Charles Llenza

BUILDING TECHNOLOGIES PROGRAM

June 20, 2013

Energy Conservation Standards for Refrigerated Beverage 

Vending Machines: Framework Public Meeting 
2

Welcome and Introduction

• Introductions (around the room)

• Role of the Facilitator

• Meeting Ground Rules:

– One person speaks at a time & raises hand to be recognized.

– Always state your name for the record since there will be a 

complete transcript of this meeting.

– Be concise, focus on issues & not personalities, and share ‘airtime’.

– Hold any sidebar conversations outside of the meeting room.

– All participants (including Webinar participants) set your phones 

to mute.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Morning Agenda

9:00 – 9:05 am Welcome

9:05 – 9:30 am Opening Remarks, Introductions, and Agenda Review

9:30 – 10:00 am Rulemaking Process Overview

10:00 – 10:30 am Authority and Definitions

10:30 – 10:45 am Break

10:45 – 11:15 am Test Procedure and Test Metrics

11:15 – 11:45 am Market & Technology Assessment, Screening Analysis 

11:45 am – 12:30 pm Engineering Analysis

12:30 – 1:30 pm Break for Lunch
4

Afternoon Agenda

1:30 – 2:00 pm Markups and Energy Use Analyses

2:00 – 2:30 pm Life-Cycle Cost and Payback Period Analysis

2:30 – 2:45 pm Break

2:45 – 3:00 pm Shipments Analysis and National Impact Analysis

3:00 – 3:15 pm Preliminary Manufacturer Impact Analysis

3:15 – 3:30 pm NOPR Analyses

3:30 – 4:00 pm Other Issues and Comments

4:00pm Closing Remarks
5

Opening Remarks

Interested parties who contacted DOE to request an 

opportunity to issue an opening statement should speak 

now.
6

5

3

2

Test Procedure & Test Metrics

Rulemaking Process Overview

Authority & Definitions

1 Introduction

6

Rulemaking Analyses

Public Meeting Agenda

Closing Remarks

4
7

Purpose of the Framework Document Public Meeting

• Present the analytical approaches to be used to 

evaluate energy conservation standards for 

refrigerated beverage vending machines (BVMs)

• Inform interested parties of and facilitate the 

rulemaking process

• Provide a forum for public discussion of rulemaking 

issues

• Encourage interested parties to submit data, 

information, and written comments

Introduction
8

Introduction

Request for Comment 

Item #-#: DOE solicits comment on a range of specific issues 

throughout the Framework document.

• Throughout this presentation, these issues will be highlighted for discussion in 

comment boxes such as this.

• Item numbers correspond to those in the Framework document.

• DOE welcomes comments concerning these specific issues and any other 

issues related to this rulemaking.
9

Instructions for Submitting Comments

• In all correspondence, please refer to this Refrigerated Beverage Vending Machine 

Rulemaking by:

– Docket # EERE-2013-BT-STD-0022, and/or RIN 1904-AD00

• Electronic: BVM2013STD0022@EE.Doe.Gov or www.regulations.gov

• Postal Mail: Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW.

Washington, D.C. 20585-0121

• Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., Suite 600

• Phone: (202) 586-2945

Introduction

Comment period closes July 19, 2013
10

2 Rulemaking Process Overview

1 Introduction

Public Meeting Agenda

5

3

Test Procedure & Test Metrics

Authority & Definitions

6

Rulemaking Analyses

Closing Remarks

4
11

Standards Development

• The Energy Policy and Conservation Act of 1975 (EPCA), as amended, directs DOE 

to prescribe energy conservation standards for beverage vending machines 

(42 U.S.C. 6295(v))

• EPCA directs DOE to develop new or amended standards designed to achieve the 

maximum improvement in energy efficiency that is technologically feasible and 

economically justified

• DOE’s rulemaking process provides the schedule and analyses 

• Under 42 U.S.C 6295(m)(1), within 6 years after issuance of any final rule 

establishing or amending a standard, DOE is required to publish: 

(A) A notice of the determination of the Secretary of Energy (Secretary) that energy 

conservation standards for the product do not need to be amended, based on the 

criteria established under subsection (n)(2); or

(B) A notice of proposed rulemaking including new proposed energy conservation 

standards based on the criteria established under subsection (o) and the procedures 

established under subsection (p)

Rulemaking Process Overview
12

• EPCA directs DOE to consider seven factors for analysis when setting 

technologically feasible and economically justifiable standards:

EPCA Requirement Corresponding DOE Analyses

1. Economic impact on consumers and 

manufacturers

• Life-Cycle Cost (LCC) Analysis

• Manufacturer Impact Analysis (MIA)

2. Lifetime operating cost savings compared to 

increased product cost

• LCC Analysis

3. Total projected energy savings • National Impact Analysis (NIA)

4. Impact on utility or performance

• Engineering Analysis

• Screening Analysis

5. Impact of any lessening of competition • MIA

6. Need for national energy conservation • NIA

7. Other factors the Secretary considers relevant

• Emissions Analysis

• Utility Impact Analysis 

• Employment Impact Analysis

Rulemaking Process Overview

Source: (42 U.S.C. § 6295(o)(2)(B)(i) and 42 U.S.C. § 6316(a))
13

• TP and ECS rulemakings are separate processes but have integrated 

timelines

• The TP rulemaking timeline duration is about 1.5 years from cradle to grave

• The ECS rulemaking timeline duration is about 3 years from cradle to grave

• For additional information on the rulemaking process go to:

http://www1.eere.energy.gov/buildings/appliance_standards/standards_dev_and_revision.html

Energy Conservation 

Standards (ECS)

Test Procedure (TP) Final 

Rule NOPR 

Test Procedure and Standard Rulemakings Timelines

Framework

Document Preliminary 

Analysis

NOPR Final

Rule

Rulemaking Process Overview
14

Framework Document

• Provides an overview of the rulemaking process and encourages early 

participation from interested parties

• Invites comments on proposed approach and issues

• Accompanying Federal Register notice of public meeting (NOPM) – 78 FR 33262, 

June 4, 2013

– Gives notice of the public meeting and availability of the Framework 

document being discussed today

– Encourages interested parties to submit comments

Rulemaking Process Overview

Framework 

Document

Preliminary 

Analysis NOPR Final Rule

Today
15

Preliminary Analysis Document

Rulemaking Process Overview

Framework 

Document

Preliminary 

Analysis NOPR Final Rule

– Design options to increase efficiency 

(engineering analysis)

– Manufacturer-to-user markups

– Energy use

– Consumer LCC and payback period (PBP)

– Shipments

– National impacts, including national 

energy savings (NES) and consumer net 

present value (NPV)

– Preliminary analysis of manufacturer 

impacts

– Discussion of comments received in 

response to the Framework document

• Accompanying Federal Register NOPM – Planned Q3 CY 2014

– Gives notice of the public meeting and availability of the technical 

support document (TSD)

– Encourages interested parties to submit comments

• Analysis
16

Notice of Proposed Rulemaking (NOPR) Document

• Discussion of comments received in response to preliminary analysis TSD

• Analysis of the impacts of potential standards on consumers, manufacturers, and 

the Nation and weighting of these impacts

• Any proposed standard levels for public comment

• Accompanying Federal Register publication – Planned Q3 CY 2015

– Gives notice of the public meeting and availability of the revised TSD

– Encourages interested parties to submit comments

Rulemaking Process Overview

Framework 

Document

Preliminary 

Analysis NOPR Final Rule
17

Final Rule Publication

• Discussion of comments received in response to the NOPR

– DOE will consider all written and verbal input in preparing the final rule 

• Revise analysis of the impacts of standards and weighing of these impacts of the 

final rule

• Determine any standard levels DOE will adopt

• Establish the compliance date for any adopted standards

• Accompanying Federal Register final rule – Planned Q3 CY 2016

Rulemaking Process Overview

Framework 

Document

Preliminary 

Analysis NOPR Final Rule
18

2013

Framework 

Document Public 

Meeting

June 2013

Preliminary Analysis

Public Meeting

Planned – Q3 2014

NOPR

Public Meeting

Planned – Q3 2015

2015 2016 2019

Proposed Energy 

Conservation Standard 

Final Rule Compliance 

Date Q3 2019

2014

TP NOPR

Public Meeting

Planned – Q4 2013

Rulemaking Schedule
19

5

3

2 Rulemaking Process Overview

Authority & Definitions

1 Introduction

6

Rulemaking Analyses

Public Meeting Agenda

Closing Remarks

4 Test Procedure & Test Metrics
20

Authority and Background – Overview

• Title III of EPCA sets forth a variety of provisions designed to improve the 

energy efficiency of various products and equipment

• Part B of Title III provides for the “Energy Conservation Program for 

Consumer Products Other Than Automobiles” (42 U.S.C. 6291–6309) 

• As part of this program, EPCA directed DOE to prescribe energy 

conservation standards for beverage vending machines (42 U.S.C. 6295(v)) 

Authority & Definitions
21

Standards Authority and Background

• DOE conducted a rulemaking from 2006-2009 that culminated in 

standards set in the 2009 BVM final rule, August 2009

• Within 6 years after issuance of any final rule establishing or amending a 

standard, DOE is required to publish:

– A notice of the determination of the Secretary of Energy that energy 

conservation standards for the product do not need to be amended, based on 

the criteria established under subsection (n)(2); or

– A notice of proposed rulemaking including new proposed energy conservation 

standards based on the criteria established under subsection (o) and the 

procedures established under subsection (p) 42 U.S.C. 6295(m)(1)

• DOE is undertaking this rulemaking to meet this EPCA requirement

Authority & Definitions
22

• Manufacturers must use a DOE-prescribed test procedure to establish 

compliance with DOE standards for refrigerated beverage vending 

machines

• The current BVM test procedure published December 8, 2006

– At least once every 7 years, the Secretary shall review test procedures for all 

covered products and—

(i) amend test procedures with respect to any covered product, if the Secretary 

determines that amended test procedures would more accurately or fully comply 

with the requirements of paragraph (3); or 

(ii) publish notice in the Federal Register of any determination not to amend a test 

procedure 42 U.S.C. 6314(a)(1)(A) 

• DOE is undertaking a rulemaking to meet this EPCA requirement

• DOE has determined these review cycles to have been initiated by the 

passage of EISA on December 19, 2007

Test Procedure Authority and Background

Authority & Definitions
23

Definitions

• EPCA definition –

- The term ‘refrigerated bottled or canned beverage vending machine’ means a 

commercial refrigerator that cools bottled or canned beverages and dispenses the 

bottled or canned beverages on payment 

(42 U.S.C. 6291(40))

• Definitions added to 10 CFR 431.292 in 2009 BVM final rule –

- Bottled or canned beverage means a beverage in a sealed container

- Class A means a refrigerated bottled or canned beverage vending machine that is fully 

cooled, and is not a combination vending machine

- Class B means any refrigerated bottled or canned beverage vending machine not 

considered to be Class A, and is not a combination vending machine

- Combination vending machine means a refrigerated bottled or canned beverage vending 

machine that also has nonrefrigerated volumes for the purpose of vending other, non-

“sealed beverage” merchandise

- V means the refrigerated volume (ft3) of the refrigerated bottled or canned beverage 

vending machine, as measured by ANSI/AHAM HRF-1-2004

Authority & Definitions
24

Coverage

• All equipment that meets the definition of refrigerated bottled or canned 

beverage vending machine is covered by this rulemaking

• Active standards exist for Class A and Class B vending machines

- Compliance date of August 31, 2012

• The 2009 BVM final rule included a placeholder reserving standards for 

combination vending machines

Authority & Definitions
25

4

3

2

Test Procedure & Test Metrics

Rulemaking Process Overview

Authority & Definitions

5 Rulemaking Analyses

Public Meeting Agenda

6 Closing Remarks

1 Introduction
26

Current Test Procedure

• Published December 2006 

• Adopted ANSI/ASHRAE 32.1-2004 as the DOE test procedure

- DOE adopted a modification to test equipment with dual nameplate voltages 

at the lower of the two voltages only

• References 5.2 of AHAM HRF-1-2004 for measuring refrigerated volume

Test Procedure & Test Metrics

Test Metric

• Daily energy consumption (DEC), in kWh/day
27

Potential Test Procedure Updates, Clarifications, and 

Modifications

1) Updating the referenced method of test

- ANSI/ASHRAE 32.1-2010 was issued to supersede ANSI/ASHRAE 32.1-2004

2) Clarifying the next-to-vend beverage temperature test condition

- No time averaging of temperature data

3) Testing at a 90 °F ambient test condition

- Elimination of the 90 °F ambient test condition requirement

Test Procedure & Test Metrics
28

Potential Test Procedure Updates, Clarifications, and 

Modifications, cont.

4) Lowest application product temperature

- Accommodation of beverage vending machines that do not dispense product 

at 36 °F

5) Product temperature measurements

- Measurement of beverage temperatures other than those next-to-vend could 

assist in determining product class

Test Procedure & Test Metrics
29

Potential Test Procedure Updates, Clarifications, and 

Modifications, cont.

6) Expanded range of lighting and control settings 

- Current DOE test procedure requires operation with normal lighting and 

control settings, using only those energy management controls that are 

permanently operational and not capable of being adjusted by a machine 

operator

- No specification for testing machines with permanently operational controls 

that can be adjusted 

7) Creating a provision to measure the impact of low-power modes of 

operation

- Account for energy savings from controls, including those that can be disabled

Test Procedure & Test Metrics
30

Test Procedure & Test Metrics

Request for Comment 

Item 1-1: DOE requests comment regarding adoption of updated test procedure 

for the beverage vending machines covered under this rulemaking.

Item 1-2: DOE requests comment on the possible elimination of the 

requirement to test units at 90 °F.

Item 1-3: DOE requests comment regarding a requirement of measurement of 

product temperatures at other than the next-to-vend positions.

Item 1-4: DOE requests comment on the current utilization of low-power modes 

in certification testing. Do any current models meet the requirements of the 

current test procedure regarding energy management controls and utilize a lowpower mode during the test? 
31

Test Procedure & Test Metrics

Request for Comment 

Item 1-5: DOE requests comment on the testing of low-power modes in a 

revised test procedure. What are the typical functions of low-power mode in 

beverage vending machines? Are these low-power modes triggered by 

scheduled timers, activity, motion sensors, or other environment or state 

changes? What lengths of time should DOE consider for the full-power mode 

and low-power mode?

Item 1-6: DOE requests comment on the applicability of the current test 

procedure, and all test procedure modifications under consideration, to 

combination vending machines.

Item 1-7: DOE requests comment on its proposal to consider modifications to 

the test procedure to account for energy management systems.
32

4

3

2

Test Procedure & Test Metrics

Rulemaking Process Overview

Authority & Definitions

1 Introduction

5 Rulemaking Analyses

Public Meeting Agenda

6 Closing Remarks
33

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
34

• Purpose:

– Characterize the BVM markets and the measures to improve efficiency

• Method: 

– Identify and characterize manufacturers of beverage vending machines

– Estimate shipments and trends in the market

– Identify technologies that could improve efficiency

– Identify regulatory and non-regulatory initiatives intended to improve the 

efficiency of the equipment covered under this rulemaking

Market and Technology Assessment
35

Market and Technology Assessment

Request for Comment 

Item 3-1: DOE seeks information that would contribute to the market 

assessment (e.g., the manufacturers of this equipment in the United States and 

the equipment they sell, by equipment class). It is particularly important that 

DOE be aware of the major and small/niche manufacturers.

Item 3-2: DOE seeks information on historical annual equipment shipments 

(both domestic and imports) by equipment class and the corresponding 

efficiency distributions of these shipments. 

Item 3-3: DOE seeks information on the proportion of equipment shipped 

annually that replaces existing equipment, for each equipment class.
36

Market and Technology Assessment

Equipment Characteristics

• Refrigerated beverage vending machine characteristics include:

– Cooling mechanism: fully cooled or not (i.e., zone cooled)

– Door type: transparent or opaque

– Storage type: stack or shelf storage

– Machine-use designation: indoor/outdoor or indoor only

– Presence of separate, non-refrigerated volume

– Type of products dispensed
37

Market and Technology Assessment

Request for Comment 

Item 3-4: DOE requests comment on whether all transparent-front beverage 

vending machines currently available on the market are fully cooled. 

Item 3-5: DOE requests comment on whether all opaque-front beverage 

vending machines currently available on the market are zone cooled. 

Item 3-6: DOE requests information on perishable items in beverage vending 

machines. Do machines that sell perishable items (in addition to or including 

beverages) ship with different software or controls than machines that sell only 

non-perishable items? Are they rated differently, such as to food safety 

specifications? What portion of the BVM market is composed of machines that 

sell perishable items? 
38

Market and Technology Assessment

Equipment Classes

• DOE divides covered equipment into classes based on performancerelated features that justify different standard levels, such as features 

affecting consumer utility (42 U.S.C. 6295(q))

• DOE establishes separate energy conservation standards for each 

equipment class

• In the 2009 final rule, DOE established three equipment classes 

• DOE could also further subdivide existing classes, were it warranted due 

to inherent differences within equipment currently covered by a class 
39

Market and Technology Assessment

Equipment Classes, cont.

• Equipment class distinctions in the 2009 BVM final rule were based on:

– Cooling mechanism: fully cooled or not (i.e., zone cooled)

– Presence of separate, non-refrigerated volume

• Fully cooled currently has no statutory definition

• DOE is considering the following definition:

Fully-cooled beverage vending machine: a refrigerated bottled or canned 

beverage vending machine within which each item in the beverage vending 

machine is brought to and stored at temperatures that fall within plus or minus 

2°F of the average beverage temperature, which is the average of the 

temperatures of all the items in the next-to-be-vended position for each 

selection.
40

Market and Technology Assessment

Request for Comment 

Item 3-7: DOE seeks comment on the equipment classes for beverage vending 

machines, and on the criteria used in creating the classes. Are the equipment 

classes appropriate? Are there other factors that should be considered in 

equipment class distinctions and definitions?

Item 3-8: DOE seeks comment regarding the possible use of alternative 

equipment classes in this rulemaking. Specifically, are there other equipment 

characteristics that should be considered for equipment class distinctions and 

definitions? 
41

Market and Technology Assessment

Request for Comment 

Item 3-9: DOE seeks comment on the considered definition of “fully cooled 

vending machine.” Does the current language reflect what is used in industry? 

Item 3-10: DOE requests comment on the creation of a new equipment class for 

machines that are manufactured and sold to vend perishable items (including or 

in addition to beverages). How should DOE define equipment sold to vend 

perishable items? Does this equipment obtain other certifications for vending 

perishable items? Is it common for beverage vending machines to vend both 

perishable and non-perishable items? Is the same beverage vending machine 

offered to vend both perishable and non-perishable items (i.e., the equipment 

is not currently differentiated in the marketplace)? 
42

Higher efficiency lighting Defrost mechanism

Higher efficiency lighting ballasts Defrost-cycle control

Remote lighting ballast location Higher efficiency compressors

Higher efficiency expansion valves Variable-speed compressors

Higher efficiency evaporator fan motors Higher efficiency condenser fan motors

Increased evaporator surface area or 

efficiency

Machine-insulation thickness increases or 

improved insulating materials

Evaporator-fan-motor controllers Suction-line heat exchangers

Higher efficiency evaporator fan blades Condenser fan motor controllers

Low pressure-differential evaporators Higher efficiency condenser fan blades

Anti-sweat heater controls Lighting controls, timers, and/or sensors

Increased condenser surface area or 

efficiency

Low-power modes incorporating 

refrigeration controls, timers, and/or 

sensors

Improved Glass Pack

Technology Options to Improve Efficiency

Market and Technology Assessment
43

Market and Technology Assessment

Request for Comment 

Item 3-11: DOE requests comment on whether any technologies or designs 

should be added to or removed from the above list. For example, do any of the 

technologies above raise issues with proprietary designs or issues where testing 

pursuant to the DOE test procedure does not reflect a change in measured 

energy efficiency?

Item 3-12: DOE requests comments, recommendations, and data on max-tech 

levels for Class A equipment, Class B equipment, and combination vending 

machines. 

Item 3-13: DOE requests comment on whether max-tech levels can only be 

achieved using proprietary designs or whether there are alternative design 

paths available that can achieve the same energy use level.
44

Market and Technology Assessment

Request for Comment 

Item 3-14: DOE requests comment on whether any technologies or designs 

should be treated individually, or be incorporated into a few standard “design 

packages.” If “design packages” are possible, how should the packages be 

assembled? DOE would develop potential standard levels based on these 

packages, but manufacturers could meet any established standards through the 

use of any design options.

Item 3-15: DOE requests comment on low-power modes. What types of lowpower modes are currently used in the BVM market? Are there other types of 

energy management systems about which DOE should be aware that are 

applicable to beverage vending machines?

Item 3-16: DOE requests comment on whether transparent-front machines 

could be designed with zone cooling.
45

Market and Technology Assessment

Baseline Models

• Represent equipment with the lowest efficiency currently on the market

• DOE will select one baseline model per equipment class

• Where available, DOE typically selects models that just meet current 

energy conservation standards to represent the baseline
46

Market and Technology Assessment

Request for Comment 

Item 3-17: DOE seeks comment on how to select baseline efficiency levels for 

equipment classes without a previous energy conservation standard (e.g., 

combination machines).

Item 3-18: What machine sizes and capacities (cubic feet, vendible capacity) 

should be used as analysis points for each equipment class? 

Item 3-19: DOE seeks information on what particular components and features 

characterize the baseline model in each equipment class (materials, 

dimensions, insulation, refrigerant type, compressors, evaporators, condensers, 

expansion devices, fans, motors, anti-condensate devices and controls, defrost 

mechanisms and controls, lighting, etc.).
47

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
48

• Purpose:

– Screen out technology options that DOE will not consider in the engineering 

analysis for beverage vending machines

• Method:

– DOE will evaluate each technology option based on the following criteria:

• Technological feasibility

• Practicability to manufacture, install, and service

– Note: Practicability is on a commercial scale at the compliance date of any 

final standards

• Impacts on product utility or available to consumers

• Impact on health and safety

Screening Analysis
49

Screening Analysis

Request for Comment 

Item 4-1: DOE welcomes comments on how the above four screening criteria 

might apply to any additional technology option(s) that an interested party 

recommends to DOE.

Item 4-2: DOE welcomes comments on the applicability of the four screening 

criteria to the technologies listed in the Market and Technology Assessment 

section.
50

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
51

• Develop the cost-efficiency curve, which characterizes the relationship 

between manufacturer selling price (MSP) and energy efficiency

• The cost-efficiency curves are key inputs for the downstream rulemaking 

analyses 

Rulemaking Analyses

• Life-Cycle Cost and Payback 

Period Analysis

•National Impact Analysis

• Manufacturer Impact 

Analysis 

• Employment Impact 

Analysis

Manufacturer Selling Price –

Efficiency Relationship

Manufacturer 

Selling Price (MSP)

Energy Consumption Level

Engineering Analysis – Purpose 

Engineering Analysis
52

Engineering Analysis Methodology

Define Baseline • Define baseline specifications for each equipment class

• Model the manufacturer production cost (MPC) and energy Model Baseline consumption of the baseline units

• Implement design options one-by-one in order of shortest 

payback to longest payback

• Add the incremental cost of each design option to the 

baseline and recalculate DEC with design options in place

Implement Design 

Options

• Apply manufacturer markup to the MPC to calculate 

manufacturer selling price using manufacturer markup

Calculate 

Manufacturer Selling 

Price

Engineering Analysis
53

Engineering Analysis

Energy Consumption Model

Total Heat 

Load 

[Btu/h]

Component 

Load

[Btu/h]

Non-Electric 

Load

[Btu/h]

Fan Motor 

Heat Load

[Btu/h]

Lighting Heat 

Load

[Btu/h]

Radiation 

Load

[Btu/h]

Conduction 

Load

[Btu/h]

Infiltration 

Load

[Btu/h]

Daily Energy 

Consumption [kWh/day]

Compressor 

Energy 

Consumption 

[kWh/day]

Compressor Model 

(ARI 540)

Electric Energy 

Consumption

[kWh/day]

Heat Load 

[Btu/h]

Legend:

Component 

Energy 

Consumption 

[kWh/day]

Fan Motor 

Energy

 Consumption 

[kWh/day]

Lighting 

Energy 

Consumption 

[kWh/day]
54

Engineering Analysis

Request for Comment 

Item 5-1: Within each equipment class, for energy consumption levels below 

the baseline, DOE seeks information on daily energy consumption and on 

incremental manufacturing costs and components (differentiation in 

components from the baseline, material costs, labor costs, factory overhead 

costs (excluding depreciation), building conversion capital expenditures, 

tooling/equipment conversion capital expenditures, research and development 

(R&D) expenses, marketing expenses, etc.). 

Item 5-2: DOE is also interested in any equipment test data that stakeholders 

can provide (including equipment parameters, test results, etc., and, in the case 

that a test procedure other than the DOE test procedure was used, the test 

procedures used and rating conditions). Test data for the baseline model in each 

equipment class is particularly important. 

Item 5-3: DOE requests feedback on the use of the design-option approach to 

determine the relationship between manufacturer selling price and energy 

efficiency for beverage vending machines.
55

Manufacturing Selling Price

• MSP includes manufacturer production costs (MPC) as well as nonproduction costs, such as maintenance, depreciation, and taxes

• Markups will be used to represent non-production costs and convert the 

MPC to the MSP

• DOE intends to estimate manufacturer markups based on publicly 

available financial information and manufacturer interviews 

Engineering Analysis

Request for Comment 

Item 5-4: DOE seeks comment on the markup approach proposed for 

developing estimates of manufacturer selling prices.
56

• DOE considers in its engineering and economic analyses all design options 

that have not been screened out, including proprietary designs

• DOE will consider proprietary designs in the subsequent analyses only if 

they are not part of a unique path to a given efficiency level

Engineering Analysis

Proprietary Designs
57

Engineering Analysis

Request for Comment 

Item 5-5: Are there proprietary designs that DOE should consider for any of the 

equipment under consideration by this rulemaking? If so, how should DOE 

acquire the cost data necessary for evaluating these designs? 

Item 5-6: Are there alternative design paths that can achieve the same level of 

max-tech energy use (energy efficiency) as those using proprietary designs?
58

Selecting Representative Unit Sizes

• Within each equipment class, DOE will select representative unit beverage 

vending machines in size ranges that represent typical units of that 

equipment class

• The representative unit sizes analyzed for the 2009 BVM final rule are 

shown in the table below

Engineering Analysis

Class A Class B

Small Medium Large Small Medium Large

Vendible Capacity

number of cans 300 400 500 450 650 800

Refrigerated Volume

ft3 17 22 34 17 22 26
59

Engineering Analysis

Request for Comment 

Item 5-7: DOE requests feedback on representative sizes. Are the representative 

sizes used for the 2009 BVM final rule adequate, and should they be retained or 

modified? 

Item 5-8: If DOE were to analyze a combination equipment class, perishables 

(including or in addition to beverages) equipment class, or other new 

equipment class, what should be the relevant representative sizes for that 

class?
60

Max-Tech

• DOE is required to analyze maximum technologically feasible 

(“max-tech”) efficiency levels

• DOE will seek interested party input on the appropriate max-tech levels 

Engineering Analysis
61

Outside Regulatory Changes

• DOE will consider the effects of other DOE energy conservation standards 

and regulatory changes outside DOE’s rulemaking process that can impact 

manufacturers of covered equipment

• Some regulatory changes can also affect the efficiency, energy 

consumption, and/or engineering costs of the beverage vending machines 

covered under this rulemaking

• DOE will attempt to identify any outside engineering issues that could 

impact the engineering analysis

Engineering Analysis
62

Engineering Analysis

Request for Comment 

Item 5-9: DOE requests information on the use of alternative refrigerants in 

beverage vending machines, including shipment, cost, and energy consumption 

information.

Item 5-10: Are there additional regulatory issues that DOE should consider in its 

analysis of beverage vending machines? Do the issues discussed in this section 

affect shipments, cost or energy efficiency?
63

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
64

• Purpose:

– Estimate actual user purchase prices from manufacturer selling prices of 

baseline and higher efficiency designs of equipment

• Method:

– Identify distribution channels and estimate share of each channel in the 

aggregate sales volume

– Estimate markup values for each level in the identified distribution channels

Markups Analysis
65

Identified Distribution Channels

Markups Analysis

• Equipment Manufacturer → Vending Machine Operator (e.g., bottler, 

beverage distributor)

• Equipment Manufacturer → Distributor → Vending Machine Operator

• Equipment Manufacturer → Site Owner

• Equipment Manufacturer → Distributor → Site Owner
66

Baseline, Incremental, and Overall Markups

• Baseline markups are cost multipliers that convert the MSP of equipment 

at the baseline efficiency level to customer purchase price

• Incremental markups are cost multipliers that convert the increments in 

MSP of equipment at higher efficiency levels (compared to the MSP at 

baseline efficiency level) to corresponding increments in the customer 

purchase price

• Incremental markups are calculated based on the proportion of the 

distribution channel costs that vary only with the equipment costs, such as 

insurance cost, profit, and depreciation 

• Fixed costs such as occupancy expenses and labor expenses do not scale 

with equipment cost and, hence, are not factored into the calculation of 

incremental markups

• Overall markups include the weighted-average distribution channel 

markups, based on distribution channel market shares, and sales tax

Markups Analysis
67

Mark Markups Analysis -Ups Analysis

Request for Comment 

Item 7-1: DOE requests information on the distribution channels described 

above for the beverage vending machines covered under this rulemaking. DOE 

also requests information on the relative fractions of shipments expected for 

each distribution channel. Do distribution channels vary by equipment class?

Item 7-2: DOE requests information on how the overall markups for the 

beverage vending machines covered under this rulemaking may vary for each 

distribution channel.

Item 7-3: DOE requests feedback on its proposal to use baseline and 

incremental markups.

Item 7-4: DOE requests comment on sources of relevant data that could be 

used to calculate markups for each distribution channel.
68

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
69

• Purpose:

– Assess the daily energy use at all the efficiency levels for all the equipment 

classes 

– Provide the basis for the unit energy costs used in the life-cycle cost analysis

Energy Use Analysis

Request for Comment 

Item 6-1: How should DOE treat energy use in “heating mode” for outdoor 

machines in cold climates? 
70

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
71

• Purpose:

– Assess economic impacts of different efficiency levels on the customers of 

refrigerated beverage vending machines

• Method:

– LCC equals customer purchase price, installation cost, and operating costs for 

the entire equipment lifetime. All costs are discounted to a particular base 

year

– Operating costs include maintenance, repair and energy costs. All operating 

costs are annualized

– Results are expressed in terms of LCC savings (LCC at baseline efficiency level 

minus LCC at higher efficiency level) and PBP

– PBP, expressed in number of years, is calculated by dividing the incremental 

cost at a higher efficiency level by the corresponding annualized operating 

cost savings

Life-Cycle Cost and Payback Period Analysis
72

Components of LCC

• Equipment purchase price for a customer is calculated by multiplying the 

MSP of the equipment with the corresponding distribution channel 

markup value

• Installation costs include the labor and material costs to commission the 

equipment into service

• Maintenance costs are the costs incurred by the customer for 

preventative maintenance of the equipment

• Repair costs include the costs to repair or replace damaged or 

malfunctioning components of the equipment

• Energy costs are the costs paid by the customer for the electricity 

consumed by the equipment

– DOE will collect information about commercial and industrial electricity 

consumption and expenditures as a means of establishing electricity prices

– DOE will use the Energy Information Administration’s (EIA’s) Annual Energy 

Outlook (AEO) to estimate future energy prices

Life-Cycle Cost and Payback Period Analysis
73

Other Major Parameters for LCC Analysis

• Discount Rates

– DOE will derive the discount rates for the different customers by estimating 

the capital costs for different customers and business types that own and/or 

operate the equipment

• Base Case Distribution of Efficiency Level Shares

– Base case efficiency level distribution is the distribution showing the market 

share of each efficiency level for each equipment class in the compliance year 

in the absence of any amended DOE standards

– If market share data is not available by efficiency level, DOE may develop 

efficiency distributions based on available models and information from 

refrigerated BVM manufacturers and experts

• Equipment Lifetime

– The average and typical range of the equipment lifetime will be determined 

based on literature and industry inputs for each equipment class

Life-Cycle Cost and Payback Period Analysis
74

• LCC analysis is carried out in the form of Monte Carlo simulations

• Typically, DOE uses 10,000 samples for each equipment class

• For each sample, the values of parameters are chosen based on the 

probability of their occurrence. These values are then combined to 

calculate the LCC and PBP for that particular sampling

• The LCC, LCC savings and PBP are expressed in the form of mean or 

median values and certain percentiles

• The LCC results are also presented in the form of estimated percentage of 

customers that benefit from, are adversely affected by, and are unaffected 

by any amended standards

Life-Cycle Cost and Payback Period Analysis

Approach: Monte Carlo Simulations
75

Life-Cycle Cost and Payback Period Analysis

Request for Comment 

Item 8-1: DOE seeks comment on the proposed approaches for estimating 

current and forecasted energy prices.

Item 8-2: DOE seeks comment on the proposed approaches for estimating 

discount rates for customers using the equipment covered under this 

rulemaking.

Item 8-3: DOE recognizes that a large fraction of the customers of beverage 

vending machines are beverage bottlers. Which commercial sectors besides the 

bottlers should be considered in the evaluation of discount rates? In addition, 

do stakeholders believe that government direct purchases of this equipment are 

large enough to require that they be included in the evaluation of discount 

rates?
76

Life-Cycle Cost and Payback Period Analysis

Request for Comment 

Item 8-4: DOE seeks feedback on what fraction of the installation, maintenance, 

and repairs involve efficiency improvements and what are the typical practices 

during the life cycle of an originally manufactured beverage vending machine 

(e.g., change lamps but not the compressor).

Item 8-5: What is a typical time period between the sale of a new BVM unit and 

the first maintenance or repairs? What are the typical cycles of maintenance 

and repairs? 

Item 8-6: DOE seeks feedback on whether and how routine maintenance, 

repair, and installation costs will change for more-efficient equipment.

Item 8-7: DOE seeks feedback on appropriate methodologies for assessing 

changes to maintenance, repair, and installation costs.
77

Life-Cycle Cost and Payback Period Analysis

Request for Comment 

Item 8-8: DOE seeks feedback on appropriate equipment lifetimes for the 

beverage vending machines covered under this rulemaking. 

Item 8-9: DOE seeks comment on whether energy conservation standards will 

have an impact on lifetimes of beverage vending machines.

Item 8-10: Is there a suitable inventory model that could be used to estimate 

the fraction of new versus rebuilt/refurbished machines in the market? If no 

inventory model exists, what is the impact of refurbishment on the equipment 

lifetime? DOE also seeks feedback on the number of refurbishment cycles in the 

typical lifetime of the beverage vending machines. DOE also seeks information 

on the effect of refurbishments on equipment utility and energy consumption. 

In a typical refurbishment, for example, are features added to the beverage 

vending machine that affect its utility and/or are changes made that affect the 

energy consumption of the equipment?
78

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
79

• Purpose:

– Project future shipments by equipment class

• Approach:

– DOE typically projects shipments for a 30-year period beginning with the 

expected compliance date of the standard

– Historical shipments data will be collected from sources such as Vending 

Times, U.S. Census Bureau data, North American Association of Food 

Equipment Manufacturers (NAFEM) reports, and other market research 

reports

– Future shipments will be calculated based on the historical shipments data, 

retirement rates of equipment, and the EIA’s AEO forecast of new commercial 

construction

– DOE may use different shipments projections in the standards case and base 

case scenarios depending on the information available

Shipments Analysis
80

Shipments Analysis Shipments Analysis

Request for Comment 

Item 9-1: DOE requests data on, sources of data related to, or any information 

pertaining to historical shipments and the market shares of the different 

efficiency levels offered in each equipment class.

Item 9-2: DOE seeks information on representative saturation rates for each 

equipment class covered under this rulemaking, as well as industry-trend data 

regarding relative stock and growth in each equipment class.

Item 9-3: DOE seeks input on methods of projecting the markets for each 

equipment class and access to models or methods that could be used to 

estimate shipments.

Item 9-4: DOE seeks input on likely impacts on shipments due to new or 

amended standards for beverage vending machines. Please comment on what 

the possible scenarios are and the estimated quantitative impact of each 

scenario on the shipments numbers.
81

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
82

• Purpose:

– Determine the projected national impacts, of any amended standards, in the 

form of NES and customer national NPV

• Method:

– Develop annual series of national energy and economic impacts

– Utilize the shipments model to estimate stock each year

– Utilize the LCC to develop input about total installed cost and energy use per 

unit (UEC) in any year

– Aggregate the costs and energy use for all years in the analysis period

– Report NES in primary and full fuel cycle (FFC) savings

– Report change in national customer NPV (in constant year dollars)

– Account for the time-value of money though defined discount rates

National Impact Analysis
83

Inputs for National Impact Analysis

• Inputs for calculating NES

– Annual energy consumption at each efficiency level of each equipment class

– Projected shipments

– Equipment stock (based on historical and projected shipments)

– Site-to-source conversion factors: These are multipliers used to convert the 

equipment energy used at the site to the source energy or primary energy

• Inputs for calculating NPV

– Total installed costs increases of all the equipment for each year of the 

analysis period

– Total annual operating costs savings of all the equipment stock for each year 

of the analysis period

– Discount factors (3-percent and 7-percent)

National Impact Analysis
84

National Impact Analysis

Request for Comment 

Item 10-1: DOE seeks comment on the share of the market that is met by 

refurbished or rebuilt machines and whether there are a substantial number of 

machines in stock that are not in active use. In particular, DOE seeks comment 

on the impact of refurbishment/rebuilding on the energy consumption and 

lifetime of the existing fleet in the absence of standards, and the impact of new 

standards on refurbishment kits, the subsequent cost, and performance of the 

stock of existing equipment.

Item 10-2: DOE seeks comment on its plan to develop NIA spreadsheet models 

for estimating national impacts of amended energy conservation standards.
85

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
86

• Purpose: 

– Assessment of the potential impacts of energy conservation standards on 

manufacturers of refrigerated beverage vending machines

• Method:

– Develop draft industry financial metrics based on public data

– Conduct interviews with manufacturers covering key issues and quantitative 

inputs 

– Perform an industry cash-flow and industry net present value (INPV) analysis 

through use of the Government Regulatory Impact Model (GRIM)

– Examine subgroups and cumulative regulatory burden

Preliminary Manufacturer Impact Analysis
87

• Manufacturer Subgroups:

– DOE will identify and analyze subgroups of manufacturers that may be 

disproportionately affected by efficiency standards

– DOE will identify small business manufacturers and conduct a Regulatory 

Flexibility Act analysis to determine the impacts of standards on this subgroup

• Cumulative Regulatory Burden:

– DOE will identify and consider the impact of multiple product-specific 

regulations on manufacturers

Preliminary Manufacturer Impact Analysis
88

Preliminary Manufacturer Impact Analysis

Request for Comment 

Item 12-1: DOE seeks comment on appropriate manufacturer subgroups, if any, 

that DOE should consider in the manufacturer subgroup analysis for beverage 

vending machines.

Item 12-2: DOE seeks comment on small businesses that could be impacted by 

amended energy conservation standards for beverage vending machines, and 

what those impacts might entail.

Item 12-3: DOE welcomes comments on other existing or pending regulations it 

should consider in its examination of cumulative regulatory burden.
89

Manufacturer

 Impact 

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analyses

Employment

 Impact 

Analysis

 Utility 

 Impact

 Analysis
90

• Purpose:

– Analyze the economic impacts of standards on customers subgroups who may 

be disproportionately impacted compared with the general user population

• A subgroup comprises a subset of the population likely to be affected 

disproportionately by new or amended energy conservation standards

• Method:

– Use the LCC analysis by specifically tailoring it to use parameters that are 

applicable to the identified subgroups

– The subgroup analysis results will be compared to the national average results 

(from the LCC analysis) to determine whether or not the identified subgroups 

are disproportionately affected

Customer Subgroup Analysis
91

Customer Subgroup Analysis

Request for Comment 

Item 11-1: DOE seeks input on which customer subgroups DOE should consider 

in the present rulemaking. Examples of possible subgroups DOE could consider 

appropriate for beverage vending machines are manufacturing facilities that 

own their own BVM units, which was the identified subgroup in the 2009 BVM 

final rule analysis, and site owners that pay the utilities but don’t own or stock 

the equipment. 
92

Manufacturer

 Impact 

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analyses

Employment

 Impact 

Analysis

 Utility 

 Impact

 Analysis
93

Employment Impact Analysis

• Purpose:

– Assess the overall impact on national employment from the imposition of 

efficiency standards at differing levels

– Includes only indirect employment impacts

• Direct employment impacts are estimated in the manufacturer impact analysis

• Indirect employment impacts result from shifting customer expenditures among 

goods and services ( “substitution effect”) and changing equipment and energy 

costs (“income effect”)

• Method:

– DOE intends to use the ImSET (Impact of Sector Energy Technologies) model 

for the evaluation of indirect employment impacts

Employment Impact Analysis
94

Employment Impact Analysis

Request for Comment 

Item 13-1: DOE requests feedback on this approach to assessing employment 

impacts.
95

Manufacturer

 Impact 

 Analysis

Employment

 Impact 

Analysis

 Utility 

 Impact

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analyses
96

• Purpose:

– Assess the overall impacts on domestic energy supplies that would result from 

the imposition of standards

• Method:

– DOE plans to use factors derived from NEMS-BT, a variant of the NEMS 

(National Energy Modeling System) developed and used by DOE/EIA for their 

AEO report, as the basis of the utility impact analysis

– Outputs of the utility impact analysis include projections of electricity sales, 

price, generation, and capacity in the base and standards cases

Utility Impact Analysis
97

Utility Impact Analysis

Request for Comment 

Item 14-1: DOE seeks input on its proposed use of NEMS-BT to conduct the 

utility impact analysis.

Item 14-2: Should DOE consider using methods other than NEMS in the utility 

impact analysis?
98

Manufacturer

 Impact 

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analyses

Employment

 Impact 

Analysis

 Utility 

 Impact

 Analysis
99

• Purpose:

– Estimate environmental impacts from potential energy conservation standards for 

beverage vending machines including changes in FFC emissions

• Method:

– DOE will base the emission factors for FFC on NEMS, supplemented by data from other 

sources. The following emissions are assessed: 

• Carbon dioxide (CO2)

• Sulfur dioxide (SO2) 

– SO2 emissions from affected electric generating units are subject to nationwide and 

regional emissions cap and trading programs

• Nitrogen oxides (NOx)

– Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern States and 

DC

• Methane (CH4)

• Nitrous oxide (N2O)

• Mercury (Hg)

Emissions Analysis
100

• DOE intends to use the most current Social Cost of Carbon (SCC) values 

developed by interagency reviews

– SCC is intended to be a monetary measure of the incremental damage resulting from 

greenhouse gas (GHG) emissions, including but not limited to agricultural productivity 

loss, human health effects, property damage from rising sea level, and changes in the 

ecosystem

• At present, the most recent interagency estimates of the potential global benefits 

resulting from reduced CO2 emissions in 2015, expressed in 2012$, were $12.9, 

$40.8, $62.2, and $117 per metric ton avoided

– For emission reductions that occur in later years, these values grow in real terms over 

time

• DOE will also estimate the potential monetary benefit of reduced NOx emissions 

resulting from the considered standard levels

Monetization of Emission Reductions
101

Emissions Analysis & Monetization

Request for Comment 

Item 15-1: DOE seeks input on its approach to conduct the emissions analysis 

for the equipment covered by this rulemaking.

Item 16-1: DOE requests comments on the approach it plans to use for 

estimating monetary values associated with emissions reductions.
102

Manufacturer

 Impact 

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analyses

Employment

 Impact 

Analysis

 Utility 

 Impact

 Analysis
103

Regulatory Impact Analysis

• Purpose:

– Explore the potential for non-regulatory alternatives to new or amended 

energy efficiency standards

• Method:

– Base the assessment on the actual impacts of any such initiatives to date, but 

consider information presented regarding the impacts that any existing 

initiative might have in the future

NOPR Analyses
104

Regulatory Impact Analysis

Request for Comment 

Item 17-1: DOE is aware of the existing ENERGY STAR program for the 

beverage vending machine industry covered under this rulemaking. Are 

stakeholders aware of any other such programs that should be examined as 

optional, non-regulatory approaches?

Item 17-2: Are there specific subgroups of end-users whom DOE should 

consider in its review of potential adverse impacts from standards developed 

under this rulemaking?
105

4

3

2

Test Procedure & Test Metrics

Rulemaking Process Overview

Authority & Definitions

1 Introduction

5 Rulemaking Analyses

Public Meeting Agenda

6 Closing Remarks
106

How to Submit Written Comments

In all correspondence, please refer to the Refrigerated Beverage Vending 

Machines rulemaking by:

– Framework Document for Refrigerated Beverage Vending Machines

– Docket Number: EERE-2013-BT-STD-0022

– Regulatory Identification Number (RIN): 1904-AD00

Electronic: BVM2013STD0022@EE.Doe.Gov or www.regulations.gov

Postal Mail: Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Courier: Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Sixth Floor, 950 L’Enfant Plaza, SW

Washington, DC 20024

Telephone: (202) 586-2945

Comment period closes: July 19, 2013

Closing Remarks