedure Amendments

• DOE also proposes to:

– reorganize the test procedure requirements at 10 CFR 431.64 into new Appendices A and B so they are easier to understand, and

– update the compliance date to reflect that the publication of the energy conservation standards final rule has been extended (Docket No. EERE

- 2010

- BT

- STD

- 0003). Appendix Content Required to be Used as of Appendix A • Te st procedure for commercial refrigeration equipment established in the 2006 test procedure final rule

• Clarifications established as part of this NOPR 30 days after publication of any test procedure final rule.

Appendix B • Te st procedure amendments adopted in the 2012 test procedure final rule

• Clarifications established as part of this NOPR Compliance date of any amended standards established in the ongoing energy conservation standards rulemaking (Docket No. EERE

- 2010

- BT

- STD

- 0003). Issue 9: DOE requests comment on the reorganization of the test procedure requirements at 10 CFR 431.64 into Appendix A and Appendix B.73 

## Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure
5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information74 

## Request for Closing Remarks

At this time DOE welcomes any closing remarks from interested parties.75 

## CRE TP Web Pages and DOE Contacts

• DOE Appliance Standards webpage:

– http://www1.eere.energy.gov/buildings/appliance_standards/

• Commercial Refrigeration Equipment Test Procedure webpage:

– http:// www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=80

• Contact Charles Llenza, Commercial Refrigeration Project Manager, from the Appliance Standards Program for additional information:

– commercial_refrigeration_equipment@ee.doe.gov

• Contact Ashley Armstrong, Test Procedure Team Lead, from the Appliance Standards Program for additional information:

– Ashley.Armstrong@ee.doe.gov