Vol. 78 Wednesday, 

No. 176 September 11, 2013 

Part II 

Department of Energy 

10 CFR Part 431 

Energy Conservation Program: Energy Conservation Standards for Walk-In 

Coolers and Freezers; Proposed Rule 


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DEPARTMENT OF ENERGY 

10 CFR Part 431 

[Docket No. EERE–2008–BT–STD–0015] 

RIN 1904–AB86 

Energy Conservation Program: Energy 

Conservation Standards for Walk-In 

Coolers and Freezers 

AGENCY: Office of Energy Efficiency and 

Renewable Energy, Department of 

Energy. 

ACTION: Notice of proposed rulemaking 

(NOPR) and public meeting. 

SUMMARY: The Energy Policy and 

Conservation Act of 1975 (EPCA), as 

amended, prescribes energy 

conservation standards for various 

consumer products and certain 

commercial and industrial equipment, 

including walk-in coolers and walk-in 

freezers. EPCA also requires the U.S. 

Department of Energy (DOE) to 

determine whether more-stringent, 

amended standards would be 

technologically feasible and 

economically justified, and would save 

a significant amount of energy. In this 

notice, DOE proposes amended energy 

conservation standards for walk-in 

coolers and walk-in freezers. The notice 

also announces a public meeting to 

receive comment on these proposed 

standards and associated analyses and 

results. 

DATES: DOE will hold a public meeting 

on Wednesday, October 9, 2013, from 9 

a.m. to 4 p.m., in Washington, DC. The 

meeting will also be broadcast as a 

webinar. See section VII, ‘‘Public 

Participation,’’ for webinar registration 

information, participant instructions, 

and information about the capabilities 

available to webinar participants. 

DOE will accept comments, data, and 

information regarding this notice of 

proposed rulemaking (NOPR) before and 

after the public meeting, but no later 

than November 12, 2013. See section 

VII, ‘‘Public Participation,’’ for details. 

ADDRESSES: The public meeting will be 

held at the U.S. Department of Energy, 

Forrestal Building, Room 8E–089, 1000 

Independence Avenue SW., 

Washington, DC 20585. To attend, 

please notify Ms. Brenda Edwards at 

(202) 586–2945. For more information, 

refer to section VII, Public Participation. 

Any comments submitted must 

identify the NOPR for Energy 

Conservation Standards for walk-in 

coolers and freezers, and provide docket 

number EERE–2008–BT–STD–0015 

and/or regulatory information number 

(RIN) number 1904–AB86. Comments 

may be submitted using any of the 

following methods: 

1. Federal eRulemaking Portal: 

www.regulations.gov. Follow the 

instructions for submitting comments. 

2. Email: WICF–2008–STD–0015@

ee.doe.gov. Include the docket number 

and/or RIN in the subject line of the 

message. 

3. Mail: Ms. Brenda Edwards, U.S. 

Department of Energy, Building 

Technologies Office, Mailstop EE–2J, 

1000 Independence Avenue SW., 

Washington, DC, 20585–0121. If 

possible, please submit all items on a 

CD. It is not necessary to include 

printed copies. 

4. Hand Delivery/Courier: Ms. Brenda 

Edwards, U.S. Department of Energy, 

Building Technologies Office, 950 

L’Enfant Plaza SW., Suite 600, 

Washington, DC 20024. Telephone: 

(202) 586–2945. If possible, please 

submit all items on a CD, in which case 

it is not necessary to include printed 

copies. 

Written comments regarding the 

burden-hour estimates or other aspects 

of the collection-of-information 

requirements contained in this proposed 

rule may be submitted to Office of 

Energy Efficiency and Renewable 

Energy through the methods listed 

above and by email to Chad_S_

Whiteman@omb.eop.gov. 

For detailed instructions on 

submitting comments and additional 

information on the rulemaking process, 

see section VII of this document (Public 

Participation). 

Docket: The docket, which includes 

Federal Register notices, public meeting 

attendee lists and transcripts, 

comments, and other supporting 

documents/materials, is available for 

review at regulations.gov. All 

documents in the docket are listed in 

the regulations.gov index. However, 

some documents listed in the index, 

such as those containing information 

that is exempt from public disclosure, 

may not be publicly available. 

A link to the docket Web page can be 

found at: http://www1.eere.energy.gov/

buildings/appliance_standards/

rulemaking.aspx/ruleid/30. This Web 

page contains a link to the docket for 

this notice on the regulations.gov site. 

The regulations.gov Web page contains 

instructions on how to access all 

documents, including public comments, 

in the docket. See section VII for further 

information on how to submit 

comments through 

www.regulations.gov. 

For further information on how to 

submit a comment, review other public 

comments and the docket, or participate 

in the public meeting, contact Ms. 

Brenda Edwards at (202) 586–2945 or by 

email: Brenda.Edwards@ee.doe.gov. 

FOR FURTHER INFORMATION CONTACT:

Mr. Charles Llenza, U.S. Department of 

Energy, Office of Energy Efficiency 

and Renewable Energy, Building 

Technologies Program, EE–2J, 1000 

Independence Avenue SW., 

Washington, DC 20585–0121. 

Telephone: (202) 586–2192. Email: 

walk-in_coolers_and_walk-in_

freezers@EE.Doe.Gov. 

Mr. Michael Kido, U.S. Department of 

Energy, Office of the General Counsel, 

GC–71, 1000 Independence Avenue 

SW., Washington, DC 20585–0121. 

Telephone: (202) 586–8145. Email: 

Michael.Kido@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Summary of the Proposed Rule 

A. Benefits and Costs to Consumers 

B. Impact on Manufacturers 

C. National Benefits 

II. Introduction 

A. Authority 

B. Background 

1. Current Standards 

2. History of Standards Rulemaking for 

Walk-In Coolers and Freezers 

III. General Discussion 

A. Component Level Standards 

B. Test Procedures and Metrics 

1. Panels 

2. Doors 

3. Refrigeration 

C. Prescriptive Versus Performance 

Standards 

D. Certification, Compliance, and 

Enforcement 

E. Technological Feasibility 

1. General 

2. Maximum Technologically Feasible 

Levels 

F. Energy Savings 

1. Determination of Savings 

2. Significance of Savings 

G. Economic Justification 

1. Specific Criteria 

a. Economic Impact on Manufacturers and 

Consumers 

b. Life-Cycle Costs 

c. Energy Savings 

d. Lessening of Utility or Performance of 

Products 

e. Impact of Any Lessening of Competition 

f. Need of the Nation to Conserve Energy 

g. Other Factors 

2. Rebuttable Presumption 

IV. Methodology and Discussion 

A. Market and Technology Assessment 

1. Definitions Related to Walk-In Coolers 

and Freezers 

a. Display Doors 

b. Freight Doors 

c. Passage Doors 

2. Equipment Included in this Rulemaking 

a. Panels and Doors 

b. Refrigeration System 

3. Equipment Classes 

a. Panels and Doors 

b. Refrigeration Systems 


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4. Technology Assessment 

B. Screening Analysis 

1. Technologies That Do Not Affect Rated 

Performance 

2. Screened-Out Technologies 

a. Panels and Doors 

b. Refrigeration 

3. Screened-In Technologies 

C. Engineering Analysis 

1. Representative Equipment 

a. Panels and Doors 

b. Refrigeration 

2. Energy Modeling Methodology 

a. Refrigeration 

3. Cost Assessment Methodology 

a. Teardown Analysis 

b. Cost Model 

c. Manufacturing Production Cost 

d. Manufacturing Markup 

e. Shipping Costs 

4. Baseline Specifications 

a. Panels and Doors 

b. Refrigeration 

5. Design Options 

a. Panels and Doors 

b. Refrigeration 

6. Cost-Efficiency Results 

a. Panels and Doors 

b. Refrigeration 

c. Numerical Results 

D. Markups Analysis 

E. Energy Use Analysis 

1. Sizing Methodology for the Refrigeration 

System 

2. Oversize Factors 

3. Product Load 

4. Other Issues 

F. Life-Cycle Cost and Payback Period 

Analyses 

1. Equipment Cost 

2. Installation Cost 

3. Annual Energy Consumption 

4. Energy Prices 

5. Energy Price Projections 

6. Maintenance and Repair Costs 

7. Product Lifetime 

8. Discount Rates 

9. Compliance Date of Standards 

10. Base-Case and Standards-Case 

Efficiency Distributions 

11. Inputs to Payback Period Analysis 

12. Rebuttable-Presumption Payback 

Period 

G. National Impact Analysis—National 

Energy Savings and Net Present Value 

1. Shipments 

a. Share of Shipments and Stock Across 

Equipment Classes 

b. Lifetimes and Replacement Rates 

c. Growth Rates 

d. Other Issues 

2. Forecasted Efficiency in the Base Case 

and Standards Cases 

3. National Energy Savings 

4. Net Present Value of Consumer Benefit 

5. Benefits from Effects of Standards on 

Energy Prices 

H. Consumer Subgroup Analysis 

I. Manufacturer Impact Analysis 

1. Overview 

2. Government Regulatory Impact Model 

Analysis 

a. Government Regulatory Impact Model 

Key Inputs 

b. Government Regulatory Impact Model 

Scenarios 

3. Discussion of Comments 

a. Cumulative Regulatory Burden 

b. Inventory Levels 

c. Manufacturer Subgroup Analysis 

4. Manufacturer Interviews 

a. Cost of testing 

b. Enforcement and Compliance 

c. Profitability Impacts 

d. Excessive Conversion Cost 

e. Disproportionate Impact on Small 

Businesses 

f. Refrigerant Phase-Out 

J. Employment Impact Analysis 

K. Utility Impact Analysis 

L. Emissions Analysis 

M. Monetizing Carbon Dioxide and Other 

Emissions Impacts 

1. Social Cost of Carbon 

a. Monetizing Carbon Dioxide Emissions 

b. Social Cost of Carbon Values Used in 

Past Regulatory Analyses 

c. Current Approach and Key Assumptions 

2. Valuation of Other Emissions 

Reductions 

V. Analytical Results 

A. Trial Standard Levels 

1. Trial Standard Level Selection Process 

2. Trial Standard Level Equations 

B. Economic Justification and Energy 

Savings 

1. Economic Impacts on Commercial 

Customers 

a. Life-Cycle Cost and Payback Period 

b. Life-Cycle Cost Subgroup Analysis 

2. Economic Impacts on Manufacturers 

a. Industry Cash-Flow Analysis Results 

b. Impacts on Direct Employment 

c. Impacts on Manufacturing Capacity 

d. Impacts on Small Manufacturer SubGroup 

e. Cumulative Regulatory Burden 

3. National Impact Analysis 

a. Amount and Significance of Energy 

Savings 

b. Net Present Value of Consumer Costs 

and Benefits 

c. Employment Impacts 

4. Impact on Utility or Performance of 

Equipment 

5. Impact of Any Lessening of Competition 

6. Need of the Nation to Conserve Energy 

7. Other Factors 

C. Proposed Standard 

VI. Procedural Issues and Regulatory Review 

A. Review Under Executive Orders 12866 

and 13563 

B. Review Under the Regulatory Flexibility 

Act 

C. Review Under the Paperwork Reduction 

Act 

D. Review Under the National 

Environmental Policy Act of 1969 

E. Review Under Executive Order 13132 

F. Review Under Executive Order 12988 

G. Review Under the Unfunded Mandates 

Reform Act of 1995 

H. Review Under the Treasury and General 

Government Appropriations Act, 1999 

I. Review Under Executive Order 12630 

J. Review Under the Treasury and General 

Government Appropriations Act, 2001 

K. Review Under Executive Order 13211 

L. Review Under the Information Quality 

Bulletin for Peer Review 

VII. Public Participation 

A. Attendance at the Public Meeting 

B. Procedure for Submitting Prepared 

General Statements for Distribution 

C. Conduct of the Public Meeting 

D. Submission of Comments 

E. Issues on Which DOE Seeks Comment 

VIII. Approval of the Office of the Secretary 

I. Summary of the Proposed Rule 

DOE proposes creating new 

performance-based energy conservation 

standards for walk-in coolers and walkin freezers (collectively, ‘‘walk-ins’’ or 

‘‘WICFs’’). The proposed standards, 

which are expressed as an annual walkin energy factor (AWEF) for refrigeration 

systems, the maximum allowable Ufactor expressed as a function of the 

ratio of edge area to core area for panels, 

and the maximum allowable daily 

energy use expressed as a function of 

the surface area for non-display and 

display doors, are shown in Table I.1. 

These proposed standards, if adopted, 

would apply to all products listed in 

Table I.1 and manufactured in, or 

imported into, the United States on or 

after 3 years after the publication date 

of any final rule establishing energy 

conservation standards for walk-ins. 

Appendix 10D of the TSD lists the 

technologies that DOE assumes 

manufacturers will use to meet the 

proposed standards. 


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1Life-cycle cost (LCC) of commercial refrigeration 

equipment is the cost to customers of owning and 

operating the equipment over the entire life of the 

equipment. Life-cycle cost savings are the 

reductions in the life-cycle costs due to amended 

energy conservation standards when compared to 

the life-cycle costs of the equipment in the absence 

of amended energy conservation standards. Further 

discussion of the LCC analysis can be found in 

Chapter 8 of the TSD. 

2Payback period (PBP) refers to the amount of 

time (in years) it takes customers to recover the 

increased installed cost of equipment associated 

with new or amended standards through savings in 

operating costs. Further discussion of the PBP can 

be found in Chapter 8 of the TSD. 

3These rates were used to discount future cash 

flows in the Manufacturer Impact Analysis. The 

discount rates were calculated from SEC filings and 

then adjusted based on cost of capital feedback 

collected from walk-in door, panel, and 

refrigeration manufacturers in MIA interviews. For 

a detailed explanation of how DOE arrived at these 

discount rates, refer to Chapter 12 of the NOPR 

TSD. 

A. Benefits and Costs to Consumers 

Table I–2 presents DOE’s evaluation 

of the economic impacts of the proposed 

standards on consumers of walk-in 

coolers and freezers, as measured by the 

shipment-weighted average life-cycle 

cost (LCC) savings 1 and the median 

payback period.2 The average LCC 

savings are positive for all equipment 

classes. At TSL 4, the percentage of 

customers who experience net benefits 

or no impacts ranges from 55 to 100 

percent, and the percentage of 

customers experiencing a net cost 

ranges from 0 to 45 percent. Chapter 11 

presents the LCC subgroup analysis on 

groups of customers that may be 

disproportionately affected by the 

proposed standard. The installed cost 

increase over the 9-year analysis period 

(2017–2025) for the proposed TSL is 

1.98 billion discounted at 7 percent. 

TABLE I–2—SHIPMENT-WEIGHTED AVERAGE IMPACTS OF PROPOSED STANDARDS (TSL 4) ON CONSUMERS OF WALK-IN

COOLERS AND WALK-IN FREEZERS

Equipment class Average LCC 

savings (2012$) 

Median payback period 

(years) 

Refrigeration System Class:* 

DC.M.I ............................................................................................................................... $611 4.4 

DC.M.O ............................................................................................................................. 3,195 2.2 

DC.L.I ................................................................................................................................ 1,117 2.7 

DC.L.O .............................................................................................................................. 2,664 2.3 

MC.M ................................................................................................................................ 1,724 0.5 

MC.L ................................................................................................................................. 2,061 0.4 

Panel Class: 

SP.M** .............................................................................................................................. 8 4.5 

SP.L** ............................................................................................................................... 72 3.6 

FP.L** ............................................................................................................................... 30 4.5 

Non-Display Door Class: 

PD.M ................................................................................................................................. 0.3 5.5 

PD.L .................................................................................................................................. 52 4.7 

FD.M ................................................................................................................................. 1 5.4 

FD.L .................................................................................................................................. 136 2.9 

Display Door Class: 

DD.M ................................................................................................................................. 228 2.2 

DD.L .................................................................................................................................. 200 N/A 

* For dedicated condensing (DC) refrigeration systems, results include both capacity ranges. 

** Results are per 100 square feet. 

B. Impact on Manufacturers 

The industry net present value (INPV) 

is the sum of the discounted cash flows 

to the industry from the base year 

through the end of the analysis period 

(2013 to 2046). Using real discount rates 

of 10.5 percent for panels, 9.4 percent 

for doors, and 10.4 percent for 

refrigeration 3, DOE estimates that the 

industry net present value (INPV) for 

manufacturers of walk-in cooler and 

freezer refrigeration systems, panels, 

and doors in the base case (without new 

standards) is $851 million in 2012$. 

Under the proposed standards, DOE 

expects the impact on INPV to range 

from no change to a 9 percent decrease. 


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4All monetary values in this section are 

expressed in 2012 dollars and are discounted to 

2013. 

5Total U.S. commercial sector energy (source 

energy) used for refrigeration in 2010 was 1.21 

quads. Source: U.S. Department of Energy—Office 

of Energy Efficiency and Renewable Energy. 

Buildings Energy Data Book, Table 3.1.4, 2010 

Commercial Energy End-Use Splits, by Fuel Type 

(Quadrillion Btu). 2012. (Last accessed April 23, 

2013.) http://buildingsdatabook.eren.doe.gov/

TableView.aspx?table=3.1.4 

6A metric ton is equivalent to 1.1 short tons. 

Results for NOX and Hg are presented in short tons. 

7 DOE calculates emissions reductions relative to 

the Annual Energy Outlook (AEO) 2013 Reference 

case, which generally represents current legislation 

and environmental regulations for which 

implementing regulations were available as of 

December 31, 2012. 

8 DOE also estimated CO2 and CO2 equivalent 

(CO2eq) emissions that occur through 2030 (CO2eq 

includes greenhouse gases such as CH4 and N2O). 

The estimated emissions reductions through 2030 

are 79 million metric tons CO2, 7,897 thousand tons 

CO2eq for CH4, and 338 thousand tons CO2eq for 

N2O. 

9 DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg 

emissions before it monetizes Hg in its rulemakings. 

Total industry conversion costs 

estimated to be $51 million are assumed 

to be incurred in the years prior to the 

start of compliance with the standards. 

Based on DOE’s interviews with the 

manufacturers of walk-in coolers and 

walk-in freezers, DOE does not expect 

significant loss of employment. 

C. National Benefits 4

DOE’s analyses indicate that the 

proposed standards would save a 

significant amount of energy. The 

lifetime full-fuel-cycle energy savings 

for walk-in coolers and freezers 

purchased in the 30-year period that 

begins in the year of compliance with 

new standards (2017–2046) amount to 

5.39 quadrillion British thermal units 

(quads). The average annual energy 

savings over the life of walk-in coolers 

and freezers purchased in 2017 through 

2046 is 0.18 quads, which is equivalent 

to 14.8 percent of the annual U.S 

commercial refrigeration sector energy.5

The cumulative net present value 

(NPV) of total consumer costs and 

savings of the proposed standards 

ranges from $8.6 billion (at a 7-percent 

discount rate) to $24.3 billion (at a 3- 

percent discount rate) for walk-in 

coolers and freezers. This NPV 

expresses the estimated total value to 

customers of future operating cost 

savings minus the estimated increased 

product costs for products purchased in 

2017–2046. 

In addition, the proposed standards 

would have significant environmental 

benefits. The energy savings would 

result in cumulative emission 

reductions of 298 million metric tons 

(Mt) 6 of carbon dioxide (CO2), 1,428 

thousand tons of methane, 379.5 

thousand tons of sulfur dioxide (SO2), 

443.8 thousand tons of nitrogen oxides 

(NOX), and 0.6 tons of mercury (Hg).7 8

The value of the CO2 reductions is 

calculated using a range of values per 

metric ton of CO2 (otherwise known as 

the Social Cost of Carbon, or SCC) 

developed by an interagency process. 

The derivation of the SCC values is 

discussed in section IV.M. DOE 

estimates the net present monetary 

value of the CO2 emissions reduction is 

between $1.9 billion and $27.5 billion, 

depending on the SCC value used, over 

a 30-year analysis period. DOE also 

estimates the net present monetary 

value of the NOX emissions reduction is 

$243 million at a 7-percent discount rate 

and $553 million at a 3-percent discount 

rate over a 30-year analysis period. Over 

a 9-year analysis period, DOE estimates 

the net present monetary value of the 

CO2 emissions reduction is between 

$0.33 billion and $4.07 billion, 

depending on the SCC value used, while 

the net present monetary value of the 

NOX emissions reduction is $70.5 

million at a 7-percent discount rate and 

$99.8 million at a 3-percent discount 

rate.9 DOE notes that the estimated total 

social benefits of the rule outweigh the 

costs whether a 30-year or a 9-year 

analysis period is used. 

Table I–3 summarizes the national 

economic costs and benefits expected to 

result from the proposed standards for 

walk-in coolers and walk-in freezers. 

TABLE I–3—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF WALK-IN COOLER AND WALK-IN FREEZER

ENERGY CONSERVATION STANDARDS

Category Present value 

Billion 2012$ 

Discount rate 

(percent) 

Benefits 

Operating Cost Savings ....................................................................................................... 12.4 7 

31 .6 3 

CO2 Reduction Monetized Value (at $12.9/t case)* ............................................................ 1 .9 5 

CO2 Reduction Monetized Value (at $40.8/t case)* ............................................................ 9 .0 3 

CO2 Reduction Monetized Value (at $62.2/t case)* ............................................................ 14 .4 2 .5 

CO2 Reduction Monetized Value (at $117.0/t case)* .......................................................... 27 .5 3 

NOX Reduction Monetized Value (at $2,639/Ton)** ........................................................... 0 .24 7 

0 .55 3 

Total Benefits† .............................................................................................................. 21.6 7 

41 .1 3 

Costs 

Incremental Installed Costs ................................................................................................. 3 .8 7 

7 .2 3 

Net Benefits 

Including CO2 and NOX Reduction Monetized Value ......................................................... 17 .8 7 

33 .9 3 

* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC 

from the integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate an escalation factor. 


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10 DOE used a two-step calculation process to 

convert the time-series of costs and benefits into 

annualized values. First, DOE calculated a present 

value in 2013, the year used for discounting the 

NPV of total consumer costs and savings, for the 

time-series of costs and benefits using discount 

rates of three and seven percent for all costs and 

benefits except for the value of CO2 reductions. For 

the latter, DOE used a range of discount rates, as 

shown in Table I.3. From the present value, DOE 

then calculated the fixed annual payment over a 30- 

year period (2014 through 2043) that yields the 

same present value. The fixed annual payment is 

the annualized value. Although DOE calculated 

annualized values, this does not imply that the 

time-series of cost and benefits from which the 

annualized values were determined is a steady 

stream of payments. 

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

† Total Benefits for both the 3 percent and 7 percent cases are derived using the CO2 reduction monetized value series corresponding to average SCC with 3-percent discount rate. 

The benefits and costs of today’s 

proposed standards, for equipment sold 

in 2017–2046, can also be expressed in 

terms of annualized values. The 

annualized monetary values are the sum 

of (1) the annualized national economic 

value of the benefits from consumer 

operation of equipment that meets the 

proposed standards (consisting 

primarily of operating cost savings from 

using less energy, minus increases in 

equipment purchase and installation 

costs, and (2) the annualized monetary 

value of the benefits of emission 

reductions, including CO2 emission 

reductions.10

Although combining the values of 

operating savings and CO2 emission 

reductions provides a useful 

perspective, two issues should be 

considered. First, the national operating 

savings are domestic U.S. consumer 

monetary savings that occur as a result 

of market transactions while the value 

of CO2 reductions is based on a global 

value. Second, the assessments of 

operating cost savings and CO2 savings 

are performed with different methods 

that use different time frames for 

analysis. The national operating cost 

savings is measured for the lifetime of 

walk-ins shipped from 2017–2046. The 

SCC values, on the other hand, reflect 

the present value of some future 

climate-related impacts resulting from 

the emission of one ton of carbon 

dioxide in each year. These impacts 

continue well beyond 2100. 

Table I–4 shows the estimates of 

annualized benefits and costs of the 

proposed standards. (All monetary 

values below are expressed in 2012$.) 

The results under the primary estimate 

are as follows. Using a 7-percent 

discount rate for benefits and costs other 

than CO2 reduction, for which DOE 

used a 3-percent discount rate along 

with the average SCC series that uses a 

3-percent discount rate, the cost of the 

standards proposed in today’s rule is 

$367 million per year in increased 

equipment costs, while the annualized 

benefits are $1.225 billion per year in 

reduced equipment operating costs, 

$499 million in CO2 reductions, and $24 

million in reduced NOX emissions. In 

this case, the net benefit amounts to 

$1.382 billion per year. Using a 3- 

percent discount rate for all benefits and 

costs and the average SCC series, the 

cost of the standards proposed in 

today’s rule is $399 million per year in 

increased equipment costs, while the 

benefits are $1.606 billion per year in 

reduced operating costs, $499 million in 

CO2 reductions, and $31 million in 

reduced NOX emissions. In this case, the 

net benefit amounts to $1.737 billion 

per year. 

TABLE I–4—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR WALK-IN COOLERS AND WALK-IN

FREEZERS

Discount rate 

Primary 

estimate* Low net 

benefits 

estimate* 

High net 

benefits 

estimate* (million 2012$/year) 

Benefits 

Operating Cost Savings .......................... 7% .......................... 1,225 1,188 1,279 

3% .......................... 1,606 1,544 1,687 

CO2 Reduction Monetized Value (at 

$12.9t case)**.

5% .......................... 142 142 142 

CO2 Reduction Monetized Value (at 

$40.8/t case)**.

3% .......................... 499 499 499 

CO2 Reduction Monetized Value (at 

$62.2/t case)**.

2.50% ..................... 739 739 739 

CO2 Reduction Monetized Value (at 

$117.0/t case)**.

3% .......................... 1,534 1,534 1,534 

NOX Reduction Monetized Value (at 

$2,639/Ton)**.

7% .......................... 24 24 24 

3% .......................... 31 31 31 

Total Benefits† ................................. 7% plus CO2 range 1,748 1,712 1,803 

7% .......................... 1,249 1,212 1,303 

3% .......................... 1,637 1,574 1,718 

3% plus CO2 range 2,136 2,074 2,217 

Costs 

Total Incremental Installed Costs ........... 7% .......................... 367 377 357 

3% .......................... 399 414 385 

Net Benefits 

Total† ...................................................... 7% plus CO2 range 1,382 1,335 1,446 

7% .......................... 883 835 946 

3% .......................... 1,238 1,160 1,333 


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11All references to EPCA in this document refer 

to the statute as amended through the American 

Energy Manufacturing Technical Corrections Act 

(AEMTCA), Public Law 112–210 (Dec. 18, 2012). 

12For editorial reasons, upon codification in the 

U.S. Code, Part C was re-designated Part A–1. 

TABLE I–4—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR WALK-IN COOLERS AND WALK-IN

FREEZERS—Continued 

Discount rate 

Primary 

estimate* Low net 

benefits 

estimate* 

High net 

benefits 

estimate* (million 2012$/year) 

3% plus CO2 range 1,737 1,660 1,832 

* This table presents the annualized costs and benefits associated with walk-in coolers and freezers shipped in 2017¥2046. These results include benefits to consumers which accrue after 2046 from the walk-in coolers and freezers purchased in 2017–2046. Costs incurred by manufacturers, some of which may be incurred in preparation for the rule, are not directly included, but are indirectly included as part of incremental 

equipment costs. The Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the AEO2013 Reference case, 

Low Estimate, and High Estimate, respectively. In addition, incremental product costs reflect a medium decline rate for projected product price 

trends in the Primary Estimate, a low decline rate for projected product price trends using a Low Benefits Estimate, and a high decline rate for 

projected product price trends using a High Benefits Estimate. 

** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC 

from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile 

SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature 

change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate 

an escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. 

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

rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled 

discount rate, and those values are added to the full range of CO2 values. 

DOE has tentatively concluded that 

the proposed standards represent the 

maximum improvement in energy 

efficiency that is technologically 

feasible and economically justified. DOE 

further notes that manufacturers already 

produce commercially available 

equipment that achieve these levels for 

most, if not all, equipment classes 

covered by today’s proposal. Based on 

the analyses described above, DOE has 

tentatively concluded that the benefits 

of the proposed standards to the Nation 

(energy savings, positive NPV of 

consumer benefits, consumer LCC 

savings, and emission reductions) 

would outweigh the burdens (loss of 

INPV for manufacturers). 

DOE also considered more-stringent 

and less-stringent efficiency levels as 

trial standard levels (TSLs), and is still 

considering them in this rulemaking. 

However, DOE has tentatively 

concluded that the potential burdens of 

the more-stringent efficiency levels 

would outweigh the projected benefits. 

Based on consideration of the public 

comments DOE receives in response to 

this notice and related information 

collected and analyzed during the 

course of this rulemaking effort, DOE 

may adopt efficiency levels presented in 

this notice that are either higher or 

lower than the proposed standards, or 

some combination of level(s) that 

incorporate the proposed standards in 

part. 

II. Introduction 

The following section briefly 

discusses the statutory authority 

underlying today’s proposal, as well as 

some of the relevant historical 

background related to walk-ins. 

A. Authority 

Title III, Part C of EPCA, Public Law 

94–163 (42 U.S.C. 6311–6317, as 

codified), added by Public Law 95–619, 

Title IV, section 441(a), established the 

Energy Conservation Program for 

Certain Industrial Equipment, a program 

covering certain industrial equipment, 

which includes the walk-in coolers and 

walk-in freezers that are the focus of this 

notice.11 12 (42 U.S.C. 6311(1), (20), 

6313(f) and 6314(a)(9)) Walk-ins consist 

of two major pieces—the structural 

‘‘envelope’’ within which items are 

stored and a refrigeration system that 

cools the air in the envelope’s interior. 

DOE’s energy conservation program 

for covered equipment generally 

consists of four parts: (1) Testing; (2) 

labeling; (3) the establishment of 

Federal energy conservation standards; 

and (4) certification and enforcement 

procedures. For walk-ins, DOE is 

responsible for the entirety of this 

program. The DOE test procedures for 

walk-ins, including those prescribed by 

Congress in EISA 2007 and those 

established by DOE in the test 

procedure final rule, currently appear at 

title 10 of the Code of Federal 

Regulations (CFR) part 431, section 304. 

Any new or amended performance 

standards that DOE prescribes for walkins must achieve the maximum 

improvement in energy efficiency that is 

technologically feasible and 

economically justified. (42 U.S.C. 

6313(f)(4)(A)) For purposes of this 

rulemaking, DOE also plans to adopt 

those standards that are likely to result 

in a significant conservation of energy 

that satisfies both of these requirements. 

See 42 U.S.C. 6295(o)(3)(B). 

Technological feasibility is 

determined by examining technologies 

or designs that could be used to improve 

the efficiency of the covered equipment. 

DOE considers a design to be 

technologically feasible if it is in use by 

the relevant industry or if research has 

progressed to the development of a 

working prototype. 

In ascertaining whether a particular 

standard is economically justified, DOE 

considers, to the greatest extent 

practicable, the following factors: 

1. The economic impact of the 

standard on manufacturers and 

consumers of the equipment subject to 

the standard; 

2. The savings in operating costs 

throughout the estimated average life of 

the covered equipment in the type (or 

class) compared to any increase in the 

price, initial charges, or maintenance 

expenses for the covered equipment that 

are likely to result from the imposition 

of the standard; 

3. The total projected amount of 

energy or, as applicable, water savings 

likely to result directly from the 

imposition of the standard; 

4. Any lessening of the utility or the 

performance of the covered equipment 

likely to result from the imposition of 

the standard; 

5. The impact of any lessening of 

competition, as determined in writing 

by the Attorney General, that is likely to 

result from the imposition of the 

standard; 

6. The need for national energy and 

water conservation; and 


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7. Other factors the Secretary of 

Energy (Secretary) considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i) (I)–(VII)) 

DOE does not plan to prescribe an 

amended or new standard if interested 

persons have established by a 

preponderance of the evidence that the 

standard is likely to result in the 

unavailability in the United States of 

any covered product type (or class) of 

performance characteristics (including 

reliability), features, sizes, capacities, 

and volumes that are substantially the 

same as those generally available in the 

United States. Further, under EPCA’s 

provisions for consumer products, there 

is a rebuttable presumption that a 

standard is economically justified if the 

Secretary finds that the additional cost 

to the consumer of purchasing a product 

complying with an energy conservation 

standard level will be less than three 

times the value of the energy savings 

during the first year that the consumer 

will receive as a result of the standard, 

as calculated under the applicable test 

procedure. (42 U.S.C. 6295(o)(2)(B)(iii)) 

For purposes of its walk-in analysis, 

DOE plans to account for these factors. 

Additionally, when a type or class of 

covered equipment such as walk-ins has 

two or more subcategories, in 

promulgating standards for such 

equipment, DOE often specifies more 

than one standard level. DOE generally 

will adopt a different standard level 

than that which applies generally to 

such type or class of products for any 

group of covered products that have the 

same function or intended use if DOE 

determines that products within such 

group (A) consume a different kind of 

energy than that consumed by other 

covered products within such type (or 

class) or (B) have a capacity or other 

performance-related feature that other 

products within such type (or class) do 

not have, and which justifies a higher or 

lower standard. Generally, in 

determining whether a performancerelated feature justifies a different 

standard for a group of products, DOE 

considers such factors as the utility to 

the consumer of the feature and other 

factors DOE deems appropriate. In a rule 

prescribing such a standard, DOE 

typically includes an explanation of the 

basis on which such higher or lower 

level was established. DOE plans to 

follow a similar process in the context 

of today’s rulemaking. 

DOE notes that since the inception of 

the statutory requirements setting 

standards for walk-ins, Congress has 

since made one additional amendment 

to those provisions. That amendment 

provides that the wall, ceiling, and door 

insulation requirements detailed in 42 

U.S.C. 6313(f)(1)(C) do not apply to the 

given component if the component’s 

manufacturer has demonstrated to the 

Secretary’s satisfaction that ‘‘the 

component reduces energy consumption 

at least as much’’ if those specified 

requirements were to apply to that 

manufacturer’s component. American 

Energy Manufacturing Technology 

Corrections Act, Public Law 112–210, 

Section 2 (Dec. 18, 2012) (codified at 42 

U.S.C. 6313(f)(6)) (AEMTCA). 

Manufacturers seeking to avail 

themselves of this provision must 

‘‘provide to the Secretary all data and 

technical information necessary to fully 

evaluate its application.’’ Id. DOE is 

proposing to codify this amendment 

into its regulations. 

Since its codification, one company, 

HH Technologies, submitted data on 

May 24, 2013, demonstrating that its 

RollSeal doors satisfied this new 

AEMTCA provision. DOE reviewed 

these data and all other submitted 

information and concluded that the 

RollSeal doors at issue satisfied 42 

U.S.C. 6313(f)(6). Accordingly, DOE 

issued a determination letter on June 14, 

2013, indicating that these doors met 

Section 6313(f)(6) and that the 

applicable insulation requirements did 

not apply to the RollSeal doors HH 

Technologies identified. Nothing in this 

proposed rule affects the previous 

determination regarding HH 

Technologies. 

Federal energy conservation 

requirements generally pre-empt state 

laws or regulations concerning energy 

conservation testing, labeling, and 

standards. (42 U.S.C. 6297(a); 42 U.S.C. 

6316(b)) However, EPCA provides that 

for walk-ins in particular, any state 

standard issued before publication of 

the final rule shall not be pre-empted 

until the standards established in the 

final rule take effect. (42 U.S.C 

6316(h)(2)(B)) 

Where applicable, DOE generally 

considers standby and off mode energy 

use for certain covered products or 

equipment when developing energy 

conservation standards. See 42 U.S.C. 

6295(gg)(3). Because the vast majority of 

walk-in coolers and walk-in freezers 

operate continuously to keep their 

contents cold at all times, DOE is not 

proposing standards for standby and off 

mode energy use. 

B. Background 

1. Current Standards 

EPCA defines a walk-in cooler and a 

walk-in freezer as an enclosed storage 

space refrigerated to temperatures 

above, and at or below, respectively, 

32 °F that can be walked into. The 

statute also defines walk-in coolers and 

freezers as having a total chilled storage 

area of less than 3,000 square feet, 

excluding products designed and 

marketed exclusively for medical, 

scientific, or research purposes. (42 

U.S.C 6311(20)) EPCA also provides 

prescriptive standards for walk-in 

coolers and freezers manufactured on or 

after January 1, 2009, which are 

described below. 

First, EPCA sets forth general 

prescriptive standards for walk-ins. 

Walk-ins must have automatic door 

closers that firmly close all walk-in 

doors that have been closed to within 1 

inch of full closure, for all doors 

narrower than 3 feet 9 inches and 

shorter than 7 feet; walk-ins must also 

have strip doors, spring hinged doors, or 

other methods of minimizing infiltration 

when doors are open. Walk-ins must 

also contain wall, ceiling, and door 

insulation of at least R–25 for coolers 

and R–32 for freezers, excluding glazed 

portions of doors and structural 

members, and floor insulation of at least 

R–28 for freezers. Walk-in evaporator 

fan motors of under 1 horsepower and 

less than 460 volts must be 

electronically commutated motors 

(brushless direct current motors) or 

three-phase motors, and walk-in 

condenser fan motors of under 1 

horsepower must use permanent split 

capacitor motors, electronically 

commutated motors, or three-phase 

motors. Interior light sources must have 

an efficacy of 40 lumens per watt or 

more, including any ballast losses; lessefficacious lights may only be used in 

conjunction with a timer or device that 

turns off the lights within 15 minutes of 

when the walk-in is unoccupied. See 42 

U.S.C. 6313(f)(1). 

Second, EPCA sets forth new 

requirements related to electronically 

commutated motors for use in walk-ins. 

See 42 U.S.C. 6313(f)(2)). Specifically, 

in those walk-ins that use an evaporator 

fan motor with a rating of under 1 

horsepower and less than 460 volts, that 

motor must be either a three-phase 

motor or an electronically commutated 

motor unless DOE determined prior to 

January 1, 2009 that electronically 

commutated motors are available from 

only one manufacturer. (42 U.S.C. 

6313(f)(2)(A)) DOE determined by 

January 1, 2009 that these motors were 

available from more than one 

manufacturer; thus, according to EPCA, 

walk-in evaporator fan motors with a 

rating of under 1 horsepower and less 

than 460 volts must be either threephase motors or electronically 

commutated motors. DOE documented 

this determination in the rulemaking 

docket as docket ID EERE–2008–BT– 

STD–0015–0072. This document can be 


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found at http://www.regulations.gov/

#!documentDetail;D=EERE-2008-BTSTD-0015-0072. Additionally, EISA 

provided DOE with the authority to 

permit the use of other types of motors 

as evaporative fan motors—if DOE 

determines that, on average, those other 

motor types use no more energy in 

evaporative fan applications than 

electronically commutated motors. (42 

U.S.C. 6313(f)(2)(B)) DOE is unaware of 

any other motors that would offer 

performance levels comparable to the 

electronically commutated motors 

required by Congress. Accordingly, all 

evaporator motors rated at under 1 

horsepower and under 460 volts must 

be electronically commutated motors or 

three-phase motors. 

Third, EPCA sets forth additional 

requirements for walk-ins with 

transparent reach-in doors. Freezer 

doors must have triple-pane glass with 

either heat-reflective treated glass or gas 

fill for doors and windows for freezers. 

Cooler doors must have either doublepane glass with treated glass and gas fill 

or triple-pane glass with treated glass or 

gas fill. (42 U.S.C. 6313(f)(3)(A)–(B)) For 

walk-ins with transparent reach-in 

doors, EISA also prescribed specific 

anti-sweat heater-related requirements: 

Walk-ins without anti-sweat heater 

controls must have a heater power draw 

of no more than 7.1 or 3.0 watts per 

square foot of door opening for freezers 

and coolers, respectively. Walk-ins with 

anti-sweat heater controls must either 

have a heater power draw of no more 

than 7.1 or 3.0 watts per square foot of 

door opening for freezers and coolers, 

respectively, or the anti-sweat heater 

controls must reduce the energy use of 

the heater in a quantity corresponding 

to the relative humidity of the air 

outside the door or to the condensation 

on the inner glass pane. See 42 U.S.C. 

6313(f)(3)(C)–(D). 

2. History of Standards Rulemaking for 

Walk-In Coolers and Freezers 

EPCA directs the Secretary to issue 

performance-based standards for walkins that would apply to equipment 

manufactured 3 years after the final rule 

is published, or 5 years if the Secretary 

determines by rule that a 3-year period 

is inadequate. (42 U.S.C. 6313(f)(4)) 

DOE initiated the current rulemaking 

by publishing a notice announcing the 

availability of its ‘‘Walk-In Coolers and 

Walk-In Freezers Energy Conservation 

Standard Framework Document’’ and a 

meeting to discuss the document. The 

notice also solicited comment on the 

matters raised in the document. 74 FR 

411 (Jan 6, 2009). More information on 

the framework document is available at: 

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

appliance_standards/rulemaking.aspx/

ruleid/30. The framework document 

described the procedural and analytical 

approaches that DOE anticipated using 

to evaluate energy conservation 

standards for walk-ins and identified 

various issues to be resolved in 

conducting this rulemaking. 

DOE held the framework public 

meeting on February 4, 2009, in which 

it: (1) Presented the contents of the 

framework document; (2) described the 

analyses it planned to conduct during 

the rulemaking; (3) sought comments 

from interested parties on these 

subjects; and (4) in general, sought to 

inform interested parties about, and 

facilitate their involvement in, the 

rulemaking. Major issues discussed at 

the public meeting included: (1) The 

scope of coverage for the rulemaking; (2) 

development of a test procedure and 

appropriate test metrics; (3) 

manufacturer and market information, 

including distribution channels; (4) 

equipment classes, baseline units, and 

design options to improve efficiency; 

and (5) life-cycle costs to consumers, 

including installation, maintenance, and 

repair costs, and any consumer 

subgroups DOE should consider. At the 

meeting and during the comment period 

on the framework document, DOE 

received many comments that helped it 

identify and resolve issues pertaining to 

walk-ins relevant to this rulemaking. 

DOE then gathered additional 

information and performed preliminary 

analyses to help develop potential 

energy conservation standards for this 

equipment. This process culminated in 

DOE’s announcement of another public 

meeting to discuss and receive 

comments on the following matters: (1) 

The equipment classes DOE planned to 

analyze; (2) the analytical framework, 

models, and tools that DOE used to 

evaluate standards; (3) the results of the 

preliminary analyses performed by 

DOE; and (4) potential standard levels 

that DOE could consider. 75 FR 17080 

(April 5, 2010) (the April 2010 Notice). 

DOE also invited written comments on 

these subjects and announced the 

availability on its Web site of a 

preliminary technical support document 

(preliminary TSD) it had prepared to 

inform interested parties and enable 

them to provide comments. Id. (More 

information about the preliminary TSD 

is available at: http://

www1.eere.energy.gov/buildings/

appliance_standards/rulemaking.aspx/

ruleid/30.)Finally, DOE sought views on 

other relevant issues that participants 

believed either would impact walk-in 

standards or that the proposal should 

address. Id. at 17083. 

The preliminary TSD provided an 

overview of the activities DOE 

undertook to develop standards for 

walk-ins and discussed the comments 

DOE received in response to the 

framework document. The preliminary 

TSD also addressed separate standards 

for the walk-in envelope and the 

refrigeration system, as well as 

compliance and enforcement 

responsibilities and food safety 

regulatory concerns. The document also 

described the analytical framework that 

DOE used (and continues to use) in 

considering standards for walk-in 

coolers and freezers, including a 

description of the methodology, the 

analytical tools, and the relationships 

between the various analyses that are 

part of this rulemaking. Additionally, 

the preliminary TSD presented in detail 

each analysis that DOE had performed 

for these products up to that point, 

including descriptions of inputs, 

sources, methodologies, and results. 

These analyses were as follows: 

• A market and technology 

assessment addressed the scope of this 

rulemaking, identified the potential 

classes for walk-in coolers and freezers, 

characterized the markets for these 

products, and reviewed techniques and 

approaches for improving their 

efficiency; 

• A screening analysis reviewed 

technology options to improve the 

efficiency of walk-in coolers and 

freezers, and weighed these options 

against DOE’s four prescribed screening 

criteria; 

• An engineering analysis estimated 

the manufacturer selling prices (MSPs) 

associated with more energy-efficient 

walk-in coolers and freezers; 

• An energy use analysis estimated 

the annual energy use of walk-in coolers 

and freezers; 

• A markups analysis converted 

estimated MSPs derived from the 

engineering analysis to consumer prices; 

• A life-cycle cost analysis calculated, 

for individual consumers, the 

discounted savings in operating costs 

throughout the estimated average life of 

walk-in coolers and freezers, compared 

to any increase in installed costs likely 

to result directly from the imposition of 

a given standard; 

• A payback period analysis 

estimated the amount of time it takes 

individual consumers to recover the 

higher purchase price expense of more 

energy-efficient products through lower 

operating costs; 

• A shipments analysis estimated 

shipments of walk-in coolers and 

freezers over the time period examined 

in the analysis, and was used in 

performing the national impact analysis; 


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• A national impact analysis assessed 

the national energy savings and the 

national net present value of total 

consumer costs and savings that are 

expected to result from specific 

potential energy conservation standards 

for walk-in coolers and freezers; and 

• A preliminary manufacturer impact 

analysis (MIA) took the initial steps in 

evaluating the effects on manufacturers 

of new efficiency standards. 

The public meeting announced in the 

April 2010 Notice took place on May 19, 

2010. At this meeting, DOE presented 

the methodologies and results of the 

analyses set forth in the preliminary 

TSD. Interested parties that participated 

in the public meeting discussed a 

variety of topics, but the comments 

centered on the following issues: (1) 

Separate standards for the refrigeration 

system and the walk-in envelope; (2) 

responsibility for compliance; (3) 

equipment classes; (4) technology 

options; (5) energy modeling; (6) 

installation, maintenance, and repair 

costs; (7) markups and distributions 

chains; (8) walk-in cooler and freezer 

shipments; and (9) test procedures. The 

comments received since publication of 

the April 2010 Notice, including those 

received at the May 2010 public 

meeting, have contributed to DOE’s 

proposed resolution of the issues in this 

rulemaking as they pertain to walk-ins. 

This NOPR responds to the issues raised 

by the commenters. (A parenthetical 

reference at the end of a quotation or 

paraphrase provides the location of the 

item in the public record.) 

III. General Discussion 

In preparing today’s notice, DOE 

considered input from the various 

interested parties who commented on 

the framework document and 

preliminary analysis, information 

obtained from manufacturer interviews, 

and additional research that DOE 

conducted. The interested parties who 

provided comments to DOE during the 

framework document and preliminary 

analysis phases included the following: 

TABLE III–1—FRAMEWORK AND PRELIMINARY ANALYSIS COMMENTERS

Commenter(s) Abbreviated 

designation Affiliation Comment number(s) in docket 

AFM Corporation ............................................................................................. AFM ..................... Manufacturer ........ 0012.1 

Air-Conditioning, Heating, and Refrigeration Institute .................................... AHRI .................... Trade Association 0036.1, 0055.1 

American Chemistry Council ........................................................................... ACC ..................... Material Supplier .. 0062.1 

American Chemistry Council Center for the Polyurethanes Industry ............. CPI ....................... Material Supplier .. 0052.1 

American Council for an Energy Efficient Economy, Appliance Standards 

Awareness Project, Alliance to Save Energy, Natural Resources Defense 

Council, Northwest Energy Efficiency Alliance.

Joint Advocates ... Energy Efficiency 

Advocates.

0070.1 

American Panel Corporation ........................................................................... American Panel ... Manufacturer ........ 0039.1, 0048.1 

AmeriKooler, Inc. ............................................................................................. AmeriKooler ......... Manufacturer ........ 0065.1 

Appliance Standards Awareness Project ........................................................ ASAP ................... Energy Efficiency 

Advocate.

0024.1 

Bally Refrigerated Boxes, Inc. ........................................................................ Bally ..................... Manufacturer ........ 0023.1 

Carpenter Co. Chemical Systems Division ..................................................... Carpenter ............. Material Supplier .. 0068.1 

Craig Industries, Inc. and U.S. Cooler Company ........................................... Craig Industries ... Manufacturer ........ 0064.1 

Craig Industries, Inc. and US Cooler Company ............................................. Craig Industries ... Manufacturer ........ 0011.1, 0025.1, 0038.1, 

0064.1, 0071.1 

CrownTonka Walk-Ins ..................................................................................... CrownTonka ........ Manufacturer ........ 0026.1, 0057.1 

Earthjustice ...................................................................................................... Earthjustice .......... Energy Efficiency 

Advocate.

0027.1, 0047.1 

Edison Electric Institute ................................................................................... EEI ....................... Energy Efficiency 

Advocate.

0028.1 

Eliason Corporation ......................................................................................... Eliason ................. Manufacturer ........ 0013.1, 0022.1 

Foam Supplies, Inc. ........................................................................................ FSI ....................... Material Supplier .. 0029.1 

Heatcraft Refrigeration Products LLC ............................................................. Heatcraft .............. Manufacturer ........ 0058.1, 0069.1 

Heating, Air-conditioning & Refrigeration Distributors International ............... HARDI .................. Trade Association 0031.1 

Hill Phoenix Walk-Ins ...................................................................................... Hill Phoenix .......... Manufacturer ........ 0066.1 

Hired Hand Technologies ............................................................................... Hired Hand .......... Manufacturer ........ 0030.1, 0050.1 

Hussmann and Ingersoll Rand ....................................................................... Ingersoll Rand ..... Manufacturer ........ 0053.1 

Kason Industries, Inc. ..................................................................................... Kason ................... Component Supplier.0009.1, 0019.1 

Kysor Panel Systems ...................................................................................... Kysor .................... Manufacturer ........ 0032.1, 0054.1 

Manitowoc Ice ................................................................................................. Manitowoc ............ Manufacturer ........ 0056.1 

Master-Bilt Products, Inc. ................................................................................ Master-Bilt ............ Manufacturer ........ 0033.1, 0046.1 

NanoPore Insulation, LLC ............................................................................... NanoPore ............. Material Supplier .. 0067.1 

Nor-Lake, Incorporated ................................................................................... Nor-Lake .............. Manufacturer ........ 0049.1 

Owens Corning Foam Insulation, LLC ............................................................ Owens Corning .... Material Supplier .. 0034.1 

Southern California Edison and Technology Test Centers ............................ SCE ..................... Utility .................... 0035.1 

Southern California Edison, San Diego Gas & Electric, Pacific Gas & Electric Company, Sacramento Municipal Utility District.Joint Utilities ........ Utility Group ......... 0061.1 

The Northwest Energy Efficiency Alliance and the Northeast Power Coordinating Council.NEEA and NPCC Utility Representative.0021.1, 0059.1 

Zero-Zone, Inc. ................................................................................................ Zero-Zone ............ Manufacturer ........ 0051.1 

A. Component Level Standards 

In the framework document, DOE 

considered setting standards that would 

apply to the entire walk-in. See the 

framework document at http:// 

www1.eere.energy.gov/buildings/ 

appliance_standards/commercial/pdfs/ 

wicf_framework_doc.pdf. Several 

interested parties expressed concern 

about this approach because of the 

variety among assembled walk-ins, 

which would make compliance with 


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such a walk-in standard difficult and 

burdensome. Stakeholders also stated 

that different components of each walkin would likely be manufactured by 

different entities, which would make it 

difficult to enforce any standard that 

applied to an entire walk-in. 

After considering the comments 

submitted on the framework document, 

DOE modified its approach in the 

preliminary analysis. During that phase, 

it had tentatively identified two primary 

components of a walk-in: the envelope 

(the insulated box that separates the 

exterior from the interior) and the 

refrigeration system (the mechanical 

equipment that cools the envelope’s 

interior). DOE also indicated that it was 

tentatively considering developing 

separate standards for refrigeration 

systems and envelopes. 

Several interested parties agreed with 

this general approach. Manitowoc 

supported separate standards for the 

envelope and refrigeration system, 

stating that the envelope is typically 

supplied by one manufacturer and the 

refrigeration system is typically 

supplied by one or more manufacturers. 

(Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 38 and No. 0056.1 at p. 

1) Manitowoc further stated that it 

would not be practical to regulate the 

energy used by the entire walk-in 

assembly because walk-ins are highly 

customized. Manitowoc estimated that 

fewer than 20 percent of its walk-ins use 

a standard envelope and refrigeration 

system combination. (Manitowoc, No. 

0056.1 at p. 1) Pacific Gas and Electric 

Company, Southern California Edison, 

Sempra Energy Utility, and the 

Sacramento Municipal Utility District 

(hereafter referred to as the ‘‘Joint 

Utilities’’) also agreed with DOE’s 

proposal to separate the refrigeration 

system standards from the envelope 

standards because the components are 

separately produced and often 

separately sold. (Joint Utilities, No. 

0061.1 at pp. 2–3) American Panel 

stated that the envelope and 

refrigeration systems must be 

considered separately because the 

majority of WICFs are custom-made. 

(American Panel, No. 0048.1 at p. 4) 

Kysor, Master-Bilt, AHRI, and 

CrownTonka all supported separate 

standards for the envelope and 

refrigeration systems. (Kysor, Public 

Meeting Transcript, No. 0045 at p. 39; 

Master-Bilt, No. 0046.1 at p. 1; AHRI, 

No. 0055.1 at p. 2; CrownTonka, No. 

0057.1 at p. 1) One interested party did 

not agree with this approach. Craig 

Industries, also doing business as U.S. 

Cooler, commented that DOE should 

establish a combination standard for the 

envelope and refrigeration system to 

permit manufacturers greater flexibility 

when designing walk-ins. Under this 

combination approach, a more efficient 

envelope could be paired with a less 

efficient refrigeration system, or vice 

versa, to achieve the same overall 

efficiency at a lower cost. (Craig 

Industries, No. 0064.1 at p. 1) 

Additionally, interested parties 

suggested that DOE extend the idea of 

separate standards to subcomponents of 

envelopes and refrigeration systems. 

The Joint Utilities stated that a 

component performance approach 

would accurately capture efficiency 

measurements associated with the 

components, and that energy savings 

associated with targeted components 

would apply to different configurations 

of whole walk-ins and possibly even to 

repairs and retrofits. (Joint Utilities, No. 

0061.1 at p. 4) The Joint Utilities further 

added that DOE should consider 

component performance standards for 

major walk-in components that could be 

enforced at the level of the 

manufacturer’s catalog and could be 

labeled for easy inspection. (Joint 

Utilities, No. 0061.1 at p. 12) Hill 

Phoenix also recommended that large 

construction-based envelopes (i.e., those 

constructed in a manner similar to a 

building) be regulated at the component 

level, asserting that these envelopes may 

need many different options and design 

flexibility, without which a wholeenvelope calculation would likely limit 

the accuracy of any estimate of a walkin’s total energy use. (Hill Phoenix, No. 

0066.1 at p. 1) As stated previously, 

Manitowoc agreed that it would not be 

practical to regulate the energy used by 

the entire walk-in assembly because 

walk-ins are highly customized. 

(Manitowoc, No. 0056.1 at p. 1) 

Manitowoc also remarked that 

performance metrics could be 

developed for sub-classes of the 

components of an envelope, and the 

component manufacturers should be 

responsible for their own components. 

(Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 46) 

Other stakeholders discussed specific 

sub-components of the envelope or the 

refrigeration system that could be 

regulated. Kysor mentioned panels and 

doors as envelope components that 

should be considered separately and 

stated that because these components 

are often manufactured by separate 

parties, the manufacturer of each 

component should be responsible for 

the performance of that component. 

(Kysor, Public Meeting Transcript, No. 

0045 at p. 41) The Northwest Energy 

Efficiency Alliance (NEEA) and 

Northwest Power Conservation Council 

(NPCC) recommended that DOE develop 

efficiency performance standards for 

display and solid doors separately so 

that an envelope manufacturer could 

certify that the envelope meets specified 

standards. (NEEA and NPCC, No. 0059.1 

at p. 2) 

Likewise, with regard to the 

refrigeration system, NEAA and NPCC 

recommended that DOE regulate the 

efficiency of the cooling system 

components separately, an example of 

which would be setting a performance 

requirement for the specific efficiency of 

unit coolers based on control 

algorithms. (NEAA and NPCC, No. 

0059.1 at pp. 2 and 7) The Joint Utilities 

also stated that a refrigeration system 

requirement should not be based on a 

single metric and added that the indoor 

unit (i.e., unit cooler) could have a 

minimum efficiency requirement 

regardless of other components of the 

refrigeration system. (Joint Utilities, No. 

0061.1 at p. 4 and Public Meeting 

Transcript, No. 0045 at p. 64) 

Manitowoc, on the other hand, 

recommended that manufacturers have 

the option of rating the entire 

refrigeration system and that 

considering the condensing unit 

separately would not allow 

manufacturers to implement options 

that would improve the efficiency of a 

matched system. (Manitowoc, Public 

Meeting Transcript, No. 0045 at p. 38) 

Manitowoc further remarked that testing 

the refrigeration system as an integrated, 

single component and calculating the 

overall annual efficiency has the 

greatest potential for optimizing energy 

efficiency, but added that DOE should 

permit the individual components to be 

tested and the performance stated for 

the individual parts. (Manitowoc, Public 

Meeting Transcript, No. 0045 at p. 59) 

After carefully considering the 

comments described above, DOE 

proposes an approach for the envelope 

that would set separate standards for 

panels, display doors, and non-display 

doors for the reasons set forth below. 

Different manufacturers typically 

produce panels and doors (both display 

and non-display types) for use in walkin applications. In particular, display 

doors are commonly manufactured 

separately because their unique 

construction and materials require 

specialized manufacturing methods. 

Additionally, the modular nature of a 

walk-in envelope means that it is 

constructed of relatively standardized 

components that can be assembled in a 

virtually infinite number of 

configurations that may affect the 

overall consumption of a given walk-in 

unit. By regulating the performance of 

those standardized components, 

manufacturers will be able to choose 


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compliant components that should help 

ensure that whatever walk-in 

configuration is built satisfies the 

minimal level of energy consumption 

and efficiency that DOE may prescribe. 

Because of the large number of possible 

combinations of panels and doors that 

could make up an envelope, the burdens 

presented by a system-based approach 

for the entire walk-in unit would also 

likely be significantly greater than the 

burdens of the proposed approach 

because each walk-in envelope 

configuration would need to be 

separately certified as compliant. 

Alternatively, if DOE were to establish 

a set envelope of specified dimensions 

for a manufacturer to build and then to 

certify as compliant, the efficiency or 

energy usage measurement from that 

envelope would not only be more costly 

to obtain, but it would also not 

necessarily reflect the actual energy 

usage or efficiency of a given walk-in 

that is installed in the field. 

DOE also notes that requiring an 

overall envelope performance standard 

would be likely to present significant 

enforcement burdens, as it would likely 

require DOE to test several fully 

constructed envelopes in order to 

ascertain the energy efficiency 

performance of a given envelope. DOE 

tentatively believes that such an 

approach, at this time, would be unduly 

burdensome. 

DOE is not, however, proposing to set 

standards for the constituent 

components of refrigeration systems 

separately. To ensure that 

manufacturers have sufficient flexibility 

to improve the energy efficiency 

performance of their systems, DOE 

proposes to set a performance standard 

for the overall refrigeration system and 

to regulate that system as a single 

component. This approach would help 

ensure that the final refrigeration system 

assembled by the manufacturer would 

meet a given level of efficiency and 

would account for the interactive effects 

of the numerous components 

comprising the overall system. For 

example, some refrigeration systems 

implement complex control strategies, 

the benefits of which could not be 

adequately demonstrated if the 

condensing unit and unit cooler were 

considered separately for purposes of 

setting standards. 

In summary, DOE proposes to set 

specific component standards for the 

panels, display doors, and non-display 

doors of a walk-in, and a single standard 

to assess the overall performance of the 

refrigeration system. DOE acknowledges 

that, by not establishing a standard for 

the energy use of the entire walk-in, 

manufacturers cannot meet the standard 

by pairing a more-efficient envelope 

with a less-efficient refrigeration system, 

and vice versa. Also, DOE would not 

account for the energy use of some 

components, such as the electricity use 

of overhead lighting or heat load due to 

the infiltration of warm air into the 

walk-in, and would not consider design 

options whose efficacy depends on the 

interaction between the different 

covered components. Including these 

factors as part of the current rulemaking 

would likely introduce significant 

complications with respect to 

compliance and enforcement while 

yielding a comparatively small benefit 

in energy savings. DOE believes, 

however, that the proposed approach 

would help ensure that the walk-in 

components used by manufacturers 

satisfy some minimal level of energy 

efficiency and reduce the overall 

certification and enforcement burden on 

manufacturers. DOE may reconsider this 

issue in the future, particularly if 

accurate computer modeling, such as 

through an alternative efficiency 

determination method, becomes 

possible with respect to predicting the 

energy usage and efficiency of fully 

constructed walk-in units. DOE 

continues to invite comments on the 

approach presented in this NOPR. 

B. Test Procedures and Metrics 

While Congress had initially 

prescribed certain performance 

standards and test procedures 

concerning walk-ins as part of the EISA 

2007 amendments, Congress also 

instructed DOE to develop specific test 

procedures to cover walk-in equipment. 

DOE subsequently established a test 

procedure for walk-ins. See 76 FR 21580 

(April 15, 2011). See also 76 FR 33631 

(June 9, 2011) (final technical 

corrections). The test procedure lays out 

an approach that bases compliance on 

the ability of component manufacturers 

to produce components that meet the 

required standards. This approach is 

also consistent with the framework 

established by Congress, which set 

specific energy efficiency performance 

requirements on a component-level 

basis. (42 U.S.C. 6313(f)) The approach 

is discussed more fully below. 

1. Panels 

In the final test procedure rule for 

walk-ins, DOE defines ‘‘panel’’ as a 

construction component, excluding 

doors, used to construct the envelope of 

the walk-in (i.e., elements that separate 

the interior refrigerated environment of 

the walk-in from the exterior). 76 FR 

33631 (June 9, 2011). The rule explains 

that panel manufacturers would test 

their panels to obtain a thermal 

transmittance metric—known as Ufactor, measured in Btu/h-ft2-°F—and 

identifies three types of panels: display 

panels, floor panels, and non-floor 

panels. A display panel is defined as a 

panel that is entirely or partially 

comprised of glass, a transparent 

material, or both, and is used for display 

purposes. Id. It is considered equivalent 

to a window and the U-factor is 

determined by NFRC 100–2010–E0A1, 

‘‘Procedure for Determining 

Fenestration Product U-factors.’’ 76 FR 

at 33639. Floor panels are used for walkin floors, whereas non-floor panels are 

used for walls and ceilings. 

The U-factor for floor and non-floor 

panels accounts for any structural 

members internal to the panel and the 

long-term thermal aging of foam. This 

value is determined by a three-step 

process. First, both floor and non-floor 

panels must be tested using ASTM 

C1363–10, ‘‘Standard Test Method for 

Thermal Performance of Building 

Materials and Envelope Assemblies by 

Means of a Hot Box Apparatus.’’ The 

panel’s core and edge regions must be 

used during testing. Second, the panel’s 

core U-factor must be adjusted with a 

degradation factor to account for foam 

aging. The degradation factor is 

determined by EN 13165:2009–02, 

‘‘Thermal Insulation Products for 

Buildings—Factory Made Rigid 

Polyurethane Foam (PUR) Products— 

Specification,’’ or EN 13164:2009–02, 

‘‘Thermal Insulation Products for 

Buildings—Factory Made Products of 

Extruded Polystyrene Foam (XPS)— 

Specification,’’ as applicable. Third, the 

edge and modified core U-factors are 

then combined to produce the panel’s 

overall U-factor. All industry protocols 

were incorporated by reference most 

recently in the test procedure final rule 

correction. 76 FR 33631. 

2. Doors 

The walk-in test procedure final rule 

addressed two door types: display and 

non-display doors. Within the general 

context of walk-ins, a door consists of 

the door panel, glass, framing materials, 

door plug, mullion, and any other 

elements that form the door or part of 

its connection to the wall. DOE defines 

display doors as doors designed for 

product movement, display, or both, 

rather than the passage of persons; a 

non-display door is interpreted to mean 

any type of door that is not captured by 

the definition of a display door. 76 FR 

at 33631. 

The test metric for doors is in terms 

of energy use, measured in kilowatthours per day (kWh/day). The energy 

use accounts for thermal transmittance 

through the door and the electricity use 


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of any electrical components associated 

with the door. The thermal 

transmittance is measured by NFRC 

100–2010–E0A1, and is converted to 

energy consumption via conduction 

losses using an assumed efficiency of 

the refrigeration system in accordance 

with the test procedure. See 76 FR at 

33636–33637. The electrical energy 

consumption of the door is calculated 

by summing each electrical device’s 

individual consumption and accounts 

for all device controls by applying a 

‘‘percent time off’’ value to the 

appropriate device’s energy 

consumption. For any device that is 

located on the internal face of the door 

or inside the door, 75 percent of its 

power is assumed to contribute to an 

additional heat load on the compressor. 

Finally, the total energy consumption of 

the door is found by combining the 

conduction load, electrical load, and 

additional compressor load. 

3. Refrigeration 

The test procedure incorporates an 

industry test procedure applied to walkin refrigeration systems: AHRI 1250 (I– 

P)-2009, ‘‘2009 Standard for 

Performance Rating of Walk-In Coolers 

and Freezers’’ (‘‘AHRI 1250–2009’’). 76 

FR at 33631. This procedure applies to 

unit coolers and condensing units sold 

together as a matched system, unit 

coolers and condensing units sold 

separately, and unit coolers connected 

to compressor racks or multiplex 

condensing systems. It also describes 

methods for measuring the refrigeration 

capacity, on-cycle electrical energy 

consumption, off-cycle fan energy, and 

defrost energy. Standard test conditions, 

which are different for indoor and 

outdoor locations and for coolers and 

freezers, are also specified. 

The test procedure includes a 

calculation methodology to compute an 

annual walk-in energy factor (AWEF), 

which is the ratio of heat removed from 

the envelope to the total energy input of 

the refrigeration system over a year. 

AWEF is measured in Btu/W-h and 

measures the efficiency of a refrigeration 

system. DOE established a metric based 

on efficiency, rather than energy use, for 

describing refrigeration system 

performance, because a refrigeration 

system’s energy use would be expected 

to increase based on the size of the 

walk-in and on the heat load that the 

walk-in produces. An efficiency-based 

metric would account for this 

relationship and would simplify the 

comparison of refrigeration systems to 

each other. Therefore, DOE proposes to 

use an energy conservation standard for 

refrigeration systems that would be 

presented in terms of AWEF. 

C. Prescriptive Versus Performance 

Standards 

EPCA established standards for 

certain WICF components, while also 

directing the Secretary to establish 

‘‘performance-based standards,’’ which 

are the subject of this rulemaking. (42 

U.S.C. 6313(f)(4)(A)) Some interested 

parties suggested that DOE establish 

prescriptive standards for certain 

components in addition to the 

performance-based standards that DOE 

is proposing. NEEA and NPCC stated 

that DOE should establish a prescriptive 

(i.e., design) standard for electronically 

commutated motors. (NEEA and NPCC, 

No. 0059.1 at p. 7) The Joint Utilities 

recommended that DOE consider the 

precedent set by EPCA, as the EPCA 

provisions include both prescriptive 

and performance standards, and further 

recommended that DOE include 

additional prescriptive requirements for 

various components of a walk-in as 

necessary to maximize energy savings, 

and performance standards for the unit 

cooler. (Joint Utilities, No. 0061.1 at p. 

11) The Joint Utilities also 

recommended that DOE base new 

standards using those design 

requirements already prescribed by Title 

20 of California’s Code as the baseline 

when developing a performance 

standard. (Joint Utilities, No. 0061.1 at 

p. 13) SCE also referred to the 

prescriptive standards in Title 20, and 

suggested that because EPCA already 

established prescriptive measures, there 

will be limited additional benefit from 

performance measures. SCE further 

recommended that a standard for 

infiltration should be implemented 

through ASHRAE 90.1 (SCE, Public 

Meeting Transcript, No. 0045 at p. 63) 

The Joint Utilities recommended other 

specific prescriptive requirements that 

DOE should implement, including a 

minimum solar reflective index for the 

roof of a walk-in located outdoors, 

adjustable variable speed fan control for 

unit coolers, and floating head pressure 

control (a control that allows the 

pressure of the refrigerant at the 

compressor exit point to reach an 

optimal level). (Joint Utilities, No. 

0061.1 at pp. 5 and 12; Public Meeting 

Transcript, No. 0045 at p. 29) The Joint 

Utilities also asked DOE to examine 

how controls could be specified in a 

performance standard. (Joint Utilities, 

No. 0061.1 at p. 13) 

DOE notes that EPCA requires the 

promulgation of ‘‘performance-based 

standards’’ for walk-ins. That phrase 

indicates that DOE must set standards 

based on energy-related performance. 

See 42 U.S.C. 6313(f)(4). Accordingly, 

the design requirements suggested by 

commenters would be inconsistent with 

this requirement. 

D. Certification, Compliance, and 

Enforcement 

Walk-ins consist primarily of panels, 

display and non-display doors, and a 

refrigeration system, as described in 

section III.A. A number of arrangements 

exist for manufacturing walk-ins. One 

company may manufacture the panels, 

purchase the display and/or non-display 

doors and refrigeration system, assemble 

the walk-in at the factory, and ship the 

walk-in to a consumer. Alternatively, 

the same company may ship the walkin without a refrigeration system, which 

is then purchased separately by the 

consumer and installed on the walk-in. 

A contractor may purchase all the 

components from the component 

manufacturers and assemble the walk-in 

on-site. Other scenarios may also exist. 

Given the wide variety of scenarios 

under which a walk-in is manufactured, 

it is important to identify an entity or 

entities responsible for complying with 

standards and certifying compliance to 

DOE, and against whom a possible 

enforcement action could be taken. 

During the preliminary analysis 

public meeting, many interested parties 

expressed concern about compliance 

responsibilities and whether those 

burdens would fall on the envelope and 

refrigeration manufacturers 

individually, the installer, or another 

party. Additionally, the Joint Advocates 

submitted a comment urging DOE to 

ensure that the separate system 

components would be compliant with 

the energy conservation standards, and 

stating that each manufacturer should 

be held accountable for their products 

(e.g., door manufacturers are responsible 

for compliance with door standards). 

(Joint Advocates, No. 0070.1 at pp. 2–3) 

Craig Industries recommended that the 

definition of a manufacturer be 

expanded to include the installer of the 

unit, because the installer has the ability 

to ensure that the installed unit meets 

the energy conservation standards. 

(Craig Industries, No. 0071.1 at p. 1). 

Comments on this issue were 

summarized in the 2011 Certification, 

Compliance, and Enforcement for 

Consumer Products and Commercial 

and Industrial Equipment (referred to 

hereafter as the CCE final rule), and are 

not repeated here. 76 FR 12422, 12442– 

12446 (March 7, 2011). 

DOE notes that within the context of 

today’s proposal, the agency is 

contemplating an approach that would 

place the primary certification and 

compliance burden on those entities 

that manufacture particular key 

components of a walk-in—that is, the 


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panels, doors, and refrigeration system. 

This approach dovetails with that 

outlined in the recent test procedure 

final rule. The various requirements that 

manufacturers would need to follow are 

detailed in the 2011 final rule noted 

above regarding manufacturer 

certification, compliance, and 

enforcement-related responsibilities. 76 

FR 12422. For further details, see 76 FR 

at 12491. 

E. Technological Feasibility 

1. General 

In each standards rulemaking, DOE 

conducts a screening analysis, which it 

bases on information gathered on all 

current technology options and 

prototype designs that could improve 

the efficiency of the products or 

equipment that are the subject of the 

rulemaking. As the first step in such 

analysis, DOE develops a list of design 

options for consideration in 

consultation with manufacturers, design 

engineers, and other interested parties. 

DOE then determines which of these 

means for improving efficiency are 

technologically feasible. DOE considers 

technologies incorporated in 

commercial products or in working 

prototypes to be technologically 

feasible. 10 CFR 430, subpart C, 

appendix A, section 4(a)(4)(i) Although 

DOE considers technologies that are 

proprietary, it will not consider 

efficiency levels that can only be 

reached through the use of proprietary 

technologies (i.e., a unique pathway), as 

it could allow a single manufacturer to 

monopolize the market. 

Once DOE has determined that 

particular design options are 

technologically feasible, it generally 

evaluates each of these design options 

in light of the following additional 

screening criteria: (1) Practicability to 

manufacture, install, or service; (2) 

adverse impacts on product utility or 

availability; and (3) adverse impacts on 

health or safety. 10 CFR part 430, 

subpart C, appendix A, section 

4(a)(4)(ii)-(iv) Section IV.B of this notice 

discusses the results of the screening 

analyses for walk-in coolers and 

freezers. Specifically, it presents the 

designs DOE considered, those it 

screened out, and those that are the 

basis for the TSLs in this rulemaking. 

For further details on the screening 

analysis for this rulemaking, see chapter 

4 of the TSD. 

2. Maximum Technologically Feasible 

Levels 

When DOE proposes to adopt a new 

or amended or new energy conservation 

standard for a type or class of covered 

equipment such as walk-ins, it 

determines the maximum improvement 

in energy efficiency that is 

technologically feasible for such 

equipment. Accordingly, DOE 

determined the maximum 

technologically feasible (max-tech) 

improvements in energy efficiency for 

walk-ins by applying those design 

parameters that passed the screening 

analysis to the engineering analysis that 

DOE prepared as part of the preliminary 

analysis. 

In a comment on the max-tech levels 

in the preliminary analysis, AHRI 

commented that max-tech efficiency 

levels would be achieved only by a few 

units, and it requested that DOE 

demonstrate that max-tech levels can be 

achieved by commonly used products. 

(AHRI, No. 0055.1 at p. 3) 

As indicated previously, whether 

efficiency levels exist or can be 

achieved in commonly used products 

does not determine whether they are 

max-tech levels. DOE considers 

technologies to be technologically 

feasible if they are incorporated in any 

commercially available equipment or 

working prototypes. A maximum 

technologically feasible level results 

from the combination of design options 

that result in the highest efficiency level 

for an equipment class, with such 

design options consisting of 

technologies already incorporated in 

commercial products or working 

prototypes. DOE notes that it reevaluated the efficiency levels, 

including the max-tech levels, when it 

updated its results for this NOPR. See 

chapter 5 of the NOPR TSD for the 

results of the analysis. 

For panels, non-display doors, display 

doors, and refrigeration systems, the 

max-tech efficiency levels DOE has 

identified represent products with the 

most efficient design options available 

on the market, or previously offered for 

sale, in the given equipment class. No 

products at higher efficiencies are 

available or have been in the past, and 

DOE is not aware of any working 

prototype designs that would allow 

manufacturers to achieve higher 

efficiencies. Table III–2, Table III–3, 

Table III–4, and Table III–5 list the maxtech levels for panels, display doors, 

non-display doors, and refrigeration 

systems, respectively. (See section 

IV.A.3 for a description of the 

equipment classes.) 

For structural cooler and freezer 

panels, the max-tech level is 

represented by a single value for Ufactor. For all other TSLs (and for all 

floor panel levels including the maxtech level), the level is represented by 

a polynomial equation expressing the Ufactor in terms of certain panel 

dimensions, but the max tech level does 

not result in a polynomial equation 

because the U-factor does not vary with 

the size of the panel. (See section V.A.2 

for a list of equations for all TSLs.) At 

max-tech, panels are designed without 

structural members, making the panel 

uniformly comprised of hybrid 

insulation. See section IV.C.5 and 

chapter 5 of the TSD for the list of 

technologies included in max-tech 

equipment. 


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13 In the past DOE presented energy savings 

results for only the 30-year period that begins in the 

year of compliance. In the calculation of economic 

impacts, however, DOE considered operating cost 

savings measured over the entire lifetime of 

products purchased in the 30-year period. DOE has 

chosen to modify its presentation of national energy 

savings to be consistent with the approach used for 

its national economic analysis. 

TABLE III–3—MAX-TECH LEVELS FOR DISPLAY DOORS

Equipment class 

Equations for maximum 

energy consumption 

(kWh/day) * 

Display Door, Medium Temperature ................................................................................................................................... 0.0080 × Add + 0.29 

Display Door, Low Temperature ......................................................................................................................................... 0.11 × Add + 0.32 

*Add represents the surface area of the display door. 

TABLE III–4—MAX-TECH LEVELS FOR NON-DISPLAY DOORS

Equipment class 

Equations for maximum 

energy consumption 

(kWh/day) * 

Passage Door, Medium Temperature ................................................................................................................................. 0.00093 × And + 0.0083 

Passage Door, Low Temperature ....................................................................................................................................... 0.13 × And + 3.9 

Freight Door, Medium Temperature ................................................................................................................................... 0.00092 × And + 0.13 

Freight Door, Low Temperature .......................................................................................................................................... 0.094 × And + 5.2 

* And represents the surface area of the non-display door. 

TABLE III–5—MAX-TECH LEVELS FOR REFRIGERATION SYSTEMS

Equipment class 

Equations for minimum 

AWEF 

(Btu/W-h) * 

Dedicated Condensing, Medium Temperature, Indoor System, < 9,000 Btu/h Capacity .................................................. 2.63 × 10¥4 × Q + 4.53 

Dedicated Condensing, Medium Temperature, Indoor System, ≥ 9,000 Btu/h Capacity .................................................. 6.90 

Dedicated Condensing, Medium Temperature, Outdoor System, < 9,000 Btu/h Capacity ............................................... 9.23 × 10¥4 × Q + 3.90 

Dedicated Condensing, Medium Temperature, Outdoor System, ≥ 9,000 Btu/h Capacity ................................................ 12.21 

Dedicated Condensing, Low Temperature, Indoor System, < 9,000 Btu/h Capacity ........................................................ 1.93 × 10¥4 × Q + 1.93 

Dedicated Condensing, Low Temperature, Indoor System, ≥ 9,000 Btu/h Capacity ......................................................... 3.67 

Dedicated Condensing, Low Temperature, Outdoor System, < 9,000 Btu/h Capacity ...................................................... 4.53 × 10¥4 × Q + 2.17 

Dedicated Condensing, Low Temperature, Outdoor System, ≥ 9,000 Btu/h Capacity ...................................................... 6.25 

Multiplex Condensing, Medium Temperature ..................................................................................................................... 10.82 

Multiplex Condensing, Low Temperature ........................................................................................................................... 5.91 

* Q represents the system gross capacity as calculated in AHRI 1250. 

F. Energy Savings 

1. Determination of Savings 

For each TSL, DOE projected energy 

savings from the products that are the 

subject of this rulemaking purchased in 

the 30-year period that begins in the 

year of compliance with new standards 

(2017–2046). The savings are measured 

over the entire lifetime of products 

purchased in the 30-year period.13 DOE 

quantified the energy savings 

attributable to each TSL as the 

difference in energy consumption 

between each standards case and the 

base case. The base case represents a 

projection of energy consumption in the 

absence of amended mandatory 

efficiency standards and considers 

market forces and policies that affect 

demand for more efficient products. 

DOE used its national impact analysis 

(NIA) spreadsheet model to estimate 

energy savings from amended standards 

for the products that are the subject of 

this rulemaking. The NIA spreadsheet 

model (described in section IV.G of this 

notice and chapter 10 of the TSD) 

calculates energy savings in site energy, 

which is the energy directly consumed 

by products at the locations where they 

are used. For electricity, DOE reports 

national energy savings in terms of the 

savings in the energy that is used to 

generate and transmit the site 

electricity. To calculate this quantity, 

DOE derives annual conversion factors 

from the model used to prepare the 

Energy Information Administration’s 

(EIA) Annual Energy Outlook (AEO). 

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

51282 (Aug. 18, 2011), as amended at 77 

FR 49701 (August 17, 2012). The FFC 

metric includes the energy consumed in 

extracting, processing, and transporting 

primary fuels (i.e., coal, natural gas, 

petroleum fuels), and thus presents a 

more complete picture of the impacts of 

energy efficiency standards. DOE’s 

approach is based on calculation of an 

FFC multiplier for each of the energy 

types used by covered products. For 

more information on FFC energy 

savings, see sections IV.G.3 and IV.L 

and appendix 10G of the TSD. 

2. Significance of Savings 

DOE may not adopt a standard that 

would not result in significant 

additional energy savings. While the 

term ‘‘significant’’ is not defined in the 

Act, the U.S. Circuit Court of Appeals 

for the District of Columbia in Natural 

Resources Defense Council v. 

Herrington, 768 F.2d 1355, 1373 (DC 

Cir. 1985), indicated that Congress 

intended significant energy savings to 

be savings that were not ‘‘genuinely 

trivial.’’ The estimated energy savings in 

the analysis period for the trial standard 

levels considered in this rulemaking 

range from 4.28 to 6.37 quadrillion Btu 

(quads), an amount DOE considers 

significant. 


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G. Economic Justification 

1. Specific Criteria 

As discussed in section II.A, EPCA 

provides seven factors to be evaluated in 

determining whether a potential energy 

conservation standard is economically 

justified. The following sections 

generally discuss how DOE addresses 

each of those seven factors in this 

rulemaking. For further details and the 

results of DOE’s analyses pertaining to 

economic justification, see sections IV 

and V of today’s notice. 

a. Economic Impact on Manufacturers 

and Consumers 

In determining the impacts of an 

amended standard on manufacturers, 

DOE first uses an annual cash-flow 

approach to determine the quantitative 

impacts. This step includes both a shortterm assessment—based on the cost and 

capital requirements during the period 

between when a regulation is issued and 

when entities must comply with the 

regulation—and a long-term assessment 

over a 30-year period. The industrywide impacts analyzed include industry 

net present value (INPV), which values 

the industry on the basis of expected 

future cash flows; cash flows by year; 

changes in revenue and income; and 

other measures of impact, as 

appropriate. Second, DOE analyzes and 

reports the impacts on different types of 

manufacturers, including impacts on 

small manufacturers. Third, DOE 

considers the impact of standards on 

domestic manufacturer employment and 

manufacturing capacity, as well as the 

potential for standards to result in plant 

closures and loss of capital investment. 

Finally, DOE takes into account 

cumulative impacts of various DOE 

regulations and other regulatory 

requirements on manufacturers. 

For individual consumers, measures 

of economic impact include the changes 

in LCC and the PBP associated with new 

or amended standards. The LCC, which 

is also separately specified as one of the 

seven factors to be considered in 

determining the economic justification 

for a new or amended standard, is 

discussed in the following section. For 

consumers in the aggregate, DOE also 

calculates the net present value from a 

national perspective of the economic 

impacts on consumers over the forecast 

period used in a particular rulemaking. 

For the results of DOE’s analyses related 

to the economic impact on consumers, 

see section V.B.1 of this notice and 

chapters 8 and 11 of the TSD. For the 

results of DOE’s analyses related to the 

economic impact on manufacturers, see 

section V.B.2 of this notice and chapter 

12 of the TSD. 

b. Life-Cycle Costs 

The LCC is the sum of the purchase 

price of equipment (including the cost 

of its installation) and the operating 

expense (including energy and 

maintenance and repair expenditures) 

discounted over the lifetime of the 

equipment. The LCC savings for the 

considered efficiency levels are 

calculated relative to a base case that 

reflects likely trends in the absence of 

new standards. The LCC analysis 

requires a variety of inputs, such as 

equipment prices, equipment energy 

consumption, energy prices, 

maintenance and repair costs, 

equipment lifetime, and consumer 

discount rates. DOE assumes in its 

analysis that consumers purchase the 

equipment in the year in which 

compliance with the new standard is 

required. 

To account for uncertainty and 

variability in specific inputs, such as 

equipment lifetime and discount rate, 

DOE uses a distribution of values with 

probabilities attached to each value. A 

distinct advantage of this approach is 

that DOE can identify the percentage of 

consumers estimated to receive LCC 

savings or experience an LCC increase. 

In addition to identifying ranges of 

impacts, DOE evaluates the LCC impacts 

of potential standards on identifiable 

subgroups of consumers that may be 

disproportionately affected by a new 

national standard. For the results of 

DOE’s analyses related to the life-cycle 

costs of equipment, see section V.B.1.a 

of this notice and chapter 8 of the TSD. 

c. Energy Savings 

While significant conservation of 

energy is a separate statutory 

requirement for imposing an energy 

conservation standard, EPCA requires 

DOE, in determining the economic 

justification of a standard, to consider 

the total projected energy savings that 

are expected to result directly from the 

standard. DOE uses the NIA spreadsheet 

results in its consideration of total 

projected savings. For the results of 

DOE’s analyses related to the potential 

energy savings, see section V.B.3.a of 

this notice and chapter 10 of the TSD. 

d. Lessening of Utility or Performance of 

Products 

In establishing classes of equipment, 

and in evaluating design options and 

the impact of potential standard levels, 

DOE seeks to develop standards that 

would not lessen the utility or 

performance of the equipment under 

consideration. None of the TSLs 

presented in today’s NOPR would 

reduce the utility or performance of the 

equipment considered in the 

rulemaking. During the screening 

analysis, DOE eliminated from 

consideration any technology that 

would adversely impact consumer 

utility. For the results of DOE’s analyses 

related to the potential impact of new 

standards on equipment utility and 

performance, see section IV.B of this 

notice and chapter 4 of the TSD. 

e. Impact of Any Lessening of 

Competition 

EPCA directs DOE to consider the 

impact of any lessening of competition, 

as determined in writing by the 

Attorney General, that is likely to result 

from the imposition of a standard. It 

also directs the Attorney General to 

determine the impact, if any, of any 

lessening of competition likely to result 

from a proposed standard and to 

transmit such determination to the 

Secretary within 60 days of the 

publication of a proposed rule, together 

with an analysis of the nature and 

extent of the impact. DOE will transmit 

a copy of today’s proposed rule to the 

Attorney General with a request that the 

Department of Justice (DOJ) provide its 

determination on this issue. DOE will 

address the Attorney General’s 

determination in the final rule. 

f. Need of the Nation To Conserve 

Energy 

The energy savings from the proposed 

standards are likely to provide 

improvements to the security and 

reliability of the nation’s energy system. 

Reductions in the demand for electricity 

also may result in reduced costs for 

maintaining the reliability of the 

nation’s electricity system. DOE 

conducts a utility impact analysis to 

estimate how standards may affect the 

nation’s needed power generation 

capacity. The utility impact analysis is 

contained in chapter 14 of the TSD. 

The proposed standards also are 

likely to result in environmental 

benefits in the form of reduced 

emissions of air pollutants and 

greenhouse gases associated with energy 

production. DOE reports the emissions 

impacts from today’s standards, and 

from each TSL it considered, in section 

V.B.6 of this notice and chapter 15 of 

the TSD. DOE also reports estimates of 

the economic value of emissions 

reductions resulting from the 

considered TSLs. 

g. Other Factors 

EPCA allows the Secretary, in 

determining whether a standard is 

economically justified, to consider any 

other factors that the Secretary deems to 

be relevant. For the results of DOE’s 


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analyses related to other factors, see 

section V.B.7 of this notice. 

2. Rebuttable Presumption 

As set forth in 42 U.S.C. 

6295(o)(2)(B)(iii), EPCA provides for a 

rebuttable presumption that an energy 

conservation standard is economically 

justified if the additional cost to the 

consumer of equipment that meets the 

standard level is less than three times 

the value of the first-year energy (and, 

as applicable, water) savings resulting 

from the standard, as calculated under 

the applicable DOE test procedure. 

DOE’s LCC and PBP analyses generate 

values which can be used to calculate 

the payback period for consumers of 

products or equipment that meet the 

proposed standards. These analyses 

include, but are not limited to, the 

three-year payback period contemplated 

under the rebuttable presumption test. 

However, DOE routinely conducts a full 

economic analysis that considers the 

full range of impacts to the consumer, 

manufacturer, nation, and environment, 

as required under 42 U.S.C. 

6295(o)(2)(B)(i). The results of this 

analysis serve as the basis for DOE to 

evaluate the economic justification for a 

potential standard level (thereby 

supporting or rebutting the results of 

any preliminary determination of 

economic justification). The rebuttable 

presumption payback calculation is 

discussed in section IV.F.12 of this 

NOPR and chapter 8 of the TSD. 

IV. Methodology and Discussion 

A. Market and Technology Assessment 

When beginning an energy 

conservation standards rulemaking, 

DOE develops information that provides 

an overall picture of the market for the 

products concerned, including the 

purpose of the products, the industry 

structure, and market characteristics. 

This activity includes both quantitative 

and qualitative assessments based 

primarily on publicly-available 

information (e.g., manufacturer 

specification sheets and industry 

publications) and data submitted by 

manufacturers, trade associations, and 

other stakeholders. The subjects 

addressed in the market and technology 

assessment for this rulemaking include: 

(1) Quantities and types of products 

sold and offered for sale; (2) retail 

market trends; (3) products covered by 

the rulemaking; (4) equipment classes; 

(5) manufacturers; (6) regulatory 

requirements and non-regulatory 

programs (such as rebate programs and 

tax credits); and (7) technologies that 

could improve the energy efficiency of 

the products under examination. DOE 

researched manufacturers of panels, 

display doors, non-display doors, and 

refrigeration equipment. DOE also 

identified and characterized small 

business manufacturers of these 

components. See chapter 3 of the TSD 

for further discussion of the market and 

technology assessment. 

In the preliminary TSD, DOE 

presented market performance data. 

Typically, DOE’s analysis of market data 

uses catalog and performance data to 

determine the number of products on 

the market at varying efficiency levels. 

However, WICF systems and equipment 

have not previously been rated for 

efficiency by manufacturers, nor has an 

efficiency metric been established for 

this equipment. Based on the available 

data, DOE presented a sample of 

equipment at various sizes in the 

preliminary TSD and estimated the 

energy consumption of the equipment 

using the preliminary engineering 

spreadsheet. For refrigeration 

equipment in particular, DOE found 

that, as expected, the relationship 

between capacity and energy 

consumption was roughly linear. 

In a comment on the market 

performance data DOE presented, 

Manitowoc expressed concern that 

DOE’s use of linear trends to establish 

the relationship between energy 

consumption and net capacity will lead 

to an overestimation of the potential 

benefits of refrigeration system 

standards. (Manitowoc, No. 0056.1 at p. 

2) 

DOE presented the market 

performance data to illustrate its 

understanding of the market. In 

response to Manitowoc’s concern, DOE 

notes that the benefits of the rule are not 

derived from the estimates of market 

performance data but are determined 

from the LCC analysis and NIA. DOE 

seeks market performance data to help 

inform DOE’s analysis. 

1. Definitions Related to Walk-In 

Coolers and Freezers 

DOE proposes to amend the definition 

of display door and to adopt definitions 

for passage and freight door in order to 

clarify the boundaries separating these 

equipment classes. The display door 

definition was modified to permit 

transparent doors used for the passage 

of people to be categorized as display 

doors rather than as non-display passage 

doors. DOE is proposing to define 

transparent passage doors as a type of 

display door because transparent 

passage doors are generally constructed 

in the same manner and with the same 

materials as transparent reach-in doors. 

DOE proposes to include definitions for 

non-display passage and freight doors in 

order to clarify the distinction between 

the two types of doors. Non-display 

passage doors are typically smaller than 

freight doors and are designed for 

passage of people and small machines, 

whereas non-display freight doors are 

larger than passage doors and designed 

for the passage of large machines like 

forklifts. 

a. Display Doors 

As described in section III.B of this 

notice, DOE established a definition for 

display door in the test procedure. 76 

FR 33631 (June 9, 2011). DOE is now 

proposing to amend this definition to 

include all doors that are comprised of 

75 percent or more glass or other 

transparent material. This amendment is 

intended to classify passage doors that 

are mostly comprised of glass as display 

doors because the utility and 

construction of glass passage doors more 

closely resembles that of a display door. 

DOE proposes to define a display door 

as one that ‘‘(1) is designed for product 

display; or (2) has 75 percent or more 

of its surface area comprised of glass or 

another transparent material.’’ DOE 

requests comment on this proposed 

definition. 

b. Freight Doors 

DOE is proposing to separate nondisplay doors into two equipment 

classes, passage doors and freight doors. 

DOE proposes to define freight doors in 

order to clarify the distinction between 

these two equipment classes and 

remove any ambiguity about which 

energy standards apply to a given door. 

The two types of doors are constructed 

differently—for example, freight doors 

tend to have more structural support 

because they are bulkier—and warrant 

different standards for each type. DOE is 

proposing a definition of freight doors 

that would account for the fact that 

these doors are typically larger than 

passage doors and are used to allow 

large machines, like forklifts, into walkins. Specifically, DOE proposes to 

define a freight door to mean ‘‘a door 

that is not a display door and is equal 

to or larger than 4 feet wide and 8 feet 

tall.’’ DOE based these proposed 

dimensions on the standard size of a 

walk-in panel, which is 4 feet wide by 

8 feet tall. In DOE’s estimation doors 

used for the passage of people small 

machines would be less than the 

standard size of a walk-in panel and 

therefore all other doors would be 

freight doors. DOE requests comment on 

its proposed definition. 

c. Passage Doors 

DOE proposes a definition of passage 

doors to differentiate passage doors from 


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freight doors and display doors. Passage 

doors are mostly intended for the 

passage of people and small machines 

like hand carts and not for product 

display. DOE proposes to define this 

term to mean ‘‘a door that is not a 

freight or display door.’’ DOE requests 

comment on this proposed definition. 

2. Equipment Included in This 

Rulemaking 

a. Panels and Doors 

As mentioned in section III.B.1, DOE 

identified three types of panels used in 

the walk-in industry: Display panels, 

floor panels, and non-floor panels. 

Based on its research, DOE determined 

that display panels, typically found in 

beer caves (walk-ins used for the display 

and storage of beer or other alcoholic 

beverages often found in a supermarket) 

make up a small percentage of all panels 

currently present in the market. 

Therefore, because of the extremely 

limited energy savings potential 

currently projected to result from 

amending the requirements that these 

panels must meet, DOE is not proposing 

standards for walk-in display panels in 

this NOPR. Display panels, however, 

must still follow all applicable design 

standards already prescribed by EPCA, 

as discussed in section II.B.1 of this 

notice. 

DOE is also not proposing to require 

the installation of walk-in cooler floor 

panels. DOE did not consider including 

walk-in cooler floor panels in its 

analysis because of their complex 

nature. Through manufacturer 

interviews and market research, DOE 

determined that, unlike walk-in 

freezers, the majority of walk-in coolers 

are made with concrete floors and do 

not use insulated floor panels. The 

entity that installs the cooler floor is 

considered the floor’s manufacturer and 

is responsible for testing and complying 

with a walk-in cooler floor standard. If 

DOE were to require that all walk-in 

coolers to be equipped with floor 

panels, the onus of complying with this 

requirement would likely fall on entities 

that do not specialize in constructing 

walk-in coolers, and the accompanying 

burden in using these components and 

certifying compliance with the 

appropriate standards would likely be 

costly and difficult for that entity to 

fulfill. Therefore, at this time, it is 

DOE’s view that requiring the use of 

floor panels—along with the 

accompanying compliance costs— 

would present an undue burden to those 

entities that would be responsible for 

meeting these requirements. For these 

reasons, DOE is not proposing to require 

walk-in coolers to have floor panels, nor 

is DOE proposing energy efficiency 

standards for cooler floor panels. (DOE 

is, however, proposing energy efficiency 

standards for walk-in freezer floor 

panels and notes that EPCA requires 

floor insulation of at least R–28 for 

walk-in freezers. (42 U.S.C. 

6313(f)(1)(D)).) 

DOE also identified two types of 

doors in the walk-in market, display 

doors and non-display doors, which are 

discussed in section III.B.2 of this 

NOPR. All types of doors will be subject 

to the performance standards proposed 

in this rulemaking. 

b. Refrigeration System 

DOE defines the refrigeration system 

of a walk-in as the mechanism 

(including all controls and other 

components integral to the system’s 

operations) used to create the 

refrigerated environment in the interior 

of the walk-in cooler and freezer, 

consisting of either (1) a packaged 

system where the unit cooler and 

condensing unit are integrated into a 

single piece of equipment, (2) a split 

system with separate unit cooler and 

condensing unit sections, or (3) a unit 

cooler that is connected to a multiplex 

condensing system. 76 FR at 33631. 

DOE based its preliminary results 

used in today’s proposal on an analysis 

of storage coolers and freezers. DOE did 

not analyze blast freezer walk-ins, 

which are designed to quickly freeze 

food and then store it at a specified 

holding temperature. American Panel 

commented that blast freezer 

performance differs from storage freezer 

performance due to the large product 

loads experienced with this specialized 

equipment. (American Panel, No. 0048.1 

at p. 4) Heatcraft added that blast freezer 

refrigeration systems’ energy 

consumption would be higher than that 

of storage freezers and that they require 

wider fin spacing because of a higher 

rate of frost accumulation. (Heatcraft, 

No. 0058.1 at p. 1) 

DOE agrees with American Panel and 

Heatcraft that blast freezer refrigeration 

systems have different energy 

characteristics from storage freezers, but 

questions whether they would 

necessarily have a lower rated 

efficiency. DOE is not proposing to 

include blast freezers in this rulemaking 

analysis because they make up a small 

percentage of walk-ins currently present 

in the market. DOE requests comment 

on whether blast freezer refrigeration 

systems would have difficulty 

complying with DOE’s refrigeration 

efficiency standards and, if so, to direct 

DOE to (and supply it with) any test 

procedure data supporting this 

conclusion. DOE proposes to apply the 

same standards to blast freezer 

refrigeration systems as to storage 

freezer refrigeration systems, unless 

DOE finds that blast freezer refrigeration 

systems would have difficulty 

complying with DOE’s standards. 

Otherwise, DOE will consider excluding 

blast freezers from coverage under this 

rulemaking, although they would still 

have to comply with the already 

statutorily-prescribed standards in 

EPCA. 

Regarding the particular refrigerant to 

be used in the analysis, DOE analyzed 

refrigeration equipment using R404A, a 

hydrofluorocarbon (HFC) refrigerant 

blend, in the preliminary analysis. 

Heatcraft supported DOE’s approach to 

use only HFC refrigerants in the 

analysis, but also suggested that DOE 

consider lower global warming potential 

(GWP) refrigerants—such as R134a, 

R407A, or R407C—in the analyses as 

well because of shifts in the marketplace 

towards these products, even though 

these refrigerants may have lower 

efficiencies. (Heatcraft, No. 0069.1 at p. 

3) 

DOE used R404A in its analysis for 

this NOPR because it is widely used 

currently in the walk-in industry. DOE 

appreciates Heatcraft’s suggestion to 

analyze alternative refrigerants, 

especially those with a lower GWPs 

given the interest by many 

manufacturers to use these alternatives, 

and requests comment on the extent of 

the use or likely phase-in of lower GWP 

refrigerants and asks manufacturers to 

submit data related to the ability of the 

equipment (either existing or 

redesigned) using these refrigerants to 

meet the proposed standard, as well as 

the cost of such equipment. 

3. Equipment Classes 

a. Panels and Doors 

In the preliminary analysis, DOE 

proposed to divide the envelope into 

two separate equipment classes: display 

and non-display walk-ins (that is, walkins with and without glass). Display 

walk-ins are walk-ins that have doors 

for display purposes, are typically made 

with glass, and are inherently less 

efficient than walk-ins without glass 

because glass is not as insulative as the 

insulation material used in non-display 

walk-ins (typically polyurethane or 

polystyrene). 

Interested parties commented on the 

need to separate display and nondisplay walk-ins into two different 

equipment classes. Nor-Lake and AHRI 

agreed with the equipment classes 

proposed by DOE, and AHRI 

commented that the equipment classes 

represent the most common walk-in 


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configurations. (Nor-Lake, No. 0049.1 at 

p. 1; AHRI, No. 0055.1 at p. 2) 

Manitowoc stated that classification of 

envelopes into storage and display types 

is appropriate as it may allow for 

different performance levels for certain 

components. (Manitowoc, No. 0056.1 at 

p. 2) However, CrownTonka contended 

that it was unnecessary to have two 

equipment classes for display and nondisplay walk-ins and that separate 

classes for coolers and freezers are 

adequate. (CrownTonka, No. 0057.1 at 

p. 1) ASAP and SCE opined that one 

equipment class is sufficient and that 

the difference between non-display and 

display doors could be accounted for 

through a weighted average of the 

opaque and glass surface areas. (ASAP, 

Public Meeting Transcript, No. 0045 at 

p. 70; SCE, Public Meeting Transcript, 

No. 0045 at p. 79) However, NEAA, 

NPCC and Manitowoc countered that 

there should not be a single metric for 

both display and non-display doors 

because it would not account for the 

unique utility offered by display walkins (i.e., permitting the display of stored 

items). (NEAA and NPCC, Public 

Meeting Transcript, No. 0045 at p. 76; 

Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 78) NEAA and NPCC 

stated that, if DOE were to separate 

display and non-display walk-ins into 

two different classes, DOE should 

carefully define the boundary between 

the two classes. (NEAA and NPCC, 

Public Meeting Transcript, No. 0045 at 

p. 77) NEAA and NPCC also suggested 

that, as an alternative to having one 

equipment class for display and nondisplay walk-ins with a single 

performance metric, DOE should move 

to component level-based classes with 

separate performance metrics. (NEAA 

and NPCC, Public Meeting Transcript, 

No. 0045 at p. 76) 

Interested parties also submitted 

comments about the names of the 

equipment classes. NEAA and NPCC 

stated that if DOE has two separate 

equipment classes for display and nondisplay walk-ins, DOE should carefully 

define the boundary between the two 

classes. (NEAA and NPCC, Public 

Meeting Transcript, No. 0045 at p. 77) 

Kysor stated that the class names DOE 

suggested were confusing and offered an 

alternative—‘‘coolers with glass doors’’ 

instead of ‘‘display coolers’’—to help 

clarify the difference between the two 

separate equipment classes. (Kysor, 

Public Meeting Transcript, No. 0045 at 

p. 78) 

In light of the component level 

standards described in section III.A, 

DOE proposes to create separate 

equipment classes for panels, display 

doors, and non-display doors. These 

different items comprise the main 

components of a walk-in envelope. DOE 

proposes separate classes for panels, 

display doors, and non-display doors 

because each component type has a 

different utility to the consumer and 

possesses different energy use 

characteristics. 

In the preliminary analysis, DOE also 

considered the possibility of creating 

separate classes for walk-in coolers and 

walk-in freezers because EPCA 

specifically divides walk-in equipment 

into coolers (above 32 °F) and freezers 

(at or below 32 °F), (42 U.S.C. 6311(20)), 

and prescribes unique design 

requirements for each. (42 U.S.C. 

6313(f)(1)(C)–(D)(3)) DOE has continued 

to apply this approach in its analysis. 

Panels 

DOE has placed panels into two 

equipment classes: Freezer floor panels 

and non-floor panels (also called 

structural panels). DOE understands 

that freezer floor panels and structural 

panels serve two different utilities. 

Freezer floor panels, which are panels 

used to construct the floor of a walk-in, 

must often support the load of small 

machines like hand carts and pallet 

jacks on their horizontal faces. Nonfloor panels or structural panels, which 

include panels used to construct the 

ceiling or wall of a walk-in, provide 

structure for the walk-in. Because of 

their different utilities, the two classes 

of panels are constructed differently 

from each other and use different 

amounts of framing material, which 

affects the panels’ energy consumption. 

Structural panels are further divided 

into two more classes based on 

temperature—i.e., cooler versus freezer 

panels. Cooler structural panels are 

rated with their internal faces exposed 

to a temperature of 35 °F, as called for 

in the test procedure final rule. Freezer 

structural panels are used in walk-in 

freezers and rated with its internal face 

exposed to a temperature of ¥10 °F, as 

required by the test procedure final rule. 

76 FR at 21606; 10 CFR 431.303. EPCA 

also requires walk-in freezer panels to 

have a higher R-value than walk-in 

cooler panels. These differences result 

in different amounts of insulating foam 

between these panel types and affect the 

panel’s U-value. 

Doors 

DOE has distinguished between two 

different door types used in walk-in 

coolers and freezers: Display doors and 

non-display doors. DOE proposed 

separate classes for display doors and 

non-display doors to retain consistency 

with the dual approach laid out by 

EPCA for these walk-in components. (42 

U.S.C. 6313(f)(1)(C) and (3)) Nondisplay doors and display doors also 

serve separate purposes in a walk-in. 

Display doors contain mainly glass in 

order to display products or objects 

located inside the walk-in. Non-display 

doors function as passage and freight 

doors and are mainly used to allow 

people and products to be moved into 

and out of the walk-in. Because of their 

different utilities, display and nondisplay doors are made up of different 

material. Display doors are made of 

glass or other transparent material, 

while non-display doors are made of 

highly insulative materials like 

polyurethane. The different materials 

found in display and non-display doors 

significantly affect their energy 

consumption. 

DOE divided display doors into two 

equipment classes based on temperature 

differences: cooler and freezer display 

doors. Cooler display doors and freezer 

display doors are exposed to different 

internal temperature conditions, which 

affect the total energy consumption of 

the doors. In the test procedure final 

rule, DOE established an internal rating 

temperature of 35 °F for walk-in cooler 

display doors and ¥10 °F for walk-in 

freezer display doors. 76 FR at 21606; 10 

CFR Part 431, Subpart R, Appendix A, 

Section 5.3. 

DOE also separated non-display doors 

into two equipment classes, passage and 

freight doors. Passage doors are 

typically smaller doors and mostly used 

as a means of access for people and 

small machines, like hand carts. Freight 

doors typically are larger doors used to 

allow access for larger machines, like 

forklifts, into walk-ins. The different 

shape and size of passage and freight 

doors affects the energy consumption of 

the doors. Both passage and freight 

doors are also separated into cooler and 

freezer classes because, as explained for 

display doors, cooler and freezer doors 

are rated at different temperature 

conditions. A different rating 

temperature impacts the door’s energy 

consumption. 

In the preliminary analysis, DOE did 

not consider outdoor envelopes as a 

separate equipment class. Walk-ins 

located outdoors have very similar 

features to walk-ins located indoors, and 

DOE could not identify any additional 

design options that improved the energy 

consumption only of outdoor walk-ins. 

The Joint Utilities, NEEA and NPCC, 

CrownTonka, Nor-Lake, and Hill 

Phoenix stated that DOE should 

differentiate equipment classes by their 

external environment. (Joint Utilities, 

No. 0061.1 at p. 5; NEEA and NPCC, No. 

0059.1 at p. 6; CrownTonka, Public 

Meeting Transcript, No. 0045 at p. 81; 


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Nor-Lake, No. 0049.1 at p. 2; Hill 

Phoenix, No. 0066.1 at p. 2) The Joint 

Utilities requested that DOE evaluate 

cost-effective insulation levels for 

outdoor walk-ins, and stated that there 

would be a loss in energy savings if DOE 

did not consider region-specific 

insulation levels. (Joint Utilities, Public 

Meeting Transcript, No. 0045 at pp. 80 

and 82) Nor-Lake contested DOE’s claim 

that walk-ins designed as outdoor units 

include no additional features that 

impact energy consumption, stating that 

the ambient temperature and product 

load will change the energy 

consumption for both the indoor and 

outdoor units. (Nor-Lake, No. 0049.1 at 

p.2) Hill Phoenix recommended a 

separate equipment class for outdoor 

walk-ins because outdoor walk-ins must 

have thicker panels to withstand 

environmental conditions. (Hill 

Phoenix, No. 0066.1 at p. 2) American 

Panel observed that a walk-in located 

outdoors has an added benefit in that no 

building space was constructed to house 

the walk-in, which is a significant 

energy savings not considered in the 

preliminary analysis. (American Panel, 

No. 0048.1 at p. 3) 

Some commenters described how 

DOE could include equipment classes 

that capture the external conditions. 

SCE suggested that DOE set a series of 

different conditions by the location of 

the wall such as an outdoor, indoor, or 

demising wall (i.e., a dividing wall to 

separate spaces) between a cooler and a 

freezer space. (SCE, Public Meeting 

Transcript, No. 0045 at pp. 80 and 82– 

83) NEEA and NPCC recommended 

changing the equipment classes to 

indoor cooler, indoor freezer, outdoor 

cooler, and outdoor freezer. (NEEA and 

NPCC, No. 0059.1 at p. 6) 

Other interested parties agreed with 

DOE’s assertion that it was unnecessary 

to consider outdoor walk-ins as a 

separate equipment class. Kysor 

explained that the envelope would be 

designed for whatever ambient 

conditions it may be subjected to, and 

that adding additional performance 

requirements would be unnecessary. 

(Kysor, Public Meeting Transcript, No. 

0045 at p. 80) Manitowoc stated that 

there should not be any classification 

based on external environments as there 

are times when the envelope is exposed 

to both internal and external conditions. 

(Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 82) 

DOE is not proposing to include any 

panel or door equipment class that 

accounts for the different external 

environmental conditions that a walk-in 

could experience in real world 

applications. DOE does not find outdoor 

and indoor walk-in envelope 

components to have distinct utilities. 

Components for outdoor walk-ins and 

indoor walk-ins are generally 

constructed with the same design and 

materials and serve the same purpose. 

In response to Nor-Lake’s comment 

about DOE’s assumption about 

additional features, DOE clarifies that 

while the difference in outdoor 

temperatures affects the real world 

energy consumption of the walk-in 

envelope, DOE was referring to design 

features, such as different types of 

insulation, which differ from the design 

options found on indoor walk-ins and 

improve the energy efficiency of the 

outdoor walk-in. As to Hill Phoenix’s 

comment that a panel facing external 

conditions requires more insulation, 

DOE notes that panels with thicker 

insulation already surpass the baseline 

panel specifications, which would make 

it easier for these types of panels to meet 

the standards in today’s proposal. 

Hill Phoenix also recommended that 

DOE divide envelopes into factory 

assembled step-in style walk-ins and 

larger construction-based walk-ins. (Hill 

Phoenix, No. 0066.1 at p. 1) Because it 

is not proposing standards for walk-in 

envelopes, but rather for the panels and 

doors that are components of the 

envelopes, DOE has not adopted Hill 

Phoenix’s recommendation in today’s 

proposal. DOE has, however, separated 

into different equipment classes the 

components typically found in factoryassembled walk-ins, such as passage 

doors and floor panels, and those 

components found in large 

construction-based walk-ins, such as 

freight doors. DOE believes this 

approach will achieve the objective of 

the Hill Phoenix recommendation, 

namely that the proposed standards 

reflect the different energy use 

characteristics of factory-assembled and 

construction-based walk-ins. 

Table IV–1 lists the equipment classes 

DOE proposes to create in this NOPR. In 

the table below, medium temperature 

refers to cooler equipment and low 

temperature refers to freezer equipment. 

The column entitled ‘‘Class’’ lists the 

codes that will be used to abbreviate 

each equipment class, and will be used 

throughout the NOPR. 

TABLE IV–1—EQUIPMENT CLASSES

FOR PANELS AND DOORS

Product Temperature Class 

Structural 

Panel.

Medium ........ SP.M 

Low .............. SP.L 

Floor Panel ... Low .............. FP.L 

Display Door Medium ........ DD.M 

Low .............. DD.L 

TABLE IV–1—EQUIPMENT CLASSES

FOR PANELS AND DOORS—Continued 

Product Temperature Class 

Passage Door Medium ........ PD.M 

Low .............. PD.L 

Freight Door Medium ........ FD.M 

Low .............. FD.L 

b. Refrigeration Systems 

In the preliminary analysis, DOE 

considered dividing walk-in 

refrigeration systems into six equipment 

classes based on key physical 

characteristics that affect equipment 

efficiency: (1) The type of condensing 

unit (i.e., whether the system has a 

dedicated condensing unit or is 

connected to a multiplex system), (2) 

the operating temperature, and (3) the 

location of the walk-in (i.e., indoors or 

outdoors). In this NOPR, DOE also 

proposes to differentiate refrigeration 

system classes based on capacity. DOE 

discusses the four proposed class 

differentiations below. 

Type of Condensing Unit 

Due to the significant impact of the 

condensing unit on the overall energy 

consumption of the walk-in (as much as 

90 percent), the preliminary analysis 

differentiated between two different 

condensing unit types: dedicated 

condensing systems and multiplex 

condensing systems. In a dedicated 

condensing system, only one 

condensing unit (consisting of one or 

more compressors and condensers) 

serves a single walk-in. A multiplex 

condensing system consists of a rack of 

compressors usually located in a 

mechanical room, a large condenser or 

condensers usually located on the roof, 

and several unit coolers or evaporators 

belonging to various types of 

refrigeration equipment, including 

walk-ins. The only part of a multiplex 

condensing system that would be 

covered under the proposed standard 

would be a unit cooler in a walk-in—a 

‘‘unit cooler connected to a multiplex 

condensing system.’’ The compressor 

and condenser of a multiplex system 

would not be covered under the walkin standard because they serve 

equipment other than walk-ins. 

Furthermore, DOE would be unable to 

attribute the portion of energy use 

related to only the walk-in, at the point 

of manufacture of the compressor and 

condenser of the multiplex system. 

DOE received several comments about 

the classification of condensing types. 

AHRI, Nor-Lake and Manitowoc agreed 

with DOE’s equipment classes proposed 

in the preliminary analysis, while the 

Joint Utilities suggested redesignating 


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14For example, most medium temperature unit 

coolers are designed to operate between 15 °F and 

45 °F, and would not be able to operate at the low 

temperature rating condition of ¥10 °F. 

the multiplex and dedicated equipment 

classes as remote and self-contained, 

respectively. (AHRI, Public Meeting 

Transcript, No. 0045 at p. 74, Nor-Lake, 

No. 0049.1 at p. 1, Manitowoc, No. 0056 

at p. 2, Manitowoc, Public Meeting 

Transcript, No. 0045 at p. 73, Joint 

Utilities, Public Meeting Transcript, No. 

0045 at p. 71) The Joint Utilities 

suggested regulating condensing units 

in a manner similar to that used by DOE 

for commercial refrigeration equipment, 

which, in their view, would result in 

coverage of most of the condensing 

units serving the walk-in industry. (Joint 

Utilities, No. 0061.1 at p. 11, 12) The 

Joint Advocates suggested that DOE 

conduct a separate rulemaking for 

condensing units. (Joint Advocates, No. 

0070.1 at p. 3) They added that DOE 

should reduce the number of 

refrigeration types to self-contained and 

unit coolers only, while the Joint 

Utilities recommended against 

including remote condensing units as 

part of this rulemaking. (Joint 

Advocates, No. 0070.1 at p. 3, Joint 

Utilities, No. 0045 at p. 22) 

DOE believes the refrigeration systems 

covered by the two classes of 

equipment, dedicated condensing and 

multiplex condensing, accurately 

represent the range of refrigeration 

equipment used in walk-in coolers and 

freezers. Although the proposed classes 

differ from the classes designated in the 

commercial refrigeration equipment 

rulemaking, there are key differences 

between commercial refrigeration 

equipment refrigeration systems and 

walk-in refrigeration systems. The Joint 

Advocates and Joint Utilities refer to 

two types of refrigeration systems 

commonly used with commercial 

refrigeration equipment: ‘‘selfcontained’’ (meaning the entire 

refrigeration system is built into the 

case) and ‘‘remote condensing’’ 

(meaning the unit cooler is built into the 

case, but the whole case is connected to 

a central system of compressors and 

condensers, called a ‘‘rack’’ or 

‘‘multiplex condensing system’’, 

connected to most or all of the 

refrigeration units in a building). 

‘‘Remote condensing’’, however, can 

also refer to a configuration in which 

the unit cooler is connected to a 

dedicated (i.e., only serving that one 

unit) compressor and condenser that are 

located somewhere away from the unit 

cooler. This configuration is rare for 

commercial refrigeration equipment, but 

comprises a large proportion of walk-in 

refrigeration system applications. 

To avoid confusion over the different 

configurations for walk-ins and 

commercial refrigeration equipment that 

can be classified as ‘‘remote 

condensing’’, DOE is not proposing to 

classify walk-in refrigeration systems as 

‘‘remote condensing’’ and ‘‘selfcontained’’. Also, DOE does not agree 

that the compressor and condenser parts 

should not be covered under the walkin coolers and freezers rulemaking. 

Instead, DOE is proposing to include 

dedicated condensing units in the rule, 

even if remotely located, because these 

units could be viewed as part of the 

walk-in as long as they are connected 

only to that particular walk-in and not 

to other refrigeration equipment. For 

systems where the walk-in is connected 

to a multiplex condensing system that 

runs multiple pieces of equipment, the 

compressor and condenser would not be 

covered because they are not 

exclusively part of the walk-in. 

In consideration of the above, DOE 

proposes to create two classes of 

refrigeration systems: dedicated 

condensing and multiplex condensing. 

DOE believes that dedicated remote 

condensing units represent a substantial 

opportunity for energy savings in a 

regulation for walk-in components 

because the configuration of a dedicated 

remote condensing unit is widespread 

in several market segments, such as 

restaurants. Manufacturers can optimize 

the dedicated remote condensing unit 

with the unit cooler to take advantage of 

certain conditions, such as low ambient 

outdoor temperatures. 

DOE does not propose to create 

separate classes for dedicated packaged 

systems (where the unit cooler and 

condensing unit are integrated into a 

single piece of equipment) and 

dedicated split systems (with separate 

unit cooler and condensing unit 

sections). Packaged systems are 

potentially more efficient than split 

systems because they do not experience 

as much energy loss in the refrigerant 

lines. However, because packaged 

systems comprise a small share of the 

refrigeration market, DOE currently 

believes that little additional energy 

savings could be achieved by 

considering them as a separate class. 

Accordingly, DOE is not proposing to 

consider the creation of a separate 

packaged systems class. 

DOE also notes that its proposed 

standards for dedicated condensing 

systems are based on an analysis of split 

systems. DOE requests comment on its 

proposal not to consider dedicated 

packaged systems and dedicated split 

systems as separate classes and whether 

this proposal would unfairly 

disadvantage any manufacturers. 

Operating Temperature 

The second physical characteristic 

that DOE proposes as a basis for 

dividing refrigeration systems into 

equipment classes is the operating 

temperature. EPCA divides walk-in 

equipment into coolers (above 32 °F) 

and freezers (at or below 32 °F) (42 

U.S.C. 6311(20)) Using this distinction, 

DOE is proposing to categorize 

refrigeration systems as low or medium 

temperature systems based on the 

temperature profiles of their unit 

coolers. The medium (M) and low (L) 

temperature units are differentiated by 

their operating temperatures, which are 

greater than 32 °F (for coolers) and less 

than or equal to 32 °F (for freezers). In 

response to DOE’s discussion of these 

classes in the preliminary analysis, 

Ingersoll Rand suggested that any walkin with defrost be rated as a freezer 

regardless of the operating temperature. 

(Ingersoll Rand, No. 0053.1 at p. 1) DOE 

has not adopted these suggestions 

because doing so would conflict with 

the statutory distinction created by 

Congress that relies on operating 

temperature to distinguish between 

walk-in coolers and freezers. See 42 

U.S.C. 6311(2) (treating walk-ins as 

separate equipment based on whether 

they are coolers or freezers). 

Furthermore, applying the rating 

conditions for low temperature 

refrigeration systems is unlikely to 

enable a tester to accurately measure the 

efficiency of a medium temperature 

refrigeration system. Requiring a 

refrigeration system with defrost to be 

rated at the low temperature rating 

conditions even if it is designed to 

operate closer to the medium 

temperature rating conditions could 

lead to inaccurate equipment ratings for 

such equipment. In certain cases, 

applying temperature ratings in this 

manner may not permit this type of 

equipment to be rated at low 

temperature rating conditions if it is not 

designed to operate at those 

conditions.14

Location of the Walk-In 

The third physical characteristic DOE 

considered is the location of the 

condensing unit (i.e., indoor or 

outdoor), which also affects the energy 

consumption of dedicated condensing 

systems. Indoor refrigeration systems 

generally operate at fixed ambient 

temperatures, while outdoor 

refrigeration systems experience varying 

temperatures through the year. This 

change in temperature affects the 

performance of the refrigeration system 

by requiring it to operate more during 


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warmer conditions and less during 

colder ones. Accordingly, the test 

procedure has one ambient rating 

condition for indoor systems and three 

ambient rating temperatures for outdoor 

systems. 

In the preliminary analysis, DOE 

considered creating separate classes for 

refrigeration systems with indoor (I) and 

outdoor (O) condensing units because of 

their different energy consumption 

characteristics. Outdoor condensing 

units can also implement a wide variety 

of design options to run more efficiently 

at low ambient temperatures. (In 

contrast, DOE did not consider indoor 

and outdoor envelope components as 

belonging to separate classes partly 

because of the absence of available 

options for improving efficiency based 

on the ambient temperature. See section 

IV.A.3.a for details.) Following the 

preliminary analysis, DOE did not 

receive any comments regarding the 

indoor and outdoor condensing unit 

classes, and therefore proposes the same 

differentiation in this NOPR. 

Refrigeration Equipment Size 

In the preliminary analysis, DOE did 

not consider different equipment classes 

based on refrigeration equipment size. 

Heatcraft suggested adding subcategories to the proposed equipment 

classes, stating that the size of 

refrigeration systems varies with 

envelope size. (Heatcraft, No. 0069.1 at 

p. 1) Manitowoc commented that small 

sized equipment would struggle to meet 

minimum standards if DOE based the 

metric on a larger size, largely due to the 

efficiency difference of each system 

size. (Manitowoc, Public Meeting 

Transcript, No. 0044 at p. 118) 

DOE is not proposing to base 

refrigeration system classes on envelope 

size because it is taking a componentlevel approach that sets standards for 

the refrigeration system independent of 

the envelope. In reaching this tentative 

decision, DOE examined the ability of 

various sized equipment to meet a 

proposed standard. For the NOPR 

analysis, DOE analyzed a wider range of 

equipment sizes than it did for the 

preliminary analysis, as described later 

in section IV.C.1.b. As a result of this 

expanded analysis, DOE observed that 

small sized equipment may have 

difficulty meeting an efficiency standard 

that is based on an analysis of large 

equipment, as Manitowoc noted. DOE 

found that this result was primarily due 

to a lack of availability of the more 

efficient compressor types (e.g., scroll 

compressors) at lower capacities. 

Additionally, certain design options, 

mainly controls, generally have a fixed 

cost, but their benefit decreases with 

lower capacities, so they are less costeffective for lower-capacity equipment. 

Therefore, DOE proposes one equipment 

class for high-capacity equipment and 

another for low-capacity equipment 

within the dedicated condensing 

category (because the compressor is 

covered only for DC systems). DOE has 

tentatively chosen 9,000 Btu/h as the 

capacity threshold for small- and largecapacity equipment based on the 

efficiency characteristics of available 

compressors, among other factors. See 

chapter 3 for details. DOE requests 

comment on the capacity threshold 

between the two capacity classes for 

dedicated condensing systems. 

Proposed Classes 

Using the proposed combinations of 

condensing unit types, operating 

temperatures, location, and size, ten 

equipment classes are possible for walkin cooler or freezer refrigeration 

systems. DOE believes that these ten 

classes accurately represent the 

refrigeration units used in the walk-in 

market today. 

Table IV–2 lists the equipment classes 

for refrigeration equipment that DOE is 

proposing in this NOPR. The column 

entitled ‘‘Class’’ lists the codes that will 

be used to abbreviate each equipment 

class, and will be used throughout the 

NOPR. 

TABLE IV–2—EQUIPMENT CLASSES FOR REFRIGERATION EQUIPMENT

Condensing type Operating temperature Condenser location 

Refrigeration capacity 

(Btu/h) 

Class 

Dedicated .................................... Medium ....................................... Indoor ......................................... < 9,000 DC.M.I, < 9,000 

≥ 9,000 DC.M.I, ≥ 9,000 

Outdoor ...................................... < 9,000 DC.M.O, < 9,000 

≥ 9,000 DC.M.O, ≥ 9,000 

Low ............................................. Indoor ......................................... < 9,000 DC.L.I, < 9,000 

≥ 9,000 DC.L.I, ≥ 9,000 

Outdoor ...................................... < 9,000 DC.L.O, < 9,000 

≥ 9,000 DC.L.O, ≥ 9,000 

Multiplex ...................................... Medium ....................................... ..................................................... .............................. MC.M 

Low ............................................. ..................................................... .............................. MC.L 

4. Technology Assessment 

In a technology assessment, DOE 

identifies technologies and designs that 

could be used to improve the energy 

efficiency or performance of covered 

equipment. For the preliminary 

analysis, DOE conducted a technology 

assessment to identify all technologies 

and designs that could be used to 

improve the energy efficiency of walkins or walk-in components. DOE 

described these technologies in chapter 

3 of the preliminary TSD. 

DOE received several comments in 

response to its preliminary list of 

technology options. NEEA and NPCC 

recommended that DOE include 

modulating condenser fan controls in its 

analysis because there are significant 

potential energy savings from this 

technology. (NEEA and NPCC, No. 

0059.1 at p. 8) Emerson agreed and 

noted that higher-efficiency 

compressors often require modulating 

fan controls to realize the full benefit of 

the higher-efficiency compressors. 

(Emerson, Public Meeting Transcript, 

No. 0045 at p. 90) The Joint Utilities 

pointed out that DOE did not include 

variable speed controls for condenser 

fans. (Joint Utilities, No. 0061.1 at p.10) 

In addition, NEEA and NPCC 

recommended that DOE include liquid 

suction heat exchangers in its analysis 

because there are significant potential 

energy savings from this technology. 

(NEEA and NPCC, No. 0059.1 at p. 8) 

In response to the recommendation 

that DOE consider condenser fan 

controls, DOE has added condenser fan 

controls as a design option because it 

determined through further analysis that 

they could be an effective means of 

saving energy. As to NEEA and NPCC’s 

recommendation that DOE include 

liquid suction heat exchangers, DOE 

also considered liquid suction heat 

exchangers in the technology 


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assessment because this technology 

could potentially be used to save 

energy. However, DOE screened this 

option from further consideration 

because further examination indicated 

that it would be unlikely to yield 

significant energy savings under the 

rating conditions used in setting 

standards for walk-in equipment. See 

chapters 3, 4, and 5 of the TSD for more 

details on the technologies considered 

in the analysis. 

B. Screening Analysis 

DOE uses four screening criteria to 

determine which design options are 

suitable for further consideration in a 

standards rulemaking. Namely, design 

options will be removed from 

consideration if they (1) are not 

technologically feasible; (2) are not 

practicable to manufacture, install, or 

service; (3) have adverse impacts on 

product utility or product availability; 

or (4) have adverse impacts on health or 

safety. 10 CFR 430, subpart C, appendix 

A, sections (4)(a)(4) and (5)(b).) 

1. Technologies That Do Not Affect 

Rated Performance 

In the preliminary analysis TSD, DOE 

proposed to screen out the following 

technologies because they do not 

improve energy efficiency: nonpenetrative internal racks and shelving, 

air and water infiltration sensors, 

humidity sensors, and heat flux sensors. 

For the reasons stated in the test 

procedure final rule, DOE’s test 

procedure establishes metrics to test the 

energy consumption or energy use of 

walk-in components and does not 

include heat load caused by infiltration. 

See 76 FR at 21594–21595. As a result, 

DOE included additional infiltrationrelated technologies in the following list 

of technologies that do not improve 

rated performance: 

• Internal racks and shelving that are 

non-penetrative; 

• Air and water infiltration sensors; 

• Extruded polystyrene insulation; 

• Humidity sensors; 

• Heat flux sensors; 

• Door gasketing improvements and 

panel interface systems; 

• Automatic door opening and 

closing systems; 

• Air curtains; 

• Strip curtains; 

• Vestibule entryways; and 

• Insulation with improved moisture 

resistance. 

In the preliminary analysis, DOE 

listed hot gas defrost as a technology 

that does not improve rated 

performance of refrigeration equipment. 

In response, the Joint Utilities stated 

that DOE should include hot gas defrost. 

(Joint Utilities, Public Meeting 

Transcript, No. 0045 at p. 25; Joint 

Utilities, No. 0061.1 at pp. 3, 7, and 10). 

DOE has included hot gas defrost as a 

design option for multiplex condensing 

systems, but not for dedicated 

condensing systems due to its lack of 

effectiveness in improving efficiency. 

Specifically, for multiplex condensing 

systems, the hot gas defrost system 

utilizes hot gas generated by the 

compressor rack. Because at least one of 

the compressors in the rack is likely to 

be running (because the rack also has to 

operate with other refrigeration units) 

no new energy is consumed to generate 

the hot gas. In contrast, for dedicated 

systems, the condensing unit typically 

turns off during an electric defrost cycle. 

Running the compressor to generate hot 

gas at a time when it would normally be 

off results in energy use that outweighs 

the energy saved by using hot gas 

defrost instead of electric defrost. See 

chapters 3 and 5 of the TSD for details. 

Also as part of the preliminary 

analysis, DOE analyzed the envelope 

and the refrigeration system separately 

and did not consider design options that 

depend on the interaction between the 

envelope and the refrigeration system. 

SCE suggested that DOE consider 

control options that depend on the 

interaction between envelope 

components and the refrigeration 

system, such as a control that turns off 

the evaporator fan when the door is 

opened. SCE suggested that DOE 

evaluate such technologies by 

establishing a typical, nominal savings 

value for use in energy consumption 

equations. (SCE, Public Meeting 

Transcript, No. 0045 at p. 25) Similarly, 

NEEA and NPCC stated that such 

technological controls have not been 

included in the design options. (NEEA 

and NPCC, No. 0059.1 at p. 7) 

A nominal savings value, as suggested 

by SCE, would be highly dependent on 

many assumptions about the application 

of the walk-in and the pairing of the 

refrigeration system with the walk-in. 

As a result, DOE does not believe that 

it would be reasonable to apply this 

shared value to all refrigeration system 

or door manufacturers because of the 

wide variety of equipment produced by 

these entities for walk-in applications. 

Moreover, DOE’s proposed component 

level approach eliminates the need to 

consider design options whose efficacy 

depends on the interaction between 

different components. 

DOE also did not consider design 

options whose benefits would not be 

captured by the test procedure, such as 

economizer cooling. Economizer cooling 

consists of directly venting outside air 

into the interior of the walk-in when the 

outside air is as cold as or colder than 

the interior of the walk-in. This 

technique relieves the load on the 

refrigeration system when a pull-down 

load (i.e., a load due to items brought 

into the walk-in at a higher temperature 

than the operating temperature and 

must then be cooled to the operating 

temperature) is necessary. However, the 

test procedure does not include a 

method for accounting for economizer 

cooling, as it does not specify 

conditions for air that would be vented 

into the walk-in, nor does it provide a 

method for measuring the energy use of 

the economizer. Therefore, any benefits 

from including an economizer on a 

WICF would not be captured by the test 

procedure. 

2. Screened-Out Technologies 

a. Panels and Doors 

In the preliminary analysis, DOE 

screened out the following technologies 

for envelopes: revolving doors, energy 

storage systems, fiber optic natural light, 

non-electric anti-sweat systems, and 

automatic insulation deployment 

systems. DOE did not receive comments 

regarding any of the screened-out 

technologies, and will continue to 

exclude them from this rulemaking. 

DOE has also screened out additional 

technologies as part of its proposal to 

regulate the components of the envelope 

separately (i.e., display doors, nondisplay doors, and panels.) See chapter 

4 of the TSD for more details on the 

screened-out technologies. 

b. Refrigeration 

In the preliminary analysis, DOE 

screened out the following technologies 

for refrigeration systems: Higherefficiency evaporator fan motors, 

improved evaporator coil, three-phase 

motors, and economizer cooling. In 

response to DOE’s request for comment 

on the screening analysis, American 

Panel, AHRI and CrownTonka agreed 

with this approach to screen out these 

technologies. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 98; 

AHRI. Public Meeting Transcript, No. 

0045 at p. 99; CrownTonka, No. 0057.1 

at p. 1) Emerson, however, disagreed 

with DOE’s decision to screen out 

economizer cooling because there are 

potential energy savings under certain 

circumstances. (Emerson, Public 

Meeting Transcript, No. 0045 at p. 100) 

Also, Heatcraft disagreed with the 

exclusion of phase motor technology 

because three-phase motors are the 

dominant motor type in the larger walkin envelopes that are a part of this 

rulemaking. (Heatcraft No. 0069.1 at p. 

2) Manitowoc remarked that there are 


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other ways to achieve an effective 

economizer cooling cycle and 

encouraged DOE to investigate other 

options to improve cycle efficiency, but 

did not provide any specific 

recommendations. (Manitowoc, Public 

Meeting Transcript, No. 0045 at p. 92) 

DOE continues to screen out threephase motor technology. The use of 

three-phase motor technology generally 

provides higher energy savings as 

compared to single-phase motors. 

Three-phase power is commonly used to 

power large motors and heavy electrical 

loads; however, it is not available for all 

businesses, particularly small business 

consumers of walk-ins. DOE did not 

consider three-phase motor technology 

as a design option based on utility to the 

consumer, one of the four screening 

criteria. In addition, use of three-phase 

motor technology may also be 

impracticable to install and service 

given the lack of three-phase power for 

some businesses. DOE did find that, as 

Heatcraft noted, very large refrigeration 

systems typically use three-phase 

power, and notes that manufacturers 

may use three-phase motors to improve 

the efficiency ratings of their equipment 

as the benefit would likely be captured 

by the test procedure. However, DOE 

continued to screen three-phase motor 

technology from its analysis for the 

reasons discussed above. 

DOE also did not consider economizer 

cooling in its analysis. Although there 

are potential energy savings under 

certain circumstances, as Emerson 

mentioned, these energy savings are not 

captured by the test procedure, as 

discussed in section IV.B.1. 

Regarding Manitowoc’s remark about 

considering other options to improve 

cycle efficiency, DOE did not identify 

any options to improve cycle efficiency 

beyond what was already considered. 

DOE requests specific recommendations 

on how to improve cycle efficiency. 

3. Screened-In Technologies 

Based on DOE’s decision to regulate 

walk-ins on a component level, DOE 

will consider separate technologies for 

each covered walk-in component (i.e. 

panels, display doors, non-display 

doors, and refrigeration systems). The 

remaining technologies that were not 

‘‘screened-out’’ are called the ‘‘screenedin’’ technologies and will be used to 

create design options for improving the 

efficiency of the walk-in components. 

The ‘‘screened-in’’ technologies for each 

covered component include: 

• Panels 

Æ Insulation thickness 

Æ Insulation material 

Æ Framing material 

• Display doors 

Æ High-efficiency lighting 

Æ Occupancy sensors 

Æ Improved glass system insulation 

performance 

Æ Anti-sweat heater controls 

• Non-display doors 

Æ Insulation thickness 

Æ Insulation material 

Æ Framing material 

Æ Improved window glass systems 

Æ Anti-sweat heat controls 

• Refrigeration Systems 

Æ Higher efficiency compressors 

Æ Improved condenser coil 

Æ Higher efficiency condenser fan 

motors 

Æ Improved condenser fan blades 

Æ Condenser fan control 

Æ Ambient sub-cooling 

Æ Improved evaporator fan blades 

Æ Evaporator fan control 

Æ Defrost controls 

Æ Hot gas defrost 

Æ Head pressure control 

C. Engineering Analysis 

The engineering analysis determines 

the manufacturing costs of achieving 

increased efficiency or decreased energy 

consumption. DOE has identified the 

following three methodologies to 

generate the manufacturing costs 

needed for the engineering analysis: (1) 

The design-option approach, which 

provides the incremental costs of adding 

design options to a baseline model to 

improve its efficiency; (2) the efficiencylevel approach, which provides the 

relative costs of achieving increases in 

energy efficiency levels without regard 

to the particular design options used to 

achieve such increases; and (3) the costassessment (or reverse engineering) 

approach, which provides ‘‘bottom-up’’ 

manufacturing cost assessments for 

achieving various levels of increased 

efficiency based on detailed data as to 

costs for parts and material, labor, 

shipping/packaging, and investment for 

models that operate at particular 

efficiency levels. 

DOE conducted the engineering 

analyses for this rulemaking using a 

combination of the design-option and 

cost-assessment approaches in 

analyzing the U-factor standards for 

panels, maximum energy use for nondisplay doors and display doors, and 

minimum AWEF for refrigeration 

systems. More specifically, DOE 

identified design options for analysis 

and then used the cost-assessment 

approach to determine the 

manufacturing costs and analytical 

modeling to determine the energy 

consumption at those levels. Additional 

details of the engineering analysis are in 

chapter 5 of the NOPR TSD. 

1. Representative Equipment 

a. Panels and Doors 

In presenting the preliminary 

analysis, DOE proposed three 

representative sizes for each envelope 

equipment class: Small, medium, and 

large. American Panel agreed with the 

sizes that DOE proposed. (American 

Panel, No. 0048.1 at p. 4) CrownTonka 

recommended that the equipment 

classes for envelopes be divided into 

only two sections, small and medium, 

because EPCA covers only walk-ins of 

less than 3,000 square feet, which 

excludes sizes that are typically 

considered ‘‘large.’’ (CrownTonka, 

Public Meeting Transcript, No. 0045 at 

p.111) Heatcraft agreed that the sizes 

chosen are small, as all the sizes 

considered must be less than 3,000 

square feet, and they recommended that 

the distribution of envelope sizes 

include larger sizes approaching the 

3,000 square foot limit, the maximum 

size limit defined in the statute. 

Heatcraft also stated that the selected 

envelope sizes will have an effect on the 

engineering analysis because certain 

technologies are utilized at different 

sizes. (Heatcraft, Public Meeting 

Transcript, No. 0045 at p. 111, No. 

0058.1 at p. 4) American Panel 

suggested that DOE use three sizes and 

investigate using an extra large size. 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 114) 

Manitowoc asserted that DOE did not 

include a large enough range of sizes 

and should consider smaller sized walkins to correctly represent the energy 

consumption of a given unit. 

Additionally, Manitowoc noted that as 

the walk-in’s size increases, there are 

different base levels of performance and 

that if DOE sets the minimum efficiency 

based on a larger size, manufacturers 

will not be able to make small-sized 

equipment meeting the standards. 

(Manitowoc, Public Meeting Transcript, 

No. 0045 at pp. 116 and 118) Hill 

Phoenix recommended that the 

envelope sizes be determined by surface 

area or volume. (Hill Phoenix, No. 

0066.1 at p. 2) NEEA and NPCC 

suggested that DOE establish a standard 

based on the square feet of panels 

shipped each year and use the square 

footage to determine the energy 

consumption of a complete functioning 

envelope. (NEEA and NPCC, No. 0059.1 

at p. 8) 

DOE notes that its proposal rests on 

a component-based approach and does 

not include infiltration losses. As a 

result, the size of the walk-in envelope 

does not affect the energy consumption 

of the components. In regard to 

American Panel’s and Heatcraft’s 


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comments about large sized walk-ins, 

DOE analyzed a large panel size that it 

considered to represent the large panels 

found in the industry. DOE anticipated 

the possibility raised by Manitowoc that 

small panels might not be able to meet 

a standard based on the large panel size 

previously under consideration and is 

now considering the adoption of an 

approach that considers small, medium, 

and large sizes. As Hill Phoenix 

suggested, DOE determined the size of 

the panel based on the panel’s surface 

area. Also, similar to NEEA and NPCC’s 

suggestion, DOE is proposing a standard 

for walk-in panels based on the panel’s 

surface area. 

Panels 

As explained previously, the 

engineering analysis for walk-in panels 

uses three different panel sizes to 

represent the variations within each 

class. DOE determined the sizes based 

on market research and the impact on 

the test metric U-factor. Table IV–3 

shows each equipment class and the 

representative sizes associated with that 

class. DOE requests comment on the 

representative sizes used in the 

proposed analysis. 

TABLE IV–3—SIZES ANALYZED: PANELS

Equipment class Size code 

Representative 

height 

(feet) 

Representative 

width 

(feet) 

SP.M ...................................................................... SML ....................................................................... 8 1 .5 

MED ....................................................................... 8 4 

LRG ....................................................................... 9 5 .5 

SP.L ....................................................................... SML ....................................................................... 8 1 .5 

MED ....................................................................... 8 4 

LRG ....................................................................... 9 5 .5 

FP.L ....................................................................... SML ....................................................................... 8 2 

MED ....................................................................... 8 4 

LRG ....................................................................... 9 6 

Doors 

Similar to the panel analysis, the 

engineering analyses for walk-in display 

and non-display doors both use three 

different sizes to represent the 

differences in doors within each size 

class DOE examined. The door sizes 

were determined using market research. 

Details are provided in Table IV–4 for 

non-display doors and Table IV–5 for 

display doors. 

TABLE IV–4—SIZES ANALYZED: NON-DISPLAY DOORS

Equipment class Size code 

Representative 

height 

(feet) 

Representative 

width 

(feet) 

PD.M ..................................................................... SML ...................................................................... 6 .5 2 .5 

MED ...................................................................... 7 3 

LRG ...................................................................... 7 .5 4 

PD.L ...................................................................... SML ...................................................................... 6 .5 2 .5 

MED ...................................................................... 7 3 

LRG ...................................................................... 7 .5 4 

FD.M ..................................................................... SML ...................................................................... 8 5 

MED ...................................................................... 9 7 

LRG ...................................................................... 12 7 

FD.L ...................................................................... SML ...................................................................... 8 5 

MED ...................................................................... 9 7 

LRG ...................................................................... 12 7 

TABLE IV–5—SIZES ANALYZED: DISPLAY DOORS

Equipment class Size code 

Representative 

height 

(feet) 

Representative 

width 

(feet) 

DD.M ..................................................................... SML ...................................................................... 5 .25 2 .25 

MED ...................................................................... 6 .25 2 .5 

LRG ...................................................................... 7 3 

DD.L ...................................................................... SML ...................................................................... 5 .25 2 .25 

MED ...................................................................... 6 .25 2 .5 

LRG ...................................................................... 7 3 

b. Refrigeration 

In the engineering analysis for walkin refrigeration systems, DOE used a 

range of capacities as analysis points for 

each equipment class. The name of each 

equipment class along with the naming 

convention was discussed in section 

IV.A.3.b. In addition to the multiple 

analysis points, scroll, hermetic, and 

semi-hermetic compressors were also 

investigated because different 

compressor types have different 


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15Scroll compressors are compressors that 

operate using two interlocking, rotating scrolls that 

compress the refrigerant. Hermetic and semihermetic compressors are piston-based compressors 

and the key difference between the two is that 

hermetic compressors are sealed and hence more 

difficult to repair, resulting in higher replacement 

costs, while semi-hermetic compressors can be 

repaired relatively easily. 

efficiencies and costs.15 Due to the wide 

range of capacities considered for each 

condenser type, and the availability of 

compressors at certain capacities, 

compressors closely matching the 

condenser capacities were examined in 

terms of their performance at varying 

operating temperatures. 

Table IV–6 identifies, for each class of 

refrigeration system, the sizes of the 

equipment DOE analyzed in the 

engineering analysis. Chapter 5 of the 

NOPR TSD includes additional details 

on the representative equipment classes 

used in the analysis. 

TABLE IV–6—SIZES ANALYZED: REFRIGERATION SYSTEM

Equipment class Sizes analyzed 

(Btu/h) Compressors analyzed 

DC.M.I, < 9,000 ................................................................................................................. 6,000 Hermetic, Semi-hermetic. 

DC.M.I, ≥ 9,000 ................................................................................................................. 18,000 Hermetic, Semi-hermetic, Scroll. 

54,000 Semi-Hermetic, Scroll. 

96,000 Semi-Hermetic, Scroll. 

DC.M.O, < 9,000 ................................................................................................................ 6,000 Hermetic, Semi-hermetic. 

DC.M.O, ≥ 9,000 ................................................................................................................ 18,000 Hermetic, Semi-hermetic, Scroll. 

54,000 Semi-Hermetic, Scroll. 

96,000 Semi-Hermetic, Scroll. 

DC.L.I, < 9,000 .................................................................................................................. 6,000 Hermetic, Semi-hermetic, Scroll. 

DC.L.I, ≥ 9,000 .................................................................................................................. 9,000 Hermetic, Semi-hermetic, Scroll. 

54,000 Semi-Hermetic, Scroll. 

DC.L.O, < 9,000 ................................................................................................................. 6,000 Hermetic, Semi-hermetic, Scroll. 

DC.L.O, ≥ 9,000 ................................................................................................................. 9,000 Hermetic, Semi-hermetic, Scroll. 

54,000 Semi-Hermetic, Scroll. 

72,000 Semi-Hermetic. 

MC.M ................................................................................................................................. 4,000 

9,000 

24,000 

MC.L .................................................................................................................................. 4,000 

9,000 

18,000 

40,000 

2. Energy Modeling Methodology 

In the preliminary analysis, DOE 

proposed using an energy consumption 

model to estimate separately the energy 

consumption rating of entire envelopes 

and entire refrigeration systems at 

various performance levels using a 

design-option approach. DOE developed 

the model as a Microsoft Excel 

spreadsheet. The spreadsheet calculated 

the cumulative effect on the energy 

consumption of adding options above 

the baseline. 

DOE continues to use a spreadsheetbased model, but is now modeling 

panels, display doors, non-display 

doors, and refrigeration systems 

separately because these components 

are tested separately. As mentioned 

above, the purpose of the engineering 

analysis is to determine the 

manufacturing costs of achieving 

increased efficiency or decreased energy 

consumption. DOE assumes that 

manufacturers will only incur costs to 

achieve efficiency gains or energy 

reductions that are accounted for in 

their certified equipment rating. 

Therefore, the energy models estimate 

the performance rating that the 

manufacturer would obtain by testing 

their equipment using the DOE test 

procedure because manufacturers are 

required to rate the components using 

the test procedure. The models estimate 

the energy ratings of baseline equipment 

and levels of performance above the 

baseline associated with specific design 

options that are added cumulatively to 

the baseline equipment. The model does 

not account for interactions between 

refrigeration systems and envelope 

components, nor does it address how a 

design option for one component may 

affect the energy consumption of other 

components, because such effects are 

not accounted for in the test procedure. 

Component performance results are 

found in appendix 5A of the TSD. DOE 

requests comment on the performance 

data found in appendix 5A of the TSD 

and requests data about the performance 

of panels, display doors, or non-display 

doors and their design options. 

a. Refrigeration 

The refrigeration energy model 

calculates the annual energy 

consumption and the AWEF of walk-in 

refrigeration systems at various 

performance levels using a design 

option approach. AWEF is the ratio of 

the total heat removed, in Btus, from a 

walk-in envelope during a one-year 

period of use (not including the heat 

generated by operation of the 

refrigeration system) to the total energy 

input of refrigeration systems, in watthours, during the same period. DOE 

proposes to base its standards for the 

refrigeration system using the AWEF 

metric and seeks comment on this 

approach. 

This model was used to analyze 

specific examples of equipment in each 

refrigeration system equipment class. 

For a given class, the analysis consists 

of calculating the annual energy 

consumption and the AWEF for the 

baseline and several levels of 

performance above the baseline. See 

chapter 5 of the TSD for further details 

about the analytical models used in the 

engineering analysis. 

For the preliminary analysis, DOE 

partially relied on refrigeration catalog 

information to obtain equipment 

specifications for its energy model. 

Manitowoc and the Joint Utilities 

believed that catalog information was 

not the best source from an analytical 

standpoint. Manitowoc observed that 

catalog information is provided mainly 

for sizing equipment and not for 

representing equipment performance, 

while the Joint Utilities pointed out that 


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the rating methodology that produced 

the data in the catalogs could be 

different from the rating methodology 

for walk-ins, which could make the data 

inappropriate for analyzing walk-ins. 

(Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 31; Joint Utilities, No. 

0061.1 at p. 3) 

In recognition of these comments, 

DOE conducted further research into 

refrigeration system performance and 

has improved the analysis for the NOPR 

in several ways. First, the energy model 

now calculates system performance 

based on a whole-system approach 

using thermodynamic principles. The 

model determines the refrigerant 

properties (pressure, temperature, etc.) 

at each point in the system and these 

properties, rather than catalog 

specifications, are used to calculate 

refrigeration capacity. Second, for any 

catalog information based on specific 

rating conditions, DOE ensured the 

rating conditions were consistent with 

those for walk-in refrigeration systems, 

or adjusted the specifications 

accordingly. Third, while it continued 

to rely on catalog data directly for some 

equipment specifications (e.g., typical 

number of fans and fan horsepower for 

units of the sizes analyzed), DOE also 

surveyed catalogs from various 

manufacturers to determine the most 

representative specifications for a 

particular type and size of equipment. 

See chapter 5 for more details on the 

refrigeration system energy model and 

other enhancements made to its 

analysis. 

The energy consumption calculations 

in the engineering analysis are based on 

calculations in AHRI 1250–2009, the 

industry test procedure incorporated by 

reference in the walk-in test procedure. 

76 FR at 33631. These calculations 

involve the refrigeration system running 

at a high load for one-third of the time 

and a low load for two-thirds of the 

time. American Panel noted that the 

load profile for restaurants would 

generally be reversed (i.e., the 

refrigeration system is sized for running 

at a high load two-thirds of the time and 

a low load one-third of the time) and 

requested DOE to adjust the load 

assumptions based on the walk-in 

application. (American Panel, No. 

0048.1 at p. 8) 

DOE’s assumption in the engineering 

analysis about the refrigeration load 

profile was made for purposes of 

comparing the performance of different 

types of refrigeration equipment that 

have varying features. Furthermore, the 

analysis attempts to assess the impacts 

of technologies manufacturers might use 

to improve the efficiencies of their 

equipment, including impacts on the 

efficiency ratings of the equipment. DOE 

will base any standards it adopts on the 

use of some or all of these technologies, 

and the DOE test procedure would serve 

as the basis for rating equipment and 

determining compliance. Therefore, the 

test procedure calculations are used in 

the analysis to determine the efficiency 

ratings of equipment utilizing the 

various technologies on which DOE 

might base the standards. 

However, DOE does not treat the load 

profile assumptions used in the 

engineering analysis as equivalent to the 

actual duty cycle of every class or 

application of refrigeration systems. 

Rather, where warranted, DOE evaluates 

other duty cycle assumptions in its 

energy use analysis, which examines the 

actual energy consumption of the 

refrigeration system under a variety of 

operating conditions and applications. 

In the energy use analysis, DOE has 

adjusted its assumptions for actual duty 

cycles based in part on American 

Panel’s recommendation. See section 

IV.E.1 and chapter 7 of the TSD for 

details. 

In the preliminary analysis, DOE 

analyzed the result of adding design 

options cumulatively to the baseline. 

DOE observed that some design options 

(e.g., larger condenser coil) increased 

the efficiency of the refrigeration system 

while also increasing its capacity. To 

distinguish between these effects, DOE 

created a ‘‘normalized energy 

consumption’’ metric in the preliminary 

analysis which represented the energy 

consumption per unit capacity. DOE 

expected that the normalized energy 

consumption metric would generally be 

analogous to an efficiency metric. For 

example, for two units of the same 

capacity, the unit with lower 

normalized energy consumption would 

be more efficient because it would use 

less energy for the same heat removal 

capability. 

In a comment on the preliminary 

analysis, American Panel stated that it 

was not beneficial for the capacity of a 

unit to increase because the refrigeration 

system must balance the heat load to 

control temperature and humidity. 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 175) After 

interviewing manufacturers and 

examining refrigeration catalogs, DOE 

observed that manufacturers typically 

offer refrigeration systems in specific, 

discrete capacities while providing 

consumers with options for improving 

system efficiency. DOE reasoned that 

manufacturers would likely design their 

systems for a certain set of capacities 

regardless of the efficiency options 

available and, consequently, 

implementing efficiency options on a 

system would be unlikely to change the 

capacity of the system because the 

manufacturer would prefer to market 

the system at the established capacity. 

Therefore, DOE agrees with American 

Panel’s assessment and has 

implemented its suggestion into the 

NOPR analysis. 

DOE notes that it analyzed six classes 

of refrigeration systems at various 

capacity points, as explained in section 

IV.C.1.b. When a design option is added 

to the baseline, it does not change the 

capacity of the unit; instead, other 

aspects of the system are adjusted to 

maintain the capacity at the specified 

point. See chapter 5 of the TSD for 

details. 

In the preliminary analysis, DOE 

considered the effects of adding design 

options to the baseline. Some interested 

parties commented on the interactive 

effects of design options. Thermocore 

stated that there are substantial 

differences in performances based on 

the integrated system as opposed to 

considering options separately. 

(Thermocore, Public Meeting 

Transcript, No. 0045 at p. 86) Emerson 

stated that DOE must account for how 

the technologies are combined because 

the effects will vary depending on what 

is already included in the system. 

(Emerson, Public Meeting Transcript, 

No. 0045 at p. 93) AHRI agreed that 

efficiency gains due to combinations of 

certain design options are not 

necessarily additive and noted that 

assessing the aggregate benefit from 

combined design options requires 

rigorous analysis and simulation of the 

total system. (AHRI, No. 0055.1 at p. 2) 

DOE recognizes that the interactive 

effects of design options must be 

considered because the efficacy of 

certain design options differs depending 

on whether they are analyzed separately 

or in conjunction with other design 

options. DOE has taken a system-based 

approach to the refrigeration system 

energy model that calculates the effect 

on the entire system of adding design 

options. Each efficiency level above the 

baseline consists of a design option 

added cumulatively and the interactive 

effects of each new design option on all 

previously added design options are 

considered. In formulating the costefficiency curves, DOE attempted to 

capture the most cost-effective design 

option at each efficiency level, given all 

previously added design options at that 

level. Manufacturers may use any 

combination of design options to meet 

the future energy conservation standard. 

See chapter 5 of the TSD for further 

discussion on the interactive effects of 

design options. 


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Some commenters disagreed with 

DOE’s refrigeration energy modeling 

approach. SCE recommended using 

DOE 2.2R (an expanded version of the 

building simulation program DOE 2.2) 

to directly model certain design options, 

such as modulating the fan speed for the 

on-cycle fan power for a unit cooler 

connected to a multiplex system. (SCE, 

Public Meeting Transcript, No. 0045 at 

p. 138) NEEA and NPCC also stated that 

the spreadsheet-based model does not 

adequately evaluate all of the design 

options and their combinations, and 

that DOE should consider using DOE 

2.2R for modeling instead. (NEEA and 

NPCC, No. 0059.1 at p. 9) 

DOE 2.2R is designed to simulate the 

operation of building refrigeration 

systems, such as those found in 

supermarkets, refrigerated warehouses, 

and industrial facilities. Although DOE 

2.2R is a powerful simulation tool that 

can aid in refrigeration system design, 

DOE believes it is inappropriate for the 

energy modeling that DOE is conducting 

as part of this rulemaking. This 

rulemaking is taking a component-level 

approach and determining the 

performance of each component (the 

panels, the doors, and the refrigeration 

system) separately, whereas DOE 2.2R 

models the interactions of components 

that comprise an entire building. Also, 

the component performance as modeled 

in the engineering analysis must be 

based on the operating conditions and 

calculations contained in the test 

procedure, which DOE believes is not 

consistent with the simulation 

methodology in DOE 2.2R. To address 

the concerns of SCE, NEEA and NPCC 

that a spreadsheet model would be 

inadequate for certain options or 

combinations of options, DOE has 

modified the spreadsheet model to more 

accurately account for combinations of 

design options and interactive effects of 

design options within a component. To 

address the Joint Utilities’ concerns 

with fan speed modulation, DOE 

included calculations for fan speed 

modulation that are consistent with the 

test procedure. 

Although DOE is not conducting the 

analysis using DOE 2.2R, DOE 

encourages interested parties to submit 

their own simulation results from DOE 

2.2R modeling and compare them to 

DOE’s engineering results. 

3. Cost Assessment Methodology 

a. Teardown Analysis 

To calculate the manufacturing costs 

of the different components of walk-in 

coolers and freezers, DOE disassembled 

baseline equipment. This process of 

disassembling systems to obtain 

information on their baseline 

components is referred to as a ‘‘physical 

teardown.’’ During the physical 

teardown, DOE characterized each 

component that makes up the 

disassembled equipment according to 

its weight, dimensions, material, 

quantity, and the manufacturing 

processes used to fabricate and assemble 

it. The information was used to compile 

a bill of materials (BOM) that 

incorporates all materials, components, 

and fasteners classified as either raw 

materials or purchased parts and 

assemblies. 

DOE also used a supplementary 

method, called a ‘‘virtual teardown,’’ 

which examines published 

manufacturer catalogs and 

supplementary component data to 

estimate the major physical differences 

between equipment that was physically 

disassembled and similar equipment 

that was not. For virtual teardowns, 

DOE gathered product data such as 

dimensions, weight, and design features 

from publicly-available information, 

such as manufacturer catalogs. 

The teardown analyses allowed DOE 

to identify the technologies that 

manufacturers typically incorporate into 

their equipment. The end result of each 

teardown is a structured BOM, which 

DOE developed for each of the physical 

and virtual teardowns. DOE then used 

the BOM from the teardown analyses as 

one of the inputs to the cost model to 

calculate the manufacturer production 

cost (MPC) for the product that was torn 

down. The MPCs derived from the 

physical and virtual teardowns were 

then used to develop an industry 

average MPC for each equipment class 

analyzed. See chapter 5 of the NOPR 

TSD for more details on the teardown 

analysis. 

For display doors and non-display 

freight doors, limited information was 

publicly available, particularly as to the 

assembly process and shipping. To 

compensate for this situation, DOE 

conducted physical teardowns for two 

representative units, one within each of 

these equipment classes. DOE 

supplemented the cost data it derived 

from these teardowns with information 

from manufacturer interviews. The cost 

models for panels and for non-display 

structural doors were created by using 

public catalog and brochure information 

posted on manufacturer Web sites and 

information gathered during 

manufacturer interviews. 

For the refrigeration system, DOE 

conducted physical teardowns of unit 

cooler and condensing unit samples to 

construct a BOM. The selected systems 

were considered representative of 

baseline, medium-capacity systems, and 

used to determine the base components 

and accurately estimate the materials, 

processes, and labor required to 

manufacture each individual 

component. From these teardowns, DOE 

gleaned important information and data 

not typically found in catalogs and 

brochures, such as heat exchanger and 

fan motor details, assembly parts and 

processes, and shipment packaging. 

Along with the physical teardowns, 

DOE performed several virtual 

teardowns of refrigeration units for the 

NOPR analysis. The complete set of 

teardowns helped DOE obtain the 

baseline average MPC for all equipment 

classes proposed. 

b. Cost Model 

The cost model is one of the 

analytical tools DOE used in 

constructing cost-efficiency curves. DOE 

derived the cost model from the 

teardown BOMs and the raw material 

and purchased parts databases. Cost 

model results are based on material 

prices, conversion processes used by 

manufacturers, labor rates, and 

overhead factors such as depreciation 

and utilities. For purchased parts, the 

cost model considers the purchasing 

volumes and adjusts prices accordingly. 

Original equipment manufacturers 

(OEMs), i.e., the manufacturers of WICF 

components, convert raw materials into 

parts for assembly, and also purchase 

parts that arrive as finished goods, 

ready-to-assemble. DOE bases most raw 

material prices on past manufacturer 

quotes that have been inflated to present 

day prices using Bureau of Labor 

Statistics (BLS) and American Metal 

Market (AMM) inflators. DOE inflates 

the costs of purchased parts similarly 

and also considers the purchasing 

volume—the higher the volume, the 

lower the price. Prices of all purchased 

parts and non-metal raw materials are 

based on the most current prices 

available, while raw metals are priced 

on the basis of a 5-year average to 

smooth out spikes. Chapter 5 of the 

NOPR TSD describes DOE’s cost model 

and definitions, assumptions, data 

sources, and estimates. 

For panels, non-display doors, and 

display doors DOE used a 

‘‘parameterized’’ computational cost 

model, which allows a user to 

manipulate the components parameters 

such as height and length by inputting 

different numerical values for these 

features to produce new cost estimates. 

This parameterized model, coupled 

with the design specifications chosen 

for each representative unit modeled in 

the engineering analysis, was used to 

develop fundamental MPC costs. The 

fundamental MPC costs were then 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55810 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

16The DOE Solid-State Lighting Research and 

Development Multi-Year Program Plan is a 

document that outlines DOE’s research goals and 

planned methodologies with respect to the 

advancement of solid-state lighting technologies in 

the United States. The complete document is 

available at: http://apps1.eere.energy.gov/buildings/ 

publications/pdfs/ssl/ssl_mypp2011_web.pdf. 

incorporated into the engineering 

analysis model where they were 

combined with additional costs 

associated with each design option. 

Costs for each design option were 

calculated based on discussions with 

panel, non-display, and display door 

manufacturers and pricing from 

commercially available sources. 

As previously mentioned in section 

IV.B.3, DOE is considering high 

efficiency lighting, specifically lightemitting diode (LED) lighting, as a 

design option to improve the efficiency 

of display doors. Forecasts of the LED 

lighting industry, including those 

performed by DOE, suggest that LED 

lighting is an emerging technology that 

will continue to experience significant 

price decreases in coming years. For this 

reason, in an effort to capture the 

anticipated cost reduction in LED 

fixtures in the analyses for this 

rulemaking, DOE incorporated price 

projections from its Solid State Lighting 

program into its MPC values. The price 

projections for LED lighting were 

developed using projections created for 

the DOE’s Solid State Lighting 

Program’s 2012 report, Energy Savings 

Potential of Solid-State Lighting in 

General Illumination Applications 2010 

to 2030 (‘‘the energy savings report’’). In 

the appendix of this report, price 

projections from 2010 to 2030 were 

provided in ($/klm) for LED lamps and 

LED luminaires. DOE analyzed the 

models used in the Solid State Lighting 

program work and determined that the 

LED luminaire projection would serve 

as a proxy for a cost projection to apply 

to LEDs on walk-in display doors. 

The price projections presented in the 

Solid State Lighting program’s energy 

savings report are based on the DOE’s 

2011 Solid State Lighting R&D MultiYear Program Plan (MYPP).16 The 

MYPP is developed based on input from 

manufacturers, researchers, and other 

industry experts. This input is collected 

by the DOE at annual roundtable 

meetings and conferences. The 

projections are based on expectations 

dependent on the continued investment 

into solid state lighting by the DOE. 

DOE incorporated the price projection 

trends from the energy savings report 

into its engineering analysis by using 

the data to develop a curve of 

decreasing LED prices normalized to a 

base year. That base year corresponded 

to the year when LED price data were 

collected for the NOPR analyses of this 

rulemaking from catalogs, manufacturer 

interviews, and other sources. DOE 

started with LED cost data specific to 

walk-in manufacturers and then applied 

the anticipated trend from the energy 

savings report to forecast the projected 

cost of LED fixtures at the time of 

required compliance with the proposed 

rule (2017). These 2017 cost figures 

were incorporated into the engineering 

analysis to calculate the MPC of display 

doors with LEDs as a design option. The 

LCC analysis (section IV.F) was carried 

out with the engineering numbers that 

account for the 2017 cost of LED 

luminaires. The reduction in costs of 

LED luminaires from 2018 to 2030 were 

taken into account in the NIA (section 

IV.G). The cost reductions were 

calculated for each year from 2018 and 

2030 and subtracted from the equipment 

costs in the NIA. 

During the preliminary analysis, DOE 

developed a cost model for the proposed 

representative sizes of walk-in 

envelopes. Panel manufacturers 

generally make panels with a 

combination of raw materials and 

purchased parts, and DOE estimated 

manufacturing process parameters, the 

required initial material quantity, scrap, 

and other factors to determine the value 

of each component. DOE then 

aggregated all parameters related to 

manufacture and assembly to determine 

facility requirements at various 

manufacturing scales and the final unit 

cost. 

To more accurately model walk-in 

costs, DOE used common factory 

parameters, which affect the cost of each 

unit produced (e.g., labor and 

fabrication rates). American Panel 

commented on some of the factors 

assumed in the cost model and the 

resulting values. In particular, in its 

view, approximately 1 million square 

feet of panels are manufactured per year 

per manufacturer, and most door 

manufacturers produce 1,800 doors per 

year. Accordingly, these numbers 

suggest a total walk-in production 

volume of well under DOE’s initial 

estimate of 30,000 per year per 

manufacturer. American Panel believed 

that overestimating the amount of 

panels manufactured per year would 

cause the small manufacturers to be at 

a disadvantage. (American Panel, Public 

Meeting Transcript, No. 0045 at 

p. 14–15; American Panel, No. 0048.1 at 

pp. 5–6) 

Assuming an average walk-in surface 

area of 500 ft2 (roughly corresponding to 

an 8-foot by 10-foot walk-in), American 

Panel’s estimate equates to 

approximately 2,000 walk-ins per year, 

per manufacturer—much lower than 

DOE’s estimate. DOE understands that 

its estimate may be more reasonable for 

a large manufacturer than a small one 

and agrees with American Panel that 

impacts on small manufacturers may be 

underestimated in an analysis that 

assumes a high production capacity. 

Thus, DOE has considered particular 

impacts on small manufacturers in the 

MIA by adjusting for their reduced 

production capacity as compared to 

larger manufacturers. See sections 

IV.I.3.c and V.B.2.d (Manufacturer 

Impact Analysis) and VI.B (Regulatory 

Flexibility Analysis, which specifically 

address the impact of the rule on small 

business manufacturers). 

Additionally, American Panel, citing 

its own experience, stated that other 

DOE cost estimates needed adjusting. 

Some examples include the following: 

• The cost of the tongue and groove 

design found on panels should be 

increased by a factor of 10.8. 

• The cost of the advanced door 

sweep should increase by a factor of 7.8. 

• The DOE cost per square foot of 

panel was too high and actual costs 

were closer to $0.25 per square foot. 

• The actual MSP for walk-in cooler 

envelopes was 70–112 percent lower 

than the DOE estimate. 

• The actual MSP for walk-in freezer 

envelopes was 24–42 percent lower than 

the DOE estimate. (American Panel, 

Public Meeting Transcript, No. 0045 at 

pp. 14–15; American Panel, No. 0048.1 

at pp. 5–6). 

DOE appreciates the efforts made by 

American Panel in preparing detailed 

comments and providing useful 

information about factory parameters, 

material costs, and the resulting 

manufacturing selling price for walk-in 

envelopes. Some of the differences can 

be explained based on the parameters 

used in the cost model, such as the 

material costs. DOE particularly 

appreciates American Panel’s comments 

related to the costs of certain designs 

and has taken these costs into 

consideration in its analysis by 

aggregating them with other data DOE 

has received through research and 

confidential manufacturer interviews. 

For instance, American Panel’s cost per 

square foot of panel was particularly 

useful in helping DOE estimate the costs 

of certain materials that make up the 

panel. 

DOE was not, however, able to use 

some of the cost data—for example, 

costs related to infiltration-reducing 

measures were not used because DOE is 

no longer considering infiltration in the 

analysis. Also, DOE has not calculated 

costs related to the assembly of the 

entire envelope—for instance, the MSP 


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of the envelope—as part of the 

engineering analysis because of the 

component-based approach DOE is 

proposing to use. Consequently, DOE is 

now using the cost model to determine 

the manufacturer production costs and 

manufacturer selling prices of the 

individual components covered by the 

standards. 

DOE estimated installation costs for 

the refrigeration systems and the 

envelope components separately as part 

of the life-cycle cost analysis. DOE has 

proposed new manufacturer cost 

estimates in chapter 5 of the TSD and 

seeks comment on the new parameters 

proposed for each component. 

c. Manufacturing Production Cost 

Once it finalized the cost estimates for 

all the components in each teardown 

unit, DOE totaled the cost of the 

materials, labor, and direct overhead 

used to manufacture the unit to 

calculate the manufacturer production 

cost of such equipment. The total cost 

of the equipment was broken down into 

two main costs: (1) The full 

manufacturer production cost, referred 

to as MPC; and (2) the non-production 

cost, which includes selling, general, 

and administration (SG&A) costs; the 

cost of research and development; and 

interest from borrowing for operations 

or capital expenditures. DOE estimated 

the MPC at each design level considered 

for each equipment class, from the 

baseline through max-tech. After 

incorporating all of the data into the 

cost model, DOE calculated the 

percentages attributable to each element 

of total production cost (i.e., materials, 

labor, depreciation, and overhead). 

These percentages were used to validate 

the data by comparing them to 

manufacturers’ actual financial data 

published in annual reports, along with 

feedback obtained from manufacturers 

during interviews. DOE uses these 

production cost percentages in the MIA 

(see section IV.I). 

In the preliminary analysis, DOE 

developed both an envelope cost and a 

refrigeration system cost for each 

equipment class and size using a 

manufacturing cost model. See chapter 

5 of the preliminary TSD. American 

Panel suggested that manufacturer cost 

should be estimated using a sample 

from 40 manufacturers and 

representative volumes. (American 

Panel, Public Meeting Transcript, No. 

0045 at p. 312) In response to American 

Panel’s comment, DOE believes it is 

infeasible to sample so many 

manufacturers because data on 

manufacturing cost and representative 

volumes are not publicly available for 

most manufacturers of walk-ins and 

walk-in components, particularly small, 

private companies. Additionally, not all 

manufacturers were willing to share cost 

information with DOE. DOE did hold 

confidential interviews with 

manufacturers, some of whom chose not 

to share this information. DOE notes 

that cost information it did obtain was 

helpful in enabling the agency to 

develop and refine its estimates of 

manufacturer cost. The interview 

process is explained in chapter 12 of the 

TSD. 

d. Manufacturing Markup 

DOE uses MSPs to conduct its 

downstream economic analyses. DOE 

calculated the MSPs by multiplying the 

manufacturer production cost by a 

markup and adding the equipment’s 

shipping cost. The production price of 

the equipment is marked up to ensure 

that manufacturers can make a profit on 

the sale of the equipment. DOE gathered 

information from manufacturer 

interviews to determine the markup 

used by different equipment 

manufacturers. Using this information, 

DOE calculated an average markup for 

each component of a walk-in. DOE 

requests comments on the proposed 

markups listed in Table IV–7. 

TABLE IV–7—MANUFACTURER

MARKUPS

Walk-in component Markup 

(percent) 

Panels ....................................... 32 

Display Doors ........................... 50 

Non-Display Doors ................... 62 

Refrigeration Equipment ........... 35 

e. Shipping Costs 

In the preliminary analysis TSD, DOE 

calculated manufacturer shipping costs 

assuming that manufacturers include 

outbound freight as part of their 

equipment selling price. In response to 

DOE’s request for comment on shipping 

assumptions, American Panel and 

NEEA and NPCC remarked that DOE’s 

costs were significantly higher than 

actual industry shipping rates. 

(American Panel, Public Meeting 

Transcript, No. 0045 at pp. 15, 142; 

NEEA and NPCC, No. 0059 at p. 9) 

Additionally, American Panel stated 

that freight costs are typically paid in 

full by the customer and not absorbed 

by the manufacturer who is selling the 

equipment. (American Panel, No. 0048.1 

at p. 5) Both American Panel and 

CrownTonka said that sometimes the 

freight cost would be included as part 

of the selling price and sometimes it 

would be entirely separate; i.e., paid by 

the buyer directly to the freight 

company. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 143; 

CrownTonka, Public Meeting 

Transcript, No. 0045 at p. 144) NEEA 

and NPCC stated that freight costs are 

normally included in the packaged price 

to consumers. (NEEA and NPCC, No. 

0059.1 at p. 9) 

DOE re-evaluated the shipping rates 

in preparing this NOPR. These rates 

were developed by conducting 

additional research on shipping rates 

and by interviewing manufacturers of 

the covered equipment. For example, 

DOE found through its research that 

most panel, display door, and nondisplay door manufacturers use less 

than truck load freight to ship their 

respective components and revised its 

estimated shipping rates accordingly. 

DOE also found that most 

manufacturers, when ordering 

component equipment for installation in 

their particular manufactured product, 

do not pay separately for shipping costs; 

rather, it is included in the selling price 

of the equipment. However, when 

manufacturers include the shipping 

costs in the equipment selling price, 

they typically do not mark up the 

shipping costs for profit, but instead 

include the full cost of shipping as part 

of the price quote. DOE has revised its 

methodology accordingly. Please refer to 

chapter 5 of the TSD for details. 

4. Baseline Specifications 

a. Panels and Doors 

In the preliminary analysis, DOE set 

the baseline level of performance to 

correspond to the most common least 

efficient component that is compliant 

with the standards set forth in EPCA. 

(42 U.S.C. 6313(f)(1)(3)) DOE 

determined specifications for each 

equipment class by surveying currently 

available units and models. This 

approach was used for the NOPR 

analyses to determine the baseline units 

for panels, display doors, and nondisplay doors. More detail about the 

specifications for each baseline model 

can be found in chapter 5 of the TSD. 

Because the walk-in market is 

comprised of panels insulated with 

polyurethane and extruded polystyrene, 

DOE proposed in the preliminary 

analysis that the R-value for the baseline 

insulation used in the walk-in envelope 

would be the average of the typical long 

term thermal resistance (LTTR) R-values 

of polyurethane and extruded 

polystyrene. CPI opposed the use of an 

average R-value for extruded 

polystyrene and polyurethane because it 

would affect the accuracy of the 

normalized energy consumption 

calculation for the envelope. (CPI, No. 


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0052.1, at p.1) DOE agrees with CPI’s 

concern and is using in the revised 

analysis foam-in-place polyurethane as 

the baseline insulation for panels and 

non-display doors. Polyurethane is more 

commonly used as panel or non-display 

door insulation, has a better long term 

thermal resistance, and is less expensive 

than extruded polystyrene. DOE notes 

that extruded polystyrene may 

outperform polyurethane in other 

respects, like moisture absorption, 

which are not captured in the energy 

consumption model because they are 

not included in the test procedure. 

DOE’s analysis also uses wood 

framing members as the baseline 

framing material in panels. The analysis 

assumes the typical wood frame 

completely borders the insulation and is 

1.5 inches wide. DOE requests comment 

on its baseline specifications for walkin panels, specifically the assumptions 

about framing material and framing 

dimensions. 

The baseline display doors modeled 

in DOE’s analysis are based on the 

minimum specifications set by EPCA. 

(42 U.S.C. 6313(f)(3)) DOE modeled 

baseline display cooler doors comprised 

of two panes of glass with argon gas fill 

and hard coat low emittance or low-e 

coating. The baseline cooler display 

door requires 2.9 Watts per square foot 

of anti-sweat heater wire and does not 

have a heater wire controller. The 

baseline display freezer doors modeled 

in DOE’s analysis consist of three panes 

of glass, argon gas, and soft coat low-e 

coating. Baseline freezer doors use 15.23 

watts per square foot of anti-sweat 

heater wire power and require an antisweat heater wire controller. DOE also 

estimates that each baseline door 

includes one fluorescent light with 

electronic ballasts, with a door shorter 

than 6.5 feet having a 5-foot fluorescent 

bulb and a door equal to or taller than 

6.5 feet having a 6-foot fluorescent bulb. 

DOE requests comment on the baseline 

assumptions for display cooler and 

freezer doors. In particular, DOE 

requests data illustrating the energy 

consumption of anti-sweat heaters 

found on cooler and freezer display 

doors. 

DOE’s analysis assumes that the 

baseline non-display doors are 

constructed in a similar manner to 

baseline panels. Therefore, DOE’s 

analysis uses baseline non-display doors 

that consist of wood framing materials 

1.5 inches wide that completely border 

the foamed-in-place polyurethane 

insulation. DOE also includes a small 

window in a non-display door that 

conforms to the standards set by EPCA. 

DOE estimates that all passage doors 

have a 2.25 square foot window 

regardless of the passage door’s size. 

DOE analyzed two different size 

windows for non-display freight doors. 

The small freight doors have a 2.25 

square foot window and both the 

medium and large freight doors have a 

4-square foot window. DOE requests 

comment on the baseline specifications 

for non-display doors, and specifically 

on the size of the windows included in 

the baseline doors. 

DOE also received comments about 

the amount of energy savings attributed 

to infiltration reduction devices (IRDs) 

on baseline walk-in doors. NEEA and 

NPCC commented that even though 

EISA requires an infiltration reduction 

device on the baseline door, DOE 

should also include additional IRDs as 

a design option. NEEA and NPCC 

continued to suggest that DOE should 

re-evaluate the amount of energy 

savings associated with IRDs. (NEEA 

and NPCC, Public Meeting Transcript, 

No. 0045 at p. 170) The Joint Utilities 

also believed that DOE overestimated 

the impacts of IRDs in the baseline 

doors and explained that overestimating 

the baseline savings from an IRD affects 

the amount of savings achieved by the 

design options DOE evaluated. (Joint 

Utilities, No. 0061.1 at p. 5) DOE agrees 

with NEEA and NPCC and the Joint 

Utilities that a baseline door must have 

an IRD because this is required by 

EPCA. (42 U.S.C. 6313(f)(1)(A)(B)) 

However, the walk-in test procedure 

does not measure energy consumption 

from door-opening infiltration so there 

is no rated energy saving from IRDs and 

DOE is not estimating the amount of 

energy saved from IRDs on baseline 

doors. 

b. Refrigeration 

As with panels and doors, DOE set the 

baseline level of refrigeration system 

performance to correspond to 

components that were the least efficient 

but compliant with the standards set 

forth in EPCA. See 42 U.S.C. 6313(f)(1)– 

(3). DOE determined specifications for 

each equipment class by surveying 

currently available models. See chapter 

5 of the TSD for more details about the 

specifications for each baseline model. 

In the preliminary analysis, DOE 

analyzed several representative baseline 

units for refrigeration systems and 

requested comment on the 

characterization of the baseline units. In 

response to DOE’s request for comment 

on the representative units analyzed, 

several stakeholders expressed concern 

that the range of refrigeration systems 

DOE evaluated was too limited. 

Heatcraft and the Joint Utilities 

encouraged DOE to include larger 

capacity equipment and different 

compressor types. (Heatcraft, No. 0058.1 

at pp. 3–4; Heatcraft, No. 0069.1 at p. 2; 

Joint Utilities, No. 0061.1 at p. 3) 

American Panel echoed this concern 

and stated that DOE should explore the 

full range of condensing units and that 

WICF envelopes should be paired with 

different sized refrigeration systems 

based on use. (American Panel, No. 

0048.1 at pp. 8–9) DOE has considered 

these comments and has expanded its 

analysis to include a larger range of 

refrigeration system capacities. DOE has 

also included different compressor 

types in the refrigeration system 

analysis; see section IV.C.5.b and 

chapter 5 of the TSD for details. DOE 

has not considered pairing WICF 

envelopes and refrigeration systems in 

the engineering analysis, however, 

because DOE is applying a componentbased approach. 

The preliminary analysis also 

presented estimated baseline 

specifications and costs for the 

representative units it analyzed. 

American Panel remarked that the 

baseline costs in the engineering 

analysis were too low and were not 

comparable to their data. Additionally, 

it stated that the refrigeration load will 

increase if the product is not at the same 

temperature as the walk-in cooler or 

freezer. (American Panel, No. 0048.1 at 

p. 7) Interested parties also commented 

on certain baseline unit subcomponents 

that were not included in the 

engineering analysis. American Panel 

noted that baseline units could include 

a downstream solenoid valve that would 

prevent refrigerant from migrating to the 

evaporator and Heatcraft encouraged 

DOE to make sure that the amount of 

refrigerant, piping, and insulation scale 

properly with size. (American Panel, 

No. 0048.1 at p. 7; Heatcraft, No. 0069.1 

at p. 3) 

In response to American Panel’s 

comments on refrigeration system costs, 

DOE adjusted its cost model as 

described in section IV.C.3 and believes 

its costs are now more representative of 

typical equipment. Regarding 

refrigeration load, DOE does not 

consider the effect of different product 

loads in the engineering analysis 

because the engineering analysis is 

based on the rating conditions; DOE 

considers product loads in the energy 

use analysis as explained in section 

IV.E.3. In response to American Panel’s 

and Heatcraft’s comments about 

subcomponents of refrigeration 

equipment, the revised analysis now 

includes all necessary subcomponents 

from the manufacturer—i.e., those 

subcomponents needed for the unit to 

operate. The analysis includes a 

calculation of refrigerant charge that is 


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scaled with the size of the unit, as 

Heatcraft suggested. DOE has tentatively 

decided not to include piping and 

insulation between the unit cooler and 

condensing unit, as it believes these 

components would not be supplied by 

the manufacturer or included in the 

equipment’s MSP, but by the contractor 

upon installation of the equipment. DOE 

requests comment on this assumption. 

In the preliminary analysis, DOE 

made certain assumptions regarding 

saturated evaporator temperature (SET) 

and saturated condensing temperature 

(SCT) that it used in the analysis for 

freezers and coolers and indoor and 

outdoor units. In general, DOE based 

these temperatures on an assumed 

temperature difference (TD) between the 

coil temperature and the ambient 

temperature where the ambient 

temperature for indoor and outdoor 

units was specified by the rating 

conditions in AHRI 1250–2009, the test 

procedure for refrigeration systems. 76 

FR at 33631. The Joint Utilities and 

Heatcraft both submitted comments 

about the temperature set points in the 

baseline equipment; the Joint Utilities 

suggested a condensing temperature 

control point of 90 °F for both freezers 

and coolers, while Heatcraft 

recommended different temperatures for 

several equipment classes. (Joint 

Utilities, No. 0061.1 at p. 10; Heatcraft, 

No. 0069.1 at p. 2) 

In determining appropriate 

temperature set points, DOE considered 

information from various sources when 

formulating its assumptions, including 

comments, research, and discussions 

with manufacturers and other parties. 

DOE notes that the ambient temperature 

for the test procedure is 90 and 95 °F 

for indoor and outdoor condensing 

units, respectively. Given that the 

system must maintain a reasonable TD 

between the SCT and the ambient 

temperature, the SCT during the test 

procedure would be higher than the 90– 

95 °F assumption recommended by the 

Joint Utilities. Even though the set point 

during actual use may be lower, 

equipment is rated—and evaluated for 

meeting the standard—at the test 

procedure rating points. For these 

reasons, DOE believes its SCT 

assumptions are reasonable for baseline 

equipment operating at the rating 

conditions required for the test 

procedure. DOE requests comment on 

this assumption, particularly whether 

the TDs for baseline and higher 

efficiency equipment are appropriate. 

See chapter 5 of the TSD for details. 

5. Design Options 

a. Panels and Doors 

For the preliminary analysis, DOE 

included the following design options 

for the walk-in envelope: 

• Improved wall, ceiling, and floor 

insulation 

• Improved door gaskets and panel 

interface systems 

• Electronic lighting ballasts and 

high-efficiency lighting 

• Occupancy sensors and automatic 

door opening and closing systems 

• Air curtains and strip curtains 

• Vestibule entryways 

• Display and window glass system 

insulation enhancements 

• Anti-sweat heater controls and no 

anti sweat heat systems 

In the preliminary analysis, DOE 

presented tables detailing each design 

option, including the cost of 

implementing each option and a 

description of the design option’s 

properties. The discussion below sets 

forth comments received on these 

design options for panels and doors, as 

well as DOE’s proposed approach in 

today’s NOPR. 

Panels 

Stakeholders commented on steady 

state IRDs that DOE initially considered 

including as design options for the 

walk-in envelope. Craig Industries 

commented that DOE should consider 

different caulking materials as a design 

option because it is inexpensive and 

would reduce infiltration by sealing the 

joints of walk-ins, but noted that this 

design option would conflict with the 

current National Sanitation Foundation 

(NSF) standards. (Craig Industries, No. 

0064.1 at p. 3) American Panel stated 

that changing the gasketing or joint 

profile of an insulated panel would 

require a new test burden of $20,000, 

and that the improved gasketing is not 

necessarily going to be functional. It 

also noted that improved panel 

interfaces may not mate with existing 

walk-in panels, which would prevent 

manufacturers from supplying 

replacement panels. Lastly, in its view, 

the complex gasketing and panel 

interface systems could cause walk-ins 

to become more difficult to build. 

(American Panel, No. 0048.1 at p. 6; 

American Panel, Public Meeting 

Transcript, No. 0045 at p. 121) Hill 

Phoenix commented that enhancing the 

gasketing between panels will not have 

a significant impact on the walk-in’s 

energy consumption. In its view, the 

main heat load caused by infiltration is 

from door openings as opposed to 

steady state infiltration. (Hill Phoenix, 

No. 0066.1 at p. 3) 

For the reasons stated in the test 

procedure final rule, the test procedure 

promulgated by DOE no longer requires 

manufacturers to measure a walk-in’s 

steady-state infiltration. Therefore, 

design options for reducing steady state 

infiltration, including caulking and 

improved gasketing, would not impact 

the rated energy consumption of any of 

the walk-in components addressed in 

this rulemaking. 76 FR 21580, 21595 

(April 15, 2011). Furthermore, DOE 

would screen out any design options 

(including caulking) that would be 

likely to have significant adverse 

impacts on the utility of the equipment 

or had an adverse impact on health or 

safety, according to the screening 

criteria described in section IV.B. 

In the preliminary analysis, DOE 

considered design options that 

increased the baseline insulation 

thickness and improved insulation 

material. The preliminary analysis used 

a baseline insulation thickness of 4 

inches and analyzed design options 

with increased insulation thicknesses of 

5 inches, 6 inches, and 7 inches. The 

baseline panel insulation R-value was 

an average of extruded polystyrene and 

foamed-in-place polyurethane. The 

improved insulation materials in the 

preliminary analysis were vacuum 

insulated panel (VIP) insulation and 

hybrid insulation, a combination of the 

baseline material and vacuum insulated 

panels. 

Many stakeholders commented on the 

proposed insulation improvements. 

American Panel did not agree with the 

initial costs DOE initially presented for 

the increased thicknesses of insulation. 

In its view, costs were higher due to the 

increased difficulty of manufacturing 

thicker panels. To accurately reflect this 

inefficiency, American Panel suggested 

DOE increase the cost of labor per panel 

because it takes more time to foam the 

fixture. (American Panel, No. 0048.1 at 

p. 5) American Panel also remarked that 

most manufacturers possess tooling that 

is adjustable only from 4–6 inches. 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 121) Hill 

Phoenix stated that panel thicknesses 

above 5.5 inches will have a costly 

impact on the manufacturer and end 

user because manufacturers need to 

purchase more equipment to deal with 

the increased weight and the end-user 

will need more floor space to house or 

site the walk-in. (Hill Phoenix, No. 

0066.1 at p. 3) American Panel 

criticized the preliminary analysis for 

omitting insulating floor panels or an 

insulation slab with vertical breaks as 

design options. American Panel 

explained that although the payback 

period would be longer if these options 


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are included, DOE should still consider 

the long term energy savings that these 

options may yield. (American Panel, No. 

0048.1 at p. 5) 

DOE agrees with American Panel that 

most manufacturers do not currently 

have the tooling to produce panels with 

more than 6 inches of insulation. In 

addition, DOE finds that constructing 

and handling panels thicker than 6 

inches would be unduly burdensome to 

the manufacturer because panels thicker 

than 6 inches would be very difficult to 

handle, store, ship, and produce at 

typical industry production volumes. 

Because panels thicker than 6 inches 

would not be practicable to 

manufacture, DOE screened them out 

from its analysis. DOE’s NOPR analysis 

limits the maximum insulation 

thickness to 6 inches of foam and DOE 

does not expect its proposed standard to 

require panels thicker than 5 inches (see 

chapter 5 and appendix 10D of the 

TSD); however, the agency requests 

comment on this assumption in the 

analysis. DOE notes Hill Phoenix’s 

comment about the increased labor cost 

associated with increasing the panel 

thickness and proposes to account for 

the increased cost of handling large 

panels in its cost-efficiency analysis. 

DOE also agrees with American Panel’s 

comment that requiring insulated floor 

panels for walk-in coolers would 

produce long term energy savings. 

However, DOE is not proposing to set a 

standard for walk-in cooler floors as 

explained in section IV.A.2.a of this 

notice. 

Two stakeholders made comments 

specifically about VIPs. NanoPore stated 

that silica-carbon based core materials 

have a better lifetime performance than 

fiberglass core materials when using 

vacuum insulated panels, and noted 

that VIPs have reached a point of large 

scale commercialization. (NanoPore, No. 

0067.1 at pp. 1 and 6) However, Hill 

Phoenix commented that VIPs are 

impractical because of the high cost to 

the manufacturer, and that vacuum 

insulated panels would require 

additional labor and tooling. (Hill 

Phoenix, No. 0066.1 at p. 3) 

DOE included hybrid insulation (half 

foam-in-place polyurethane and half 

VIP) as a design option to improve the 

efficiency of walk-in panels and nondisplay doors. It did not, however, 

include VIP insulation as a design 

option because DOE cannot definitively 

conclude that VIPs have the structural 

capability of supporting typical walk-in 

loads, particularly since VIPs can easily 

be punctured, which would cause a loss 

in thermal insulation (see chapter 5 of 

the TSD for details). DOE notes that 

while NanoPore stressed the benefits of 

silica-carbon based VIP, DOE did not 

specify the type of VIP used in the 

engineering analysis in order to 

maximize manufacturer flexibility in 

meeting the proposed standard. DOE 

agrees with Hill Phoenix that VIPs are 

more expensive and may require 

additional tooling, but DOE does not 

find this increased cost would prevent 

manufacturers from implementing VIPs. 

DOE also notes that the high costs of 

VIPs are captured in the engineering 

analysis for panels and non-display 

doors. 

In its engineering analysis for walk-in 

panels, DOE included design options 

which increase the baseline insulation 

thickness, change the baseline 

insulation material from foam-in-place 

polyurethane to a hybrid of 

polyurethane and VIP, change the 

baseline framing material from wood to 

high density polyurethane, and 

eliminate a structural panel’s framing 

material. DOE assumed in its analysis 

that freezer floor panels retain some 

type of framing material to maintain 

structural integrity because the foam 

itself may be unable to support heavy, 

perpendicular loads—e.g. personnel, 

machinery, and products—to the panel’s 

face. DOE also assumed that high 

density polyurethane framing materials 

used in a panel have the same 

dimensions as the wood framing 

materials used in a wood-framed panel. 

DOE seeks comment on these panel 

design options, particularly with respect 

to the specifications for high density 

polyurethane framing materials. 

Doors 

Stakeholders also commented on 

design options that would reduce the 

infiltration from door openings: namely, 

automatic door opening and closing 

systems, which automatically open and 

close the door by sensing when a person 

is about to pass or has passed through; 

air curtains and strip curtains, both of 

which provide a secondary barrier to air 

infiltration when the door is open; and 

vestibule entryways, which consist of a 

series of two doors separated by a space 

through which one would pass to enter 

the walk-in. Hired Hand noted that the 

engineering analysis omitted automatic 

roll-up doors or bi-folding envelope 

doors, and that these doors cannot be 

adequately subsumed under ‘‘automatic 

door opening and closing’’ (which DOE 

did include) because this option does 

not capture the full benefit of these 

doors. (Hired Hand, No. 0050.1 at pp. 1– 

2) American Panel was skeptical that 

automatic door opening and closing 

sensors existed in the industry and did 

not agree with DOE’s proposed cost of 

the technology. (American Panel, No. 

0048.1 at p. 6) American Panel also 

stated that a vestibule is not a practical 

design option because the cost of the 

floor space and the layout of standard 

stores would be prohibitive to the end 

user. It noted that the cost of a vestibule 

is higher than DOE estimated, and 

predicted that the cost for materials and 

equipment would be well over $2,500. 

(American Panel, No. 0048.1 at pp. 3 

and 6) 

For the reasons stated in its recent 

final rule, the test procedure does not 

include a method for measuring the 

door opening infiltration associated 

with walk-ins. See 76 FR at 21595. 

Therefore, the energy consumption 

caused by door opening infiltration is 

not accounted for in the panel, display 

door, or non-display door engineering 

analyses, and design options related to 

door opening infiltration would not 

affect the energy consumption of the 

walk-in components. 

Some stakeholders specifically 

commented about the strip curtains 

design option. NEEA and NPCC stated 

that strip curtains are already required 

by EPCA, and should not be considered 

a design option, but that infiltration 

load could still be reduced by additional 

IRDs. (NEEA and NPCC, Public Meeting 

Transcript, No. 0045 at p. 170; NEEA 

and NPCC, No. 0059.1 at p. 8) NEEA, 

NPCC and Master-Bilt disagreed with 

DOE’s assumption that strip curtains 

can reduce the total energy 

consumption of a walk-in by half. NEEA 

and NPCC suggested strip curtains 

would more likely reduce the energy 

consumption by one third, according to 

a Pacific Northwest study, and MasterBilt commented that strip curtains 

reduce the compressor load by less than 

5 percent according to their own field 

tests. (NEEA and NPCC, Public Meeting 

Transcript, No. 0045 at p. 152; NEEA 

and NPCC, No. 0059.1 at p. 8; MasterBilt, Public Meeting Transcript, No. 

0045 at p. 159; Master-Bilt, No. 0046.1 

at p. 1) American Panel noted that strip 

curtain manufacturers indicated that the 

device achieves a 25 percent reduction 

in air infiltration, much lower than 

DOE’s assumption of 90 percent 

effectiveness. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 154; 

American Panel, No. 0048.1 at p. 6) 

Lastly, AHRI also commented that DOE 

overestimated the benefit of strip 

curtains, and that DOE should verify 

their assumptions with field data; AHRI 

did not provide any alternative data on 

the benefit of strip curtains. (AHRI, No. 

0055.1 at p. 2) As explained in section 

IV.B.1 of this document, however, 

infiltration devices are no longer 

included in the engineering analysis. 


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Stakeholders also commented on the 

door lighting design options presented 

in the preliminary analysis; specifically, 

occupancy sensors that cause the lights 

to operate only when people are 

present; electronic lighting ballasts, 

which are more efficient than typical 

magnetic ballasts; and high-efficiency 

light-emitting diode (LED) lighting, a 

type of lighting that uses 

semiconducting materials to produce 

light and uses less energy per lumen 

than incandescent or fluorescent 

lighting. American Panel stated that 

LED lighting is not a viable design 

option because the LED fixture and bulb 

payback period is 2.5 years. (American 

Panel, No. 0048.1 at p. 6) The Joint 

Utilities suggested that DOE should add 

LED lighting with motion controls as a 

design option for display cases. (Joint 

Utilities, Public Meeting Transcript, No. 

0045 at p. 26; Joint Utilities, Public 

Meeting Transcript, No. 0045 at p. 89; 

Joint Utilities, No. 0061.1 at p. 3) 

In response to American Panel’s 

concern about the cost of LED lighting, 

DOE accounts for the cost of the bulb 

and fixture when estimating the total 

cost of LED lighting. However, DOE has 

not automatically eliminated LED 

lighting from consideration based on 

payback period but includes it in the 

range of design options it is considering. 

For more details on the payback period 

analysis, see section IV.F. In response to 

the suggestion from Joint Utilities, a 

combined design option with LED 

lighting and motion control sensors is 

not warranted because DOE already 

includes a lighting sensor and LED 

lighting as separate design options in 

the walk-in display door engineering 

analysis. A separate design option for 

lighting sensors allows the sensor to be 

applied to fluorescent as well as LED 

lighting. 

Some stakeholders commented on the 

anti-sweat heater wire design option. 

CrownTonka commented that anti-sweat 

heater wire should be applied to nondisplay freezer doors and any windows 

in non-display doors. (CrownTonka, 

Public Meeting Transcript, No. 0045 at 

p. 89) Craig Industries supported the 

inclusion of self-regulating heater wire 

and noted that this wire is readily 

available and more efficient than other 

types of heater wires. (Craig Industries, 

No. 0064.1 at p. 1) DOE agrees with 

CrownTonka and proposes to include 

anti-sweat heater wire around the outer 

edge of non-display freezer doors as 

well as on the windows located on nondisplay doors as design options. In 

response to Craig Industries’ suggestion, 

the energy savings from self-regulating 

anti-sweat heater wire alone cannot be 

captured in the proposed engineering 

analysis for display and non-display 

doors because the energy savings are not 

captured by the test procedure. The test 

procedure credits the manufacturer with 

energy savings if a preinstalled timer, 

control system or other auto-shut-off 

system is used in conjunction with antisweat heater wire. The credit is called 

a percent time off (PTO) credit, which 

reduces the calculated power associated 

with the device. 76 FR 33631, 33635, 

33637 (June 9, 2011). 

The display door design options used 

in the analysis include improved glass 

packs—where ‘‘glass pack’’ refers to the 

combination of glass panes, gas fill, and 

low-emission coatings making up the 

transparent part of the door; anti-sweat 

heater controls for cooler doors; LED 

lighting; and lighting sensors that 

control when the lights turn on and off. 

DOE did not analyze anti-sweat heater 

controls for freezer display doors 

because baseline freezer doors are 

already required to have a controller to 

regulate the power consumed by the 

anti-sweat heater wire. EISA requires all 

freezer doors to have an anti-sweat 

heater control if the anti-sweat heater 

wire consumes more than 7.1 watts per 

square foot of door opening, and DOE 

estimated that baseline display doors 

consume 15.2 watts per square foot of 

door opening. Therefore, baseline 

display doors already have an antisweat heater wire control system in 

order to comply with EISA. 

As explained previously, the walk-in 

cooler and freezer test procedure credits 

the manufacturer for having a control. 

The type or amount of controls does not 

change the credit nor increase the 

energy savings realized by the DOE test 

procedure. For these reasons, DOE did 

not include control systems as a design 

option. Additionally, DOE did not 

consider eliminating anti-sweat heater 

wire as a separate design option. The 

improvements made to the glass pack 

cause a reduction in the power draw of 

the anti-sweat heater wire. In the case of 

display cooler doors, the performance of 

the glass pack is improved enough so 

that anti-sweat heater wire is no longer 

required on the door. DOE also did not 

consider higher efficiency ballasts in its 

analysis because it found that electronic 

ballasts already incorporated into 

baseline units and DOE is not aware of 

more efficient ballasts. DOE requests 

comment on its analyzed design options 

and specifically seeks any heat transfer 

data for the improved glass packs 

detailed in chapter 5 of the TSD. 

The design options that DOE analyzed 

in the engineering analysis for nondisplay doors include increasing the 

insulation thickness, changing the 

insulation material from baseline to a 

hybrid of polyurethane and VIP, 

changing the baseline framing material 

from wood to high density 

polyurethane, improving the window’s 

glass pack, and adding an anti-sweat 

heater wire controller to the door. These 

options are more fully described in 

chapter 5 of the TSD. DOE requests 

comment on the non-display door 

design options it analyzed, particularly 

with respect to the cost of the window 

improvements detailed in chapter 5 of 

the TSD. 

American Panel suggested that DOE 

consider low cost methods for extending 

the envelope and door lifetimes. 

(American Panel, No. 0048.1 at p. 9) 

DOE has not considered options in this 

analysis that do not improve the rated 

performance of the equipment, as 

described in section IV.B.1. The purpose 

of the engineering analysis is to analyze 

the manufacturing cost and the 

performance of the covered equipment 

as rated by the test procedure. 

Examining methods to extend the life of 

walk-in equipment, including the 

impact of such methods on standards 

adopted by DOE, would complicate and 

create a significant impediment to 

completion of this rulemaking, without 

any clear prospect that it would affect 

the standards DOE ultimately adopts. 

For this reason, DOE has decided not to 

pursue this issue. 

After considering all the comments it 

received on the design options, DOE is 

including the following design options 

in the NOPR analysis for panels, display 

doors, and non-display doors: 

Panels 

• Increased insulation thickness up to 

6 inches 

• Improved insulation material 

• Improved framing material 

Display Doors 

• High-efficiency lighting 

• Occupancy sensors 

• Display and window glass system 

insulation performance 

• Anti-sweat heater controls 

Non-Display Doors 

• Increased insulation thickness up to 

6 inches 

• Improved insulation material 

• Improved panel framing material 

• Display and window glass system 

insulation performance 

• Anti-sweat heater controls 

• No anti-sweat systems 

b. Refrigeration 

In the preliminary analysis, DOE 

included the following design options 

for the walk-in refrigeration system: 

• High-efficiency compressors 


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• Improved condenser coil 

• High-efficiency condenser fan 

motors 

• Improved condenser fan blades 

• Improved evaporator coil 

• Improved evaporator fan blades 

• Evaporator fan controls 

• Floating head pressure 

• Defrost controls 

The preliminary analysis contained 

tables detailing each design option, 

including the cost of implementing each 

option and a description of the design 

option’s properties. The discussion 

below sets forth comments received on 

these design options for refrigeration 

systems, as well as DOE’s proposed 

approach in today’s NOPR. 

One option DOE considered was highefficiency compressors. For example, 

DOE suggested using scroll compressors 

to represent the performance associated 

with higher efficiency compressors in 

walk-in applications. In response, 

Master-Bilt and Heatcraft commented 

that scroll compressors are not 

necessarily more efficient than other 

compressor types and are limited by 

their application and the prevalent 

conditions in which the compressor 

operates. (Master-Bilt, Public Meeting 

Transcript, No. 0045 at p. 1; Heatcraft, 

No. 0058.1 at p. 2) Heatcraft also stated 

that with increasing horsepower, fewer 

compressor types are available. 

(Heatcraft, No. 0069.1 at p. 1) The Joint 

Utilities added that for larger walk-in 

units, semi-hermetic compressors are 

more efficient than scroll types—except 

at low temperatures where, in their 

view, scroll compressors are more often 

utilized—but they did not provide 

information supporting the same. In 

addition, the Joint Utilities stated that 

hermetic compressors hold an added 

cost advantage over semi-hermetic 

compressors. (Joint Utilities, No. 0061.1 

at pp. 6 and 10) With regard to the types 

of compressors used in the food service 

market, American Panel suggested that 

hermetic compressors were dominant 

and stated that semi-hermetic 

compressors’ high initial cost made 

them less prevalent generally. 

(American Panel, No. 0048.1 at p. 9) 

DOE conducted additional research 

on available compressors and found that 

the prevalence of some compressor 

types varied at certain sizes. DOE also 

ensured that its analysis accounted for 

the effect that different applications and 

conditions may have on the relative 

efficiency of compressor types. In 

particular, the NOPR analysis includes 

an evaluation of a wide range of 

refrigeration capacities, and DOE has 

separately evaluated the different 

compressor types available at each 

capacity point. DOE believes that this 

modified analysis adequately captures 

the performance of each compressor 

type at each size and set of operating 

conditions. 

To obtain data on compressor 

performance, DOE’s preliminary 

analysis relied on manufacturer Web 

sites and related product specification 

sheets and did not consider the effect of 

the return gas conditions. The 

compressor data were based on return 

gas conditions under which the 

individual compressors were rated. The 

Joint Utilities stated that the return gas 

conditions were inconsistent with the 

typical operating conditions of walk-ins. 

(Joint Utilities, Public Meeting 

Transcript, No. 0045 at p. 27 and No. 

0061.1 at p. 11) In consideration of the 

Joint Utilities’ comment, DOE 

investigated the effect of the return gas 

conditions on compressor performance 

and has updated the compressor 

characteristics using return gas 

conditions that are consistent with the 

rating conditions in AHRI 1250–2009, 

which are different from the rating 

conditions for individual compressors. 

The conditions are contained within 

AHRI 1250–2009 itself, which DOE has 

incorporated into its test procedure. 76 

FR at 33631. 

After considering the stakeholder 

comments and conducting further 

research, DOE expanded its initial 

compressor range beyond scroll 

compressors and hermetic compressors 

to now include semi-hermetic 

compressors in the list of compressor 

options in order to capture most of the 

market share. This was done specifically 

due to the varying compressor 

efficiencies at different operating 

temperatures, and the lack of 

availability of certain compressor types 

at all capacity ranges. For example, it is 

difficult to obtain hermetic compressors 

at capacities exceeding 30,000 Btu/h, so 

manufacturers may be more likely to use 

semi-hermetic compressors at these 

capacities as a lower-cost alternative to 

scroll compressors. 

The preliminary TSD discusses the 

evaporator and condensing coil baseline 

and improved efficiency as coil size 

increases. In that analysis, DOE selected 

increased coil size as a design option 

because increasing the coil size 

corresponds to a drop in temperature 

difference, which would increase 

compressor capacity and result in lower 

normalized energy consumption. 

DOE received several comments about 

heat exchanger coil size and the 

associated savings. The Joint Utilities, 

Manitowoc and Heatcraft commented 

that the analysis did not consider an 

increase in fan power with an increase 

in coil size. (Joint Utilities, Public 

Meeting Transcript, No. 0045 at p. 27 

and No. 0061.1 at p. 6; Manitowoc, No. 

0056.1 at p. 2; Heatcraft, No. 0058.1 at 

pp. 2 and 3) American Panel stated that 

increasing condenser coil size would 

also require an increase in evaporator 

coil size, while Manitowoc suggested 

that the coil heat transfer equation 

should use log-mean temperature. 

(American Panel, No. 0048.1 at p. 6; 

Manitowoc, No. 0056.1 at p. 2) 

After carefully considering these 

comments, DOE modified its analysis by 

increasing fan power proportionally to 

coil size. DOE found through its 

analysis, however, that as coil size 

increases, the decrease in compressor 

power far exceeds the increase in fan 

power, which ultimately decreases the 

net energy consumption. As a result, 

DOE retained increased coil size as a 

design option in its analysis. DOE agrees 

with Manitowoc’s comment that using 

log mean temperature difference is a 

more accurate way to calculate heat 

transfer because this method accounts 

for changes in air temperature and 

refrigerant temperature across the 

refrigerant coil rather than assuming 

that these temperatures are constant. 

DOE’s analysis had used a simplified 

form of the heat transfer equations in 

the preliminary analysis, but now 

includes a log mean temperature 

difference in its analysis for the NOPR. 

In response to American Panel’s 

comment about requiring an increase in 

evaporator coil with condenser coil, 

DOE has taken a complete system 

modeling approach in analyzing the 

refrigeration system’s performance to 

capture any effects on the evaporator 

conditions from condenser coil changes. 

At this point, DOE believes that 

increasing the coil size of the condenser 

does not necessarily require an increase 

in coil size for the evaporator because 

the manufacturer would balance other 

aspects of the system to maintain the 

same capacity. DOE requests comment 

on this assumption, particularly from 

manufacturers who currently utilize 

larger condenser coils. 

Condenser Fan Motors 

In chapter 5 of the preliminary TSD, 

DOE discussed more efficient condenser 

fan motors as a viable design option. 

EPCA requires that walk-in condenser 

fan motors of less than 1 horsepower 

must use permanent split capacitor 

motors, electronically commutated 

motors, or three-phase motors. (42 

U.S.C. 6313(f)(1)(F)) Permanent split 

capacitor (PSC) motors are less 

expensive and less efficient than 

electronically-commutated (EC) motors 

and are currently used by the majority 

of manufacturers. DOE also assumed the 


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same motor efficiencies for PSC and EC 

motors that were assumed in the ANSI/ 

ARI Standard 1200–2006—that is, 29 

percent and 66 percent respectively. 

(The analysis screened out three-phase 

motors as a design option based on 

utility to the consumer, as explained in 

section IV.B.2.b, although 

manufacturers may still use this 

technology to improve the overall 

efficiency of the equipment they 

manufacture.) 

DOE received comments about the 

assumed efficiency of fan motors. 

Manitowoc commented that DOE’s 

assumed efficiency for PSC motors was 

too low and should be about 50 percent, 

while Heatcraft stated that PSC motor 

efficiency would likely be between 45 

and 55 percent, three-phase motor 

efficiency would be approximately 80 

percent, and EC motor efficiency would 

range from 60 to 90 percent. 

(Manitowoc, No. 0056.1 at p. 2; 

Heatcraft, No. 0058.1 at p. 2 and No. 

0069.1 at p. 2) The Joint Utilities 

suggested that the methodology of 

determining input power from 

efficiency ratings for small motors was 

inaccurate. (Joint Utilities, No. 0061.1 at 

p. 8) Heatcraft provided a list of parts 

to be added to the engineering analysis. 

(Heatcraft, No. 0069.1 at p. 1) 

DOE has considered the suggestions 

of Manitowoc and Heatcraft regarding 

motor efficiency and has changed its 

assumptions for PSC motors to 50 

percent and EC motors to 75 percent 

after researching currently available 

motors. Additionally, regarding 

comments received from Heatcraft about 

three-phase motors, DOE did not 

include three-phase motors as a design 

option or as part of the design of smaller 

baseline equipment due to adverse 

utility to the consumer and 

impracticability to manufacture, install 

and service, because many consumers 

do not have three-phase power sources; 

however, DOE assumed that larger 

baseline equipment would use threephase motors. See section IV.B.2.b for 

more details. DOE also included in its 

analysis the fan motor parts Heatcraft 

identified after evaluating teardown 

data and conducting further analysis of 

those parts. In response to the Joint 

Utilities’ comment that DOE should not 

determine input power from efficiency 

ratings, DOE has used this method as its 

best estimate for motor power 

consumption. DOE has not identified a 

more accurate methodology for 

determining input power and requests 

feedback on this issue. 

Chapter 5 of the preliminary TSD 

presented several fan blade options for 

the evaporator and condenser fan blade 

design option. Responding to these 

options, Heatcraft suggested the 

inclusion of swept fan blades as they are 

more aerodynamic and reduce 

vibrations and noise that result in 

inefficiencies. In addition, it also 

suggested that motor efficiency is 

independent from fan blade efficiency 

because more efficient fan blades do not 

result in high efficiencies for motors and 

vice versa. Rather, the efficiency of each 

component is due to its own intrinsic 

characteristics. After considering 

Heatcraft’s comment, DOE is continuing 

to treat the motor and fan blade options 

separately. 

The preliminary analysis examined 

evaporator fan controls as a design 

option. The impacts of fan controls were 

analyzed consistent with the test 

procedure requirement that ‘‘controls 

shall be adjusted so that the greater of 

a 25 percent duty cycle or the 

manufacturer default is used for 

measuring off-cycle fan energy. For 

variable-speed controls, the greater of 25 

percent fan speed or the manufacturer’s 

default fan speed shall be used for 

measuring off-cycle fan energy.’’ 

Because of this requirement, DOE set a 

75 percent reduction in off-cycle fan 

energy as the energy savings achieved 

for the fan control technology option. 

DOE did not differentiate between 

modulated fan controls and variable 

speed fan controls in the preliminary 

analysis. DOE received comments both 

on its characterization of the fan control 

design option and on the energy results 

for that design option. NEEA and NPCC 

expressed concern that DOE’s analysis 

caused the evaporator fan control option 

to appear less cost-effective compared to 

other design options, possibly 

indicating that DOE underestimated its 

potential energy savings. (NEEA and 

NPCC, No. 0059.1 at p. 7) The Joint 

Utilities cited studies indicating that fan 

speed control is one of the most, if not 

the most, cost-effective design option for 

many refrigeration systems. (Joint 

Utilities, Public Meeting Transcript, No. 

0045 at p. 28; No. 0061.1 at pp. 2 and 

6) The Joint Utilities also criticized 

DOE’s initial approach of not 

distinguishing between fan cycling and 

fan speed control. They indicated that 

the approach taken by DOE overly 

simplified the analysis, which then 

yielded considerably smaller projected 

savings for multiplex systems. Because 

of the complexity of the size ranges and 

system variations of these units, a more 

detailed analysis than the single design 

option used in the preliminary analysis 

is, in their view, required to sufficiently 

evaluate the potential energy savings 

from using a fan control system. They 

recommended that an analysis of fan 

speed controls include the benefit of 

operating at reduced fan speeds for the 

majority of the time the system operates. 

(Joint Utilities, No. 0061.1 at pp. 6 and 

9) NEEA and NPCC agreed with DOE’s 

approach insofar as fan controls that 

adjust envelope interior temperature 

conditions should be applied to every 

walk-in. (NEEA and NPCC, No. 0059.1 

at p. 7) 

Some interested parties also 

cautioned DOE about the unintended 

consequences of implementing different 

types of fan controls. The Joint Utilities 

stated that a fan duty-cycling control 

strategy would be unacceptable in many 

applications because of the increased 

likelihood of uneven temperatures and 

the related concern for perishable 

products. (Joint Utilities, No. 0061.1 at 

p. 9) Zero Zone stated that variable 

speed evaporator fan motors could 

prevent the walk-in from maintaining 

the desired product temperature. (Zero 

Zone, No. 0051.1 at p. 1) American 

Panel stated that if fan controls cause 

the compressor to run for longer 

periods, energy consumption will 

increase because the compressor draws 

more power than the fans. American 

Panel also recommended that DOE 

ensure that whatever standards it may 

propose, that air defrost evaporators still 

be able to defrost ice build-up on 

refrigeration coils during off-cycle 

periods using lower fan speeds. 

(American Panel, No. 0048.1 at p. 7) 

One interested party commented on 

DOE’s assumed cost of the fan control 

option. The Joint Utilities stated that the 

assumed cost of $300 for fan control 

would likely be lower, particularly for 

small walk-ins, because the EC motors 

have inherent variable speed capability 

and the microcontrollers used to control 

these motors can provide the required 

voltage signal to control the EC motors. 

(Joint Utilities, No. 0061.1 at p. 9) 

To address these concerns, DOE has 

made several changes to its fan control 

analysis. DOE is now considering both 

modulated (fan cycling) and variable 

speed controls as potential design 

options. Modulated fan controls cycle 

the fans at 50 percent runtime at 100 

percent speed when the compressor is 

off, while variable speed controls set the 

fan speed to 50 percent of maximum 

speed at 100 percent runtime when the 

compressor is off. DOE’s analysis 

applies the commonly used fan power 

laws, which describe the relationship 

between power and speed during a fan’s 

operation. A reduction in fan speed 

causes a reduction in fan power to the 

third power. For example, reducing 

speed to 50 percent of full speed 

reduces the power to 12.5 percent of full 

power. Thus, variable speed controls 


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would be expected to save more energy 

than modulated fan controls for the 

particular control strategies analyzed. 

DOE applied both modulated fan 

controls and variable speed fan controls 

as a design option for all classes 

analyzed. DOE did not, however, 

consider controls that respond to 

specific box conditions because, as 

stated in the test procedure final rule, 

the impact of these controls would not 

be captured using the component-level 

approach, which analyzes refrigeration 

systems separately from envelope 

components. DOE notes that, as a result 

of the enhancements made to its 

analytical approach, the NOPR analysis 

indicates that modulated and variable 

speed fan controls would likely be 

among the primary options to improve 

walk-in refrigeration system efficiency. 

DOE appreciates the concerns about 

fan controls raised by American Panel, 

the Joint Utilities, and Zero Zone. DOE’s 

research does not indicate that air 

defrost would be adversely affected by 

fan controls. Therefore, air defrost 

would likely still be adequate with 

reduced fan speed. To address 

commenters’ concerns about the 

potential effects of fan controls on food 

safety, DOE estimates that the outcome 

of using such controls would be 

equivalent to an overall 50 percent 

decrease in runtime (for a cycle control) 

or a 50 percent decrease in speed (for a 

variable-speed control) and has 

tentatively concluded that the impact of 

the controls it analyzed will be limited 

and not affect the maintenance of safe 

food temperatures. See chapter 5 for 

details. DOE requests comment from 

interested parties as to whether food 

temperatures would be adequately 

maintained in the specific control cases 

it has analyzed and, if not, what an 

appropriate control strategy would be. 

DOE seeks any data that interested 

parties can provide to show the 

relationship between fan controls and 

food temperatures. DOE also seeks 

information as to whether additional 

components are necessary to ensure 

food temperature, such as extra 

thermostats located in certain areas of 

the walk-in. To address American 

Panel’s comment about compressor 

runtime, DOE does not expect 

compressor runtime to increase from the 

inclusion of fan control implementation 

because the fans run at full speed while 

the compressor is running and fan speed 

or cycling controls are activated only 

when the compressor is off. DOE also 

does not expect controls to increase the 

amount of time the compressor is off 

because the compressor cycles on based 

on the walk-in’s interior temperature, 

which DOE believes will not be 

significantly affected by the fan control 

strategy modeled in the analysis. 

Defrost Controls 

In the preliminary analysis, DOE 

evaluated several defrost control options 

available in the market. DOE considered 

using time-initiated, time-terminated 

defrost as the baseline. The design 

option involved a generic defrost 

control that would result in half as 

many defrosts per day. Heatcraft and 

American Panel doubted whether 

existing defrost controls could achieve 

the 50 percent reduction in defrosts 

assumed in the preliminary analysis. 

(American Panel, No. 0048.1 at p. 7; 

Heatcraft, No. 0058.1 at p. 4) In 

addition, Heatcraft, American Panel and 

the Joint Utilities suggested DOE replace 

time termination with temperature 

termination in the base case. (Heatcraft, 

No. 0058.1 at p. 4; American Panel, No. 

0048.1 at p. 7; Joint Utilities, Public 

Meeting Transcript, No. 0045 at p. 26) 

Heatcraft and the Joint Utilities also 

noted that defrost time should be 

dependent on system size to account for 

the greater surface area of larger units 

and suggested that the baseline defrost 

control strategy be a time-initiated, 

temperature-terminated scheme, which 

is the industry standard. (Heatcraft, No. 

0058.1 at pp. 3–4; Joint Utilities, No. 

0061.1 at p. 3) 

In response to comments received 

about defrost control, DOE’s analysis 

now applies a temperature-terminated 

defrost approach for all defrost control 

schemes (baseline or higher). The 

defrost cycle ends once the coil 

temperature reaches 45 °F. For the 

defrost design option, DOE is 

continuing to apply a generic defrost 

control that would reduce the number of 

defrosts per day. The magnitude of the 

reduction is set at 40 percent, which is 

less than the 50 percent level originally 

assumed in the preliminary analysis. 

DOE chose this reduced level because it 

would result in significant energy 

savings while still maintaining adequate 

defrost capability. Further details about 

the defrost control parameters are found 

in chapter 5 of the TSD. 

Floating Head Pressure 

In the preliminary analysis, DOE also 

considered floating head pressure as a 

design option. With floating head 

pressure, the compressor pressure and 

the saturated condensing temperature 

(SCT) float down to the minimum level 

at which the compressor can operate. 

DOE assumed that floating head 

pressure would allow the SCT to float 

down to 70 °F. DOE also assumed that 

the SCT would decrease at the same rate 

as the ambient temperature such that 

the system would maintain the same 

temperature difference (TD) between the 

SCT and the ambient air. This change 

resulted in a predicted reduction in 

energy consumption because 

compressors generally run more 

efficiently at a lower SCT. The capacity 

of the system was related to the SCT and 

the TD. 

Some interested parties commented 

on DOE’s assumptions relating to 

floating head pressure. Heatcraft 

disagreed with DOE’s assumption that 

the TD would be constant as SCT 

decreases and stated that the TD 

increases as SCT decreases. To illustrate 

its point, Heatcraft calculated the TD of 

a system at an SCT of 115 °F and again 

at an SCT of 70 °F and found that the 

ratio of the condenser TD between these 

two SCT conditions would be 

approximately 1.19, not 1.0 (where a 

ratio of 1.0 would correspond to no 

change in TD as SCT decreases). This 

value was calculated using the total heat 

of rejection (THR) of the condenser. 

(Heatcraft, No. 0058.1 at p. 4) The Joint 

Utilities had several comments relating 

to the implementation of floating head 

pressure. They recommended that DOE 

account for the additional fan power 

required for floating head pressure, and 

stated that varying the speed of 

condenser fans as part of a floating head 

pressure control has effects on the 

system such as more stable operation of 

the expansion valve and less likelihood 

of compressor damage due to liquid 

refrigerant reaching the compressor. 

(Joint Utilities, No. 0061.1 at pp. 6 and 

10) The Joint Utilities also identified 

two different head pressure control 

types that have an impact on projected 

energy savings: fan control or fan 

cycling and a condenser valve to 

maintain the minimum condensing 

temperature. (Joint Utilities, No. 0061.1 

at p. 10) Finally, the Joint Utilities 

pointed out that if a lower initial or 

baseline SCT value is assumed, the 

estimated savings for floating head 

pressure will be less. (Joint Utilities, No. 

0061.1 at p. 10) 

To account for the suggestions made 

by commenters, DOE has implemented 

changes to its NOPR analysis of floating 

head pressure. First, DOE investigated 

the control methods identified by the 

Joint Utilities. In the current model used 

for the NOPR analysis, fan modulation 

is implemented in the baseline to 

maintain a fixed head pressure. When 

floating head pressure is implemented, 

a valve and accompanying controls are 

added to maintain a minimum 

condensing temperature. Regarding the 

comments on fan power submitted by 

the Joint Utilities, DOE agrees that at 

lower ambient temperatures, the 


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required fan airflow is higher when 

floating head pressure is implemented 

because the TD is smaller. DOE’s 

current energy model calculates the fan 

power necessary to maintain adequate 

heat transfer when floating head 

pressure is implemented. DOE assumed 

that condenser fans would be 

modulated in the baseline; variable 

speed condenser fans are considered as 

a separate design option. DOE’s model 

calculates the energy savings of variable 

speed condenser fans with or without 

floating head pressure implemented. 

The energy model does not capture 

increased stability in the expansion 

valve or the reduced possibility of 

compressor damage because the energy 

model attempts to capture the 

performance as rated by the test 

procedure, and for the reasons stated in 

the test procedure final rule, the test 

procedure established by DOE is 

designed to rate only certain aspects of 

the equipment—e.g., AWEF and 

capacity. 76 FR 21580, 21597–21598 

(April 15, 2011). 

DOE also assumes that a system tested 

by the manufacturer would likely be a 

new system, which is unlikely to 

experience decreased stability in the 

expansion valve; therefore, DOE did not 

capture expansion valve stability in the 

energy model. The energy model also 

does not capture long-term compressor 

damage because DOE assumes the test 

procedure would be performed at the 

point of manufacture of the equipment, 

and would therefore not capture such 

damage to the compressor. Compressor 

replacement is, however, addressed in 

the life cycle cost analysis (see section 

IV.F.6). Any additional benefits that 

accrue due to reduced maintenance are 

also not captured in the engineering 

analysis. 

DOE also acknowledges the Joint 

Utilities’ observation that the savings for 

the floating head pressure option 

depends on the baseline SCT and DOE’s 

energy modeling confirms their 

assertion that the floating head pressure 

option would appear to save less energy 

if the baseline SCT were lower. 

However, DOE chose certain baseline 

SCT values for each class that would be 

realistic considering the equipment 

rating conditions, as explained in 

section IV.C.4.b. To address Heatcraft’s 

comment that TD would increase with 

decreasing SCT, DOE analyzed the total 

heat of rejection of sample systems 

using the specified temperatures in the 

test procedure and found an average TD 

ratio corresponding to each compressor 

type analyzed. DOE implemented the 

TD ratio in the engineering analysis. See 

chapter 5 of the TSD for more details on 

the floating head pressure design 

option. DOE requests comment on its 

assumptions and implementation of this 

option, particularly regarding the cost to 

implement various floating head 

pressure control schemes and the energy 

savings that would be achieved. 

Refrigeration Summary 

After considering all the comments it 

received on the design options, DOE is 

including the following design options 

in the NOPR analysis: 

• Higher efficiency compressors 

• Improved condenser coil 

• Higher efficiency condenser fan 

motors 

• Improved condenser and evaporator 

fan blades 

• Ambient sub-cooling 

• Evaporator and condenser fan 

control 

• Defrost control 

• Hot gas defrost 

• Head pressure control 

Each design option is explained in 

detail in chapter 5 of the TSD. 

6. Cost-Efficiency Results 

a. Panels and Doors 

In the preliminary analysis, DOE 

plotted total energy consumption in 

kilowatt-hours per day versus the 

increasing cost of representative walk-in 

envelopes. Because DOE is proposing to 

set component level standards, each of 

the three main products that make up 

walk-in envelopes have independent 

cost-efficiency curves. For panels, DOE 

measured the U-factor, a measure of 

thermal conductivity expressed in 

British thermal units per hour-square 

foot-Fahrenheit (Btu/h-ft2-F); that is, the 

heat conducted through the panel per 

unit time, per square foot of panel 

surface area, per degree Fahrenheit. A 

lower U-factor corresponds to less heat 

conducted through the panel, indirectly 

decreasing the energy use of the walkin because the refrigeration system does 

not have to expend additional energy to 

remove heat from the walk-in. DOE 

plotted the decrease in U-factor versus 

the increase in cost of a single panel. 

For non-display doors and display 

doors, DOE plotted energy consumption 

in kWh/day versus the increasing cost of 

an individual non-display door. For a 

more detailed description of the 

engineering analysis results, see 

appendix 5A of the TSD. 

b. Refrigeration 

In the preliminary analysis, DOE 

chose refrigeration system sizes that best 

represented the market, but did not 

attempt to match the refrigeration 

systems to any particular envelope in 

the engineering analysis. DOE received 

several comments on the preliminary 

analysis regarding matching the 

refrigeration system to the envelope 

size. American Panel suggested that, 

because of their interdependence, 

refrigeration and walk-in size should be 

analyzed together. (American Panel, 

Public Meeting Transcript, No. 0045 at 

p. 115) NEEA, NPCC, Heatcraft, and 

American Panel recommended that the 

refrigeration system size match the 

envelope size. (NEEA and NPCC, No. 

0059.1 at p. 9, Heatcraft, No. 0069.1 at 

p. 1, American Panel, No. 0048.1 at p. 

4) 

DOE is proposing to regulate the 

refrigeration system as an individual 

component in accordance with its 

proposed component-level approach, 

and is also analyzing the individual 

components of an envelope (panels and 

doors), rather than the entire envelope. 

For these reasons, DOE did not attempt 

to match refrigeration systems with any 

particular envelope size. Rather, DOE 

chose refrigeration system sizes for the 

analysis that capture the range of 

systems that might be used in a walkin. 

In the preliminary analysis, DOE 

plotted the cost-efficiency data points 

using normalized energy consumption 

for its engineering analysis. AHRI 

recommended using AWEF and 

commented that the normalized values 

favor design options, which, in its view, 

do not necessarily reduce energy 

consumption. The Joint Utilities 

believed that non-normalized values 

would be helpful to understand the 

analyses. (AHRI, No. 0055.1 at pp. 2–3; 

Joint Utilities, Public Meeting 

Transcript, No. 0045 at p. 171) 

Consistent with the test procedure final 

rule and AHRI’s suggestion, DOE is 

using AWEF to construct its costefficiency curves. See 76 FR 21597– 

21598, 10 CFR 431.302. 

In chapter 5, Appendix A of the 

preliminary TSD, DOE provided costefficiency curves for all the equipment 

classes. Numerous stakeholders 

requested that DOE provide more detail 

about the methodology behind the cost 

efficiency curves because they are 

concerned about the accuracy of these 

curves. (Emerson, Public Meeting 

Transcript, No. 0045 at p. 165; AHRI, 

Public Meeting Transcript, No. 0045 at 

p. 169 and No. 0055.1 at p. 2,4; 

Manitowoc, No. 0056.1 at p. 2 and 

Public Meeting Transcript, No. 0045 at 

p. 125) Additionally, Manitowoc 

suggested that a broader view of the 

industry’s costs and sizes is required to 

improve the accuracy of the results 

(Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 162) 

DOE appreciates the stakeholder 

comments and notes that it has updated 


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its initial cost-efficiency curves based 

on changes to its analysis. DOE has 

provided more detail in this NOPR and 

the NOPR TSD about the calculation 

methodology used in the engineering 

analysis, particularly due to the 

publication of the test procedure final 

rule. DOE also updated its analysis with 

the most recent pricing data related to 

the costs of materials and purchased 

parts and adjusted the projected energy 

savings of certain design options as 

detailed in section IV.C.5.b. 

c. Numerical Results 

Table IV–8, Table IV–9, Table IV–10, 

and Table IV–11 present cost-efficiency 

data for panels, display doors, nondisplay doors, and refrigeration systems, 

respectively. For refrigeration systems, 

because of the large number of analysis 

points, DOE presents results for only 

one type of system, DC.L.O, in this 

notice. See appendix 5A of the TSD for 

complete cost-efficiency results. 

TABLE IV–8—COST-EFFICIENCY RESULTS FOR PANELS

Class/size 

Efficiency level 

Baseline 1 2 3 4 5 6 

SP.M.SML ............. Cost [$] ................. $54 $58 $61 $67 $73 $86 $231 

U-factor [Btu/h-ft-F] 0.082 0.046 0.040 0.032 0.027 0.024 0.011 

SP.M.MED ............ Cost [$] ................. $153 $159 $165 $179 $192 $229 $615 

U-factor [Btu/h-ft-F] 0.061 0.043 0.038 0.030 0.025 0.024 0.011 

SP.M.LRG ............. Cost [$] ................. $240 $247 $256 $276 $296 $354 $951 

U-factor [Btu/h-ft-F] 0.056 0.042 0.037 0.030 0.025 0.024 0.011 

SP.L.SML .............. Cost [$] ................. $56 $61 $67 $73 $86 $231 ....................

U-factor [Btu/h-ft-F] 0.073 0.040 0.032 0.027 0.024 0.011 ....................

SP.L.MED ............. Cost [$] ................. $159 $165 $179 $192 $229 $615 ....................

U-factor [Btu/h-ft-F] 0.053 0.038 0.030 0.025 0.024 0.011 ....................

SP.L.LRG .............. Cost [$] ................. $249 $256 $276 $296 $354 $951 ....................

U-factor [Btu/h-ft-F] 0.050 0.037 0.030 0.025 0.024 0.011 ....................

FP.L.SML .............. Cost [$] ................. $85 $93 $97 $104 $111 $270 ....................

U-factor [Btu/h-ft-F] 0.071 0.041 0.036 0.030 0.025 0.018 ....................

FP.L.MED ............. Cost [$] ................. $176 $190 $195 $209 $222 $566 ....................

U-factor [Btu/h-ft-F] 0.059 0.039 0.035 0.029 0.024 0.015 ....................

FP.L.LRG .............. Cost [$] ................. $301 $322 $331 $353 $374 $973 ....................

U-factor [Btu/h-ft-F] 0.054 0.039 0.035 0.028 0.024 0.014 ....................

TABLE IV–9—COST-EFFICIENCY RESULTS FOR DISPLAY DOORS

Class/size 

Efficiency level 

Baseline 1 2 3 4 5 6 

DD.M.SML ............ Cost [$] ................. $277 $274 $340 $423 $544 $710 $1,375 

Energy Use [kWh/

day].

2.50 1.74 0.98 0.84 0.68 0.58 0.38 

DD.M.MED ............ Cost [$] ................. $357 $354 $420 $530 $651 $870 $1,751 

Energy Use [kWh/

day].

2.91 2.15 1.14 0.96 0.80 0.66 0.40 

DD.M.LRG ............ Cost [$] ................. $470 $478 $544 $692 $813 $1,108 $2,291 

Energy Use [kWh/

day].

3.76 2.78 1.43 1.18 0.99 0.81 0.46 

DD.L.SML ............. Cost [$] ................. $509 $506 $627 $793 $960 $1,375 ....................

Energy Use [kWh/

day].

5.22 4.34 4.14 2.73 2.02 1.66 ....................

DD.L.MED ............. Cost [$] ................. $643 $640 $761 $980 $1,202 $1,751 ....................

Energy Use [kWh/

day].

6.47 5.58 5.39 3.49 2.56 2.08 ....................

DD.L.LRG ............. Cost [$] ................. $831 $839 $1,135 $1,432 $1,553 $2,291 ....................

Energy Use [kWh/

day].

8.54 7.40 4.83 3.57 3.36 2.70 ....................

TABLE IV–10—COST-EFFICIENCY RESULTS FOR NON-DISPLAY DOORS

Class/size 

Efficiency level 

Baseline 1 2 3 4 5 6 7 8 9 

PD.M.SML ............. Cost [$] ................. $180 $184 $210 $214 $222 $273 $281 $487 $655 ............

Energy Use [kWh/ 

day].

0.30 0.27 0.22 0.22 0.21 0.17 0.16 0.04 0.02 ............

PD.M.MED ............ Cost [$] ................. $210 $214 $240 $245 $255 $306 $316 $522 $741 ............

Energy Use [kWh/ 

day].

0.32 0.28 0.24 0.23 0.22 0.18 0.17 0.05 0.03 ............

PD.M.LRG ............. Cost [$] ................. $265 $270 $296 $303 $316 $368 $381 $587 $904 ............


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TABLE IV–10—COST-EFFICIENCY RESULTS FOR NON-DISPLAY DOORS—Continued 

Class/size 

Efficiency level 

Baseline 1 2 3 4 5 6 7 8 9 

Energy Use [kWh/ 

day].

0.36 0.31 0.27 0.25 0.24 0.20 0.19 0.06 0.04 ............

PD.L.SML .............. Cost [$] ................. $235 $240 $291 $342 $351 $359 $425 $553 $728 ............

Energy Use [kWh/ 

day].

7.08 6.96 6.52 6.26 6.23 6.20 6.07 6.01 5.98 ............

PD.L.MED ............. Cost [$] ................. $265 $270 $322 $373 $383 $393 $459 $587 $814 ............

Energy Use [kWh/ 

day].

7.82 7.69 7.25 6.99 6.95 6.92 6.79 6.72 6.67 ............

PD.L.LRG .............. Cost [$] ................. $322 $328 $380 $431 $445 $459 $524 $653 $978 ............

Energy Use [kWh/ 

day].

9.03 8.88 8.43 8.18 8.11 8.07 7.94 7.88 7.79 ............

FD.M.SML ............. Cost [$] ................. $356 $362 $388 $398 $417 $469 $489 $694 $1,119 ............

Energy Use [kWh/ 

day].

0.39 0.35 0.30 0.28 0.26 0.22 0.21 0.08 0.05 ............

FD.M.MED ............ Cost [$] ................. $574 $581 $647 $662 $692 $738 $768 $860 $1,225 $1,899 

Energy Use [kWh/ 

day].

0.65 0.60 0.46 0.44 0.40 0.36 0.34 0.31 0.25 0.19 

FD.M.LRG ............. Cost [$] ................. $719 $727 $793 $813 $853 $898 $938 $1,029 $1,394 $2,296 

Energy Use [kWh/ 

day].

0.73 0.66 0.53 0.49 0.45 0.41 0.38 0.35 0.29 0.21 

FD.L.SML .............. Cost [$] ................. $416 $423 $474 $526 $546 $566 $632 $760 $1,194 ............

Energy Use [kWh/ 

day].

10.25 10.08 9.63 9.38 9.29 9.23 9.10 9.03 8.92 ............

FD.L.MED ............. Cost [$] ................. $679 $688 $753 $845 $875 $905 $997 $1,225 $1,911 ............

Energy Use [kWh/ 

day].

13.71 13.49 12.58 12.13 11.99 11.90 11.67 11.55 11.35 ............

FD.L.LRG .............. Cost [$] ................. $828 $838 $904 $995 $1,035 $1,075 $1,167 $1,394 $2,310 ............

Energy Use [kWh/ 

day].

15.62 15.36 14.45 14.00 13.81 13.69 13.45 13.34 13.06 ............

TABLE IV–11—COST-EFFICIENCY RESULTS FOR REFRIGERATION SYSTEMS

Class/size 

Efficiency level 

Baseline 1 2 3 4 5 6 7 8 9 10 11 12 

DC.L.O HER* 

6 kBtu ...........

Cost [$] ............... $1591 $1616 $1641 $1671 $1745 $1749 $1760 $1798 $1848 $1898 $2058 ............ ............

AWEF Btu/Wh .... 2.40 2.62 2.81 2.97 3.30 3.31 3.34 3.43 3.56 3.62 3.65 ............ ............

DC.L.OHER 9 

kBtu.

Cost [$] ............... $1720 $1745 $1770 $1800 $1876 $1881 $1919 $1969 $1980 $2144 $2194 ............ ............

AWEF Btu/Wh .... 2.91 3.10 3.27 3.47 3.86 3.87 3.96 4.07 4.09 4.38 4.44 ............ ............

DC.L.O SCR 

6 kBtu.

Cost [$] ............... $1838 $1863 $1888 $1918 $1992 $1996 $2034 $2084 $2095 $2250 $2300 ............ ............

AWEF Btu/Wh .... 2.86 3.14 3.39 3.70 4.07 4.09 4.24 4.44 4.48 4.79 4.89 ............ ............

DC.L.O SCR 

9 kBtu.

Cost [$] ............... $1944 $1969 $1999 $2024 $2100 $2105 $2143 $2193 $2204 $2381 $2531 $2581 ............

AWEF Btu/Wh .... 3.70 3.98 4.35 4.64 5.11 5.13 5.28 5.48 5.52 5.86 6.15 6.25 ............

DC.L.O SCR 

54 kBtu.

Cost [$] ............... $6938 $6968 $7018 $7068 $7188 $7288 $7312 $7362 $7512 $7594 $10312 $10337 $11062 

AWEF Btu/Wh .... 4.09 4.44 4.92 5.38 5.93 6.27 6.34 6.43 6.58 6.64 7.77 7.78 7.91 

DC.L.O SEM 

6 kBtu.

Cost [$] ............... $2095 $2120 $2145 $2175 $2248 $2253 $2291 $2341 $2352 $2402 $2555 ............ ............

AWEF Btu/Wh .... 2.47 2.69 2.90 3.15 3.48 3.50 3.60 3.74 3.77 3.84 3.93 ............ ............

DC.L.O SEM 

9 kBtu.

Cost [$] ............... $2270 $2295 $2320 $2350 $2426 $2430 $2468 $2518 $2666 $2677 $2727 ............ ............

AWEF Btu/Wh .... 2.78 2.96 3.12 3.40 3.77 3.78 3.86 3.96 4.28 4.30 4.36 ............ ............

DC.L.O SEM 

54 kBtu.

Cost [$] ............... $7776 $7806 $7856 $7906 $8006 $8129 $8208 $8258 $8340 $11254 $11720 $11804 ............

AWEF Btu/Wh .... 3.36 3.63 3.99 4.32 4.74 5.24 5.36 5.43 5.47 6.37 6.52 6.54 ............

DC.L.O SEM 

72 kBtu.

Cost [$] ............... $9772 $9802 $9877 $9952 $10075 $10175 $10225 $10304 $10427 $11091 $13999 $14083 ............

AWEF Btu/Wh .... 3.41 3.70 4.11 4.50 4.96 5.36 5.44 5.53 5.58 5.79 6.71 6.72 ............

* HER indicates a hermetic compressor, SCR indicates a scroll compressor, and SEM indicates a semi-hermetic compressor. 

D. Markups Analysis 

This section explains how DOE 

developed the distribution channel and 

supply chain markups to determine 

installed costs for the end-users of 

refrigeration systems and envelope 

components. 

In the preliminary analysis, DOE 

described different distribution 

channels for the two broadly defined 

segments of the WICF market: the food 

sales (grocery) segment and the food 

service segment for the purposes of 


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55822 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

calculating markups. In the food sales 

segment, the refrigeration systems are 

predominantly unit coolers connected 

to multiplex condensing systems. In the 

food service and convenience store 

market segment, the refrigeration 

systems are mostly dedicated 

condensing systems. DOE 

acknowledged that walk-in units may 

also be assembled in the field, with key 

components sourced from different 

vendors through different channels. 

However, in the preliminary analysis, 

DOE conducted the markups analysis on 

complete walk-in systems and did not 

apply separate markups for different 

components. Consequently, DOE 

assumed in the preliminary analysis 

that the refrigeration system and the 

envelope followed identical distribution 

channels even if they were 

manufactured by a different set of 

manufacturers. 

One interested party recommended 

that DOE include an additional 

distribution channel. Heatcraft 

commented that the refrigeration system 

manufacturers often sell directly to the 

envelope manufacturers, who integrate 

the refrigeration systems with the 

envelopes and then sell the assembled 

units. (Heatcraft, Public Meeting 

Transcript, No. 0045 at p. 187) Heatcraft 

identified this market segment as OEMs 

and observed that this important 

channel of distribution was not 

considered by DOE, even though 50 

percent of the refrigeration system 

business is distributed through the OEM 

market segment. 

The revised NOPR analysis uses 

component-level standards for specific 

envelope components and for the 

refrigeration systems. Because of this 

component-level standards approach, 

DOE conducts all the key analysis steps 

separately for the refrigeration systems 

and the selected envelope components 

in the NOPR analysis. As part of this 

approach, DOE includes a distinct OEM 

distribution channel in the markup 

analysis. Based on interviews with 

several manufacturers, DOE estimates 

that the percentage share of the 

aggregate shipments of refrigeration 

systems attributable to the OEM 

segment of the market is 55 percent for 

all dedicated condensing refrigeration 

systems, similar to the 50 percent share 

indicated by Heatcraft. 

Another interested party commented 

on the relative shares of the different 

market segments DOE identified. In the 

preliminary analysis, DOE estimated 

that for walk-ins with dedicated 

condensing units, 50 percent of 

aggregate sales were for the food service 

segment and the remaining 50 percent 

were for the convenience and small 

grocery stores segment. American Panel 

commented that for walk-in equipment 

sold with dedicated condensing 

equipment, the share of the food service 

segment across the two broad market 

segments should be 80 percent and the 

share of the convenience and small 

grocery stores segment should be 20 

percent. (American Panel, No. 0048.1 at 

p. 8) In the NOPR, DOE revised its 

shipment analysis as described in 

chapter 9 of the TSD and noted that for 

the walk-ins with dedicated condensing 

equipment, the relative shares for the 

food service segment and the 

convenience and small grocery stores 

segment are now 78 percent and 22 

percent, respectively, compared to 50 

percent each for these two segments 

estimated in the preliminary analysis. 

These new values closely match the 

percentage shares indicated by 

American Panel. 

Several interested parties commented 

on the shares of different distribution 

channels across the market segments 

that DOE previously applied. In the 

preliminary analysis, DOE indicated 

that the percentage share of the 

aggregate shipments of refrigeration 

systems through refrigeration 

wholesalers was 15 percent for 

multiplex equipment and 57.5 percent 

for dedicated condensing equipment on 

an average basis for all the market 

segments. Heatcraft stated that the 

percentage share of the aggregate 

shipments of refrigeration systems 

through the refrigeration wholesalers is 

50 percent. (Heatcraft, Public Meeting 

Transcript, No. 0045 at p. 284) Based on 

information gathered through interviews 

with manufacturers of refrigeration 

systems, DOE has revised its estimates 

for the percentage share of the aggregate 

shipments of refrigeration systems 

through wholesalers. For the NOPR, 

DOE revised these estimates to 42 

percent for dedicated condensing 

systems and 45 percent for the unit 

coolers connected to a multiplex 

condensing system. 

In the preliminary analysis, DOE 

assumed that the share of electronic 

commerce (E-commerce) resellers in the 

food service market for dedicated 

condensing systems is 10 percent. 

American Panel commented that this 

figure was too high and should be 1 

percent or, at most, 2 percent. 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 195 and No. 

0048.1 at p. 8) Manitowoc pointed out 

that E-commerce resellers often 

represent food service equipment 

distributors selling to territories outside 

the specific territory assigned to them 

by the manufacturer and that their sales 

could be considered distributor sales. In 

its view, if this aspect is considered, 

then the share of the E-commerce 

business estimated by DOE in the 

preliminary analysis is too high. 

(Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 195) NEEA and NPCC 

reinforced the observations made by 

American Panel and Manitowoc, and 

suggested that DOE adjust the markup 

analysis accordingly. (NEEA and NPCC, 

No. 0059.1 at p. 9) DOE agrees with 

Manitowoc’s observation that the Ecommerce share of total sales is 

essentially composed of sales through 

the distributor segment and, therefore, 

there is no need to identify this channel 

of distribution separately. As a result of 

this observation, DOE did not identify 

this as a separate distribution channel in 

the NOPR analysis. 

American Panel noted that the 

distribution channel shares described by 

DOE for walk-ins with dedicated 

condensing equipment sold in the food 

service market segment are accurate for 

the national accounts and distributors 

under the current economic situation, 

but it expected to see the market share 

of the national chains increase to 20 

percent with the economy improving in 

the next 2 to 3 years. (American Panel, 

Public Meeting Transcript, No. 0045 at 

p. 144) American Panel also pointed out 

that, for walk-ins with dedicated 

condensing equipment sold to the food 

service segment, the market share for 

contractors should be 5 percent instead 

of 10 percent. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 194) 

In the NOPR markup analysis, DOE has 

factored American Panel’s estimates and 

revised the corresponding market shares 

to 10 percent for the national chains and 

5 percent for the contractors. 

Regarding the values of the markup 

multipliers presented in chapter 6 of the 

preliminary TSD, several interested 

parties commented on the methodology 

for arriving at the multiplier. AHRI 

stated that, when multiple-stage 

markups (manufacturer, distributor, 

dealer, and contractor) are estimated 

separately and multiplied to estimate 

the overall markups, the errors in the 

different stages are compounded in the 

final result. (AHRI, No. 0055.1 at p. 3) 

AHRI suggested that DOE avoid 

compounding errors and instead use 

retail prices in the analysis. DOE notes 

that the current methodology of the 

markup analysis is standardized in 

DOE’s economic analysis in its energy 

conservation rulemaking activities. A 

retail price analysis is not feasible, 

because a representative sample of 

direct end-user prices is difficult to 

obtain from distributors and contractors 

because pricing data are considered 

business-sensitive. Furthermore, these 


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parties often use aggregate markups on 

the entire contract and separate 

markups for labor and/or equipment 

installations cannot be established. 

Therefore, DOE continues to use a 

markup analysis in this NOPR. 

Craig Industries commented that the 

mechanical contractor may not always 

purchase envelope components from the 

distributor, but can purchase them 

directly from the manufacturers and, 

therefore, the baseline markup for the 

mechanical contractor should not 

include the distributor markup. (Craig 

Industries, No. 0064.1 at p. 1) In the 

NOPR, DOE is proposing componentlevel standards for the envelope 

components and has revised the markup 

analysis accordingly. DOE assumes that 

the general contractors would purchase 

the envelope components directly from 

the manufacturer, and hence, did not 

include the markup percentages of the 

distributors in the estimated overall 

markups for sales through the contractor 

channel in the NOPR analysis. 

Regarding the values of the markup 

multipliers presented in chapter 6 of the 

preliminary TSD, American Panel 

commented that the markup multiplier 

values were too high and should 

correspond to approximately 10–12 

percent of the markup. (American Panel, 

Public Meeting Transcript, No. 0045 at 

p. 201) American Panel also questioned 

DOE’s assumption that the markup 

multipliers for unit coolers connected to 

multiplex systems would be 

substantially lower than the multipliers 

for the dedicated condensing 

equipment, when both types of 

equipment move through the same 

channel of distribution. (American 

Panel, No. 0048.1 at p. 8) In response to 

the first comment, DOE notes that the 

markup multipliers obtained in the 

revised analysis are consistent with the 

markup multipliers derived for other 

refrigeration products that often share 

the same distribution channels with 

walk-in coolers and freezers. Therefore, 

DOE considers the markup multipliers 

to be representative of the industry. 

Regarding the second comment, DOE 

notes that the overall markup 

multipliers depend not only on the 

channels through which the products 

are sold, but also on the relative shares 

of sales of the distribution channels. 

Because unit coolers connected to 

multiplex condensing systems are 

predominantly used in food sales, and 

a larger percentage of such equipment is 

sold directly to contractors, the 

equipment would be expected to have 

lower weighted average markup 

multipliers. The NOPR analysis uses 

weighted average baseline markup 

multipliers for multiplex and nonmultiplex equipment of 1.43 and 1.51, 

respectively. 

One interested party commented on 

DOE’s data sources. NEEA and NPCC 

recommended that, in view of the 

several comments DOE received on the 

markup analysis and ongoing 

restructuring and consolidation of the 

food retailing industry, DOE should 

obtain manufacturer assistance in recrafting the markup estimates for each 

distribution channel. (NEEA and NPCC, 

No. 0059.1 at p. 9) In the NOPR 

analysis, DOE has revised many of its 

estimates of the shares of individual 

channels based on comments received 

from interested parties. Given their 

general reliability, in estimating the 

markup multipliers in specific 

distribution channels, DOE uses data 

from trade associations and economic 

census data from the U.S. Census 

Bureau. The NOPR analysis relies on the 

most recently available data to derive 

the markup multipliers. 

Table IV–12 shows the overall 

weighted average baseline and 

incremental markups for sales of 

refrigeration systems and envelope 

components. Chapter 6 and appendix 

6A of the TSD provide complete details 

of the methodology and data used in the 

estimation of the markup multipliers. 

TABLE IV–12—OVERALL MARKUP

MULTIPLIERS FOR ALL EQUIPMENT

CLASSES

Equipment 

class 

Markup 

multipliers 

Baseline Incremental 

DC.M.I * ..... 1.51 1.19 

DC.L.I * 

DC.M.O * ... 1.51 1.19 

DC.L.O * 

MC.M ........ 1.43 1.25 

MC.L 

SP.M ......... 1.16 1.09 

SP.L 

DD.M ......... 1.41 1.29 

DD.L 

PD.M ......... 1.16 1.09 

PD.L 

FD.M ......... 1.16 1.09 

FD.L 

* For DC refrigeration systems, markups 

apply to both capacity ranges. 

E. Energy Use Analysis 

The energy use analysis estimates the 

annual energy consumption of 

refrigeration systems serving walk-ins 

and the energy consumption that can be 

directly ascribed to the selected 

components of the WICF envelopes. 

These estimates are used in the 

subsequent LCC and PBP analyses 

(chapter 8 of the TSD) and NIA (chapter 

10 of the TSD). 

In the preliminary analysis, DOE 

estimated the annual energy 

consumption for a complete theoretical 

walk-in consisting of an envelope and a 

matched refrigeration system, each at a 

specific efficiency level, using a set of 

assumptions for product loading, duty 

cycle, and other associated conditions. 

In the NOPR, DOE is proposing energy 

consumption standards separately for 

the refrigeration systems and a selected 

set of envelope components: Panels, 

non-display doors, and display doors. 

Consequently, DOE revised the 

methodology for estimating the annual 

energy consumption to reflect the new 

approach. 

A key change from the preliminary 

analysis methodology for estimating the 

annual energy consumption is that in 

the NOPR analysis, DOE is no longer 

matching the refrigeration systems to 

specific envelope sizes. The estimates 

for the annual energy consumption of 

each analyzed representative 

refrigeration system (see section IV.C.2) 

were reached by assuming that (1) the 

refrigeration system is sized such that it 

follows a specific daily duty cycle for a 

given number of hours per day at full 

rated capacity, and (2) the refrigeration 

systems produce no additional 

refrigeration effect for the remaining 

period of the 24-hour cycle. These 

assumptions are consistent with the 

present industry practice for sizing 

refrigeration systems. This methodology 

assumes that the refrigeration system is 

paired with an envelope that generates 

a load profile such that the rated hourly 

capacity of the paired refrigeration 

system, operated for the given number 

of run hours per day, produces adequate 

refrigeration effect to meet the daily 

refrigeration load of the envelope with 

a safety margin to meet contingency 

situations. Thus, the annual energy 

consumption estimates for the 

refrigeration system depends on the 

methodology adopted for sizing, the 

implied assumptions and the extent of 

oversizing. The sizing methodology 

adopted in this NOPR analysis is further 

discussed later in this section. 

For the envelopes, the estimates of 

product and infiltration loads are no 

longer used in estimating energy 

consumption in the analysis because 

these factors are not intended to be 

mitigated by any of the component 

standards. DOE calculated only the 

transmission loads across the envelope 

components under test procedure 

conditions and combined that with the 

annual energy efficiency ratio (AEER) to 

arrive at the annual refrigeration energy 

consumption associated with the 

specific component. AEER is a ratio of 

the net amount of heat removed from 


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the envelope in Btu by the refrigeration 

system and the annual energy consumed 

in watt-hours using bin temperature 

data specified in AHRI 1250–2009 to 

calculate AWEF. The annual electricity 

consumption attributable to any 

envelope component is the sum of the 

direct electrical energy consumed by 

electrically-powered sub-components 

(e.g., lights and anti-sweat heaters) and 

the refrigeration energy, which is 

computed by dividing the transmission 

heat load traceable to the envelope 

component by the AEER metric, where 

the AEER metric represents the 

efficiency of the refrigeration system 

with which the envelope is paired. 

In the preliminary analysis, DOE 

estimated aggregate refrigeration loads 

of three sizes of complete WICF 

envelopes in each of the four envelope 

classes (i.e., storage and display coolers 

and freezers.) In the NOPR, given the 

component-level approach, DOE 

estimated the annual energy 

consumption per unit of the specific 

envelope components by calculating the 

transmission load of the component 

over 24 hours under the test procedure 

conditions, and then calculating the 

annual refrigeration energy 

consumption attributed to that 

component by applying an appropriate 

AEER value. 

1. Sizing Methodology for the 

Refrigeration System 

In the preliminary analysis, DOE 

calculated the required size of the 

refrigeration system for a given envelope 

by assuming that the rated capacity of 

the refrigeration system would be 

adequate to meet the refrigeration load 

of a walk-in cooler or freezer during the 

high-load condition. The load profile of 

WICF equipment that DOE used broadly 

followed the load profile assumptions of 

the industry test procedure for 

refrigeration systems—AHRI 1250–2009, 

Standard for Performance Rating of 

Walk-In Coolers and Freezers (‘‘AHRI 

1250–2009’’). As noted earlier, that 

protocol was incorporated into DOE’s 

test procedure. 76 FR 33631 (June 9, 

2011). 

As a result, the DOE test procedure 

incorporates an assumption that, during 

a 24-hour period, a WICF refrigeration 

system experiences a high-load period 

of 8 hours corresponding to frequent 

door openings, product loading events, 

and other design load factors, and a lowload period for the remaining 16 hours, 

corresponding to a minimum load 

resulting from conduction, internal heat 

gains from non-refrigeration equipment, 

and steady-state infiltration across the 

envelope surfaces. During the high-load 

period, the ratio of the envelope load to 

the net refrigeration system capacity is 

70 percent for coolers and 80 percent for 

freezers. During the low-load period, the 

ratio of the envelope load to the net 

refrigeration system capacity is 10 

percent for coolers and 40 percent for 

freezers. The relevant load equations 

correspond to a duty cycle for 

refrigeration systems, where the system 

runs at full design point refrigeration 

capacity for 7.2 hours per day for 

coolers and 12.8 hours per day for 

freezers. Specific equations to vary load 

based on the outdoor ambient 

temperature are also specified. 

DOE received several comments on its 

duty cycle assumptions in the 

preliminary analysis. American Panel 

pointed out that the average envelope 

load hourly distributions for low and 

high loads used by DOE in the 

preliminary analysis represented a light 

loading condition and should be 

reversed, implying that a typical 

refrigeration system would experience 

16 hours of high load and 8 hours of low 

load per day, rather than DOE’s 

assumptions of 8 hours and 16 hours for 

high and low load, respectively. 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 212) For the 

restaurant market segment in particular, 

American Panel noted that the high-load 

and low-load periods would both 

typically be 12 hours each. (American 

Panel, No. 0048.1 at p. 8) American 

Panel also commented that its own heat 

load calculations use 18 hours of 

maximum refrigeration system run time 

for the freezers and noted that this is the 

industry standard. (American Panel, No. 

0048.1 at p. 3) Manitowoc and Heatcraft, 

however, agreed with DOE’s 

assumptions of the hourly load 

distributions for the high-load and lowload periods, which are consistent with 

AHRI 1250–2009. (Manitowoc, Public 

Meeting Transcript, No. 0045 at p. 215; 

Heatcraft, Public Meeting Transcript, 

No. 0045 at p. 213) NEEA and NPCC 

noted that the duty cycle assumptions 

for the energy use analysis were credible 

and did not recommend any changes to 

this part of the analysis. (NEEA and 

NPCC, No. 0059.1 at p. 10) AHRI also 

commented that the assumptions made 

by DOE to calculate the duty cycle are 

acceptable for the analysis. (AHRI, No. 

0055.1 at p. 3) Manitowoc noted that the 

envelope load assumptions are not 

supported with measurements from real 

life walk-in monitoring but are based on 

conservative sizing practices followed 

by the industry to ensure that even in 

worst-case situations, the walk-in will 

maintain the necessary temperature. 

(Manitowoc, No. 0056.1 at p. 3) 

In light of the comments received 

from American Panel on current 

industry sizing practices, and 

Manitowoc’s comment that actual duty 

cycles differ from the AHRI test 

procedure conditions, DOE tentatively 

concludes that the duty cycle 

assumptions of AHRI 1250–2009 should 

not be used for the sizing purposes 

because they may not represent the 

average conditions for WICF 

refrigeration systems for all applications 

under all conditions. DOE recognizes 

that test conditions are often designed to 

effectively compare the performance of 

equipment with different features under 

the same conditions. 

For the energy use analysis, DOE 

revisited the duty cycle issue and found 

that the current industry practice for 

sizing the refrigeration system is based 

on providing a 10 percent safety margin 

multiplier to the calculated aggregate 

refrigeration load over a 24-hour daily 

cycle and assuming a nominal run time 

of 16 hours for coolers and 18 hours for 

freezers for sizing the refrigeration 

system. DOE’s key assumption in the 

preliminary analysis of equating the 

refrigeration capacity to the high-box 

load is not practiced in the industry and 

DOE has made no attempt to model the 

peak load. The nominal run time varies 

only in special situations—such as 

when freezers use hot gas defrost or 

when the temperature of the evaporator 

coil is higher than 32 °F. Consequently, 

DOE adopted the industry practice 

described above for calculating the 

energy use and load characterization. 

In this NOPR, DOE proposes a 

nominal run time of 16 hours per day 

for coolers and 18 hours per day for 

freezers to calculate the capacity of a 

‘‘perfectly’’ sized refrigeration system. A 

fixed oversize factor is then applied to 

this size to calculate the actual runtime. 

With the oversize factor applied, DOE 

assumes that the runtime of the 

refrigeration system is 13.3 hours per 

day for coolers and 15 hours per day for 

freezers at full design point capacity. 

The reference outside ambient 

temperatures for the design point 

capacity conform to the AHRI 1250– 

2009 conditions incorporated into the 

DOE test procedure and are 95 °F and 

90 °F for refrigeration systems with 

outdoor and indoor condensers, 

respectively. 

DOE notes that the AHRI assumptions 

for high-load and low-load conditions 

were supported by some interested 

parties and acknowledges that the 

distribution of high-load and low-load 

hour assumptions could be relevant to 

the equipment energy consumption. 

DOE has observed, however, that the 

high-load situation is not taken into 

account by the industry in its standard 

sizing methods and would not represent 


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current industry practices. Thus, for the 

NOPR analysis, DOE has revised its 

sizing methodology to be consistent 

with its understanding of the current 

industry practice. DOE requests 

comment on the sizing methodology. 

2. Oversize Factors 

American Panel commented that 

DOE’s preliminary analysis assumptions 

regarding duty cycle and sizing 

conflicted with the prevalent practice in 

the industry, which resulted in 

considerable oversizing of the 

refrigeration systems when paired with 

a given envelope. Oversizing leads to 

higher first cost estimates for the 

refrigeration equipment and distorts the 

LCC and PBP results because the energy 

savings are not commensurate with the 

first costs. American Panel further 

commented that because the 

refrigeration systems examined as part 

of the preliminary analysis are poorly 

matched to the envelopes, no 

meaningful conclusion can be drawn 

from the accompanying LCC, PBP, and 

NIA results. (American Panel, No. 

0048.1 at p. 8 and p. 11) Regarding the 

annual energy calculations presented in 

chapter 7 of the TSD, American Panel 

did not believe that DOE properly 

matched the refrigeration systems and 

envelopes—which yielded an estimated 

8 hours or less of runtime per day. In 

its view, this preliminary estimate is 

incorrect. (American Panel, No. 0048.1 

at p. 9) American Panel also submitted 

additional documentation 

demonstrating its own methodology for 

matching the selected refrigeration 

system capacity to the estimated heat 

load of a walk-in expressed in Btu/h. 

(American Panel, No. 0048.1 at p. 9) 

DOE investigated further and found that 

the load calculation manuals and sizing 

software of several refrigeration system 

manufacturers supported American 

Panel’s recommendation on the 

approach to sizing. 

As stated previously, DOE observed 

that the typical and widespread 

industry practice for sizing the 

refrigeration system is to calculate the 

daily heat load on the basis of a 24-hour 

cycle and divide by 16 hours of runtime 

for coolers and 18 hours of runtime for 

freezers. DOE also found that it is 

customary in the industry to allow for 

a 10 percent safety margin to the 

aggregate 24-hour load resulting in 10 

percent oversizing of the refrigeration 

system. 

In the preliminary analysis, DOE 

considered a scaled mismatch factor in 

addition to the oversizing related to its 

duty cycle assumptions. DOE 

recognized that an exact match for the 

calculated refrigeration capacity may 

not be available for the refrigeration 

systems available in the market because 

most refrigeration systems are massproduced in discrete capacities. The 

capacity of the best matched 

refrigeration system is likely to be the 

nearest higher capacity refrigeration 

system available. This consideration led 

DOE to develop a scaled mismatch 

factor that could be as high as 33 

percent for the smaller refrigeration 

system sizes, and was scaled down for 

the larger sized units. In the preliminary 

analysis, DOE applied this mismatch 

oversizing factor to the required 

refrigeration capacity at the high-load 

condition to determine the required 

capacity of the refrigeration system to be 

paired with a given envelope. 

DOE received multiple comments 

regarding the mismatch factor. 

Manitowoc pointed out that the 

mismatch factors used by DOE in the 

preliminary analysis are high. DOE 

assumed that compressors are available 

only in capacity increments of 6000 

Btu/h but Manitowoc noted that 

compressors are available at capacity 

increments of 2000 Btu/h and 1500 Btu/ 

h for medium- and low-temperature 

systems, respectively. (Manitowoc, No. 

0056.1 at p. 3; Manitowoc, Public 

Meeting Transcript, No. 0045 at p. 220 

and p. 222) American Panel pointed out 

that the maximum mismatch factor 

could be 15 percent. (American Panel, 

Public Meeting Transcript, No. 0045 at 

p. 220) Heatcraft stated that DOE’s 

assumption that the sizes of 

refrigeration systems available in the 

market are at 0.5-ton intervals is not 

applicable for larger sized systems. For 

sizes from 5–10 horsepower, the 

compressors are available in 2.5- 

horsepower intervals, and for sizes from 

10–30 horsepower, compressors are 

available in 5-horsepower intervals. 

(Heatcraft, No. 0069.1 at p. 2) 

Based on these comments, DOE 

recalculated the mismatch factor 

because compressors for the lower 

capacity units are available at smaller 

size increments than what DOE 

assumed in the preliminary analysis. 

DOE also agrees with Manitowoc that 

for larger sizes, the size increments of 

available capacities are higher than size 

increments available for the lower 

capacities. DOE further noted as part of 

the revised analysis that under current 

industry practice, if the exact calculated 

size of the refrigeration system with a 10 

percent safety margin is not available in 

the market, the user may choose the 

closest matching size even if it has a 

lower capacity, allowing the daily 

runtimes to be somewhat higher than 

their intended values. The designer 

would recalculate the revised runtime 

with the available lower capacity and 

compare it with the target runtime of 16 

hours for coolers and 18 hours for 

freezers and, if this value falls within 

acceptable limits, then the chosen size 

of the refrigeration system is accepted 

and there is no mismatch oversizing. 

DOE further examined the data of 

available capacities in published 

catalogs of several manufacturers and 

noted that the range of available 

capacities depends on compressor type 

and manufacturer. Furthermore, because 

smaller capacity increments are 

available for units in the lower capacity 

range and larger capacity increments are 

available for units in the higher capacity 

range, the mismatch factor is generally 

uniform over the range of equipment 

sizes. For the NOPR, DOE tentatively 

concluded from these data that a scaled 

mismatch factor linked to the target 

capacity of the unit may not be 

applicable, but that the basic need to 

account for discrete capacities available 

in the market is still valid. To this end, 

DOE is now applying a uniform average 

mismatch factor of 10 percent over the 

entire capacity range of refrigeration 

systems. 

3. Product Load 

The NOPR analysis does not include 

an explicitly modeled product load to 

determine the annual energy 

consumption. Instead, the annual 

energy consumption estimates for the 

refrigeration systems are based on 

industry practice duty cycle 

assumptions. This approach does not 

require any explicit modeling of the 

product load. However, for the 

shipment analysis of refrigeration 

systems, DOE expressed annual 

shipments and stocks in terms of 

installed refrigeration capacity (Btu/h). 

The shipments of the refrigeration 

system were linked to the shipments of 

envelopes, which required DOE to 

estimate the required refrigeration 

capacity for the units shipped. DOE 

included several assumptions about 

product loads in these calculations. 

These assumptions are discussed in the 

relevant section on shipment (Section 

IV.G of this NOPR). 

4. Other Issues 

DOE received one comment on the 

issue of the interaction of building airconditioning systems with WICF 

systems installed within them. Ingersoll 

Rand stated that envelope 

improvements may not lead to 

significant energy savings because the 

load on the refrigeration systems of the 

WICF unit would be replaced by the 

load on the building air-conditioning 

system. DOE did not account for the 


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difference in overall energy use that 

could be directly attributed to the 

improvement of envelope components 

on the whole building cooling load and, 

correspondingly, any space-cooling 

energy impacts. At the same time, any 

envelope component improvements 

may also result in a decrease in the use 

of heating energy within the buildings. 

This impact on building heating and 

cooling loads would only occur for 

WICF units located indoors. The relative 

cooling-energy-use penalty to heatingenergy-use benefit is a function of the 

climate of the region in which the 

building is located, the building type 

and size, and the placement of the WICF 

units within the building. The relative 

monetary benefits are also a function of 

the relative heating and cooling fuel 

costs. The quantification of the relative 

benefits impact would have required an 

extensive analysis of building climatecontrol performance, which is both 

unnecessary and outside the scope 

framed by Congress. 

For the refrigeration systems, DOE 

calculated the annual energy 

consumption for all six classes of 

refrigeration systems at various capacity 

points with all available compressor 

options and at all efficiency levels for 

which results of engineering analysis 

were available. The annual energy 

consumption results were used as 

inputs to the LCC and PBP analyses. 

Based on the results of the LCC analysis, 

DOE selected the most cost-efficient 

combination of compressors and other 

components at a given AWEF level for 

a specific capacity point. Fourteen 

efficiency options were selected from 

the entire range of available AWEF 

values for each capacity point analyzed. 

To simplify further analysis, however, 

DOE chose two points from a set of four 

or five capacity points in each of the 

four dedicated condensing equipment 

classes, and one for each of the two 

multiplex condensing equipment 

classes. DOE used the shipment data to 

derive a shipment weighted AEER value 

for each TSL option for the refrigeration 

system. For the envelope components, 

DOE estimated the associated 

refrigeration energy at each of the TSL 

options and each level of efficiency of 

the components. The units of analysis 

were the unit area for the panels and 

each whole door for the doors. DOE 

added the direct electrical energy 

consumed for each of the doors at 

different efficiency levels to the 

refrigeration energy to arrive at the total 

annual energy consumption. The annual 

energy consumption results for the 

components were used as inputs to the 

LCC and PBP analyses for the 

components. Chapter 7 of the TSD 

shows the annual average energy 

consumption estimates by equipment 

class and efficiency level for both the 

refrigeration system and the 

components. 

F. Life-Cycle Cost and Payback Period 

Analyses 

DOE conducts LCC and PBP analyses 

to evaluate the economic impacts of 

potential energy conservation standards 

for walk-ins on individual consumers— 

that is, buyers of the equipment. As 

stated previously, DOE adopted a 

component-based approach for 

developing performance standards for 

walk-in coolers and freezers. 

Consequently, the LCC and PBP 

analyses were conducted separately for 

the refrigeration system and the 

envelope components: panels, nondisplay doors, and display doors. 

The LCC is defined as the total 

consumer expense over the life of a 

product, consisting of purchase, 

installation, and operating costs 

(expenses for energy use, maintenance, 

and repair). To calculate the operating 

costs, DOE discounts future operating 

costs to the time of purchase and sums 

them over the lifetime of the product. 

The PBP is defined as the estimated 

number of years it takes consumers to 

recover the increased purchase cost 

(including installation) of a more 

efficient product. The increased 

purchase cost is derived from the higher 

first cost of complying with the higher 

energy conservation standard. DOE 

calculates the PBP by dividing the 

increase in purchase cost (normally 

higher) by the change in the average 

annual operating cost (normally lower) 

that results from the standard. 

NEEA and NPCC suggested that, when 

estimating equipment lifetimes, DOE 

should consider both the economic and 

physical lifetimes of WICF equipment. 

(NEEA and NPCC, No. 0559.1 at p. 11) 

The physical lifetime refers to the 

duration before the equipment fails or is 

replaced, whereas the economic lifetime 

refers to the duration before the walk-in 

cooler and freezer equipment is taken 

out of service because the owner is no 

longer in business. In its energy 

conservation standards rulemakings, 

DOE does not typically consider the 

change of ownership of a distressed 

property due to business failure or 

insolvency of the first owner. The 

underlying assumption in this approach 

is that the higher efficiency equipment 

would continue to serve over its 

physical lifetime irrespective of 

ownership changes. Interested parties 

commented, however, that, in the case 

of walk-ins, the economic lifetime could 

be significantly lower. Owners at high 

risk of business failure or insolvency 

would be less likely to buy higher 

efficiency equipment because they 

likely would not see the long-term life 

cycle benefits of energy savings. 

In response to these comments, DOE 

attempted to include alternative Weibull 

probability distributions in the NOPR 

analysis to capture the effects of a 

reduced economic lifetime of WICF 

equipment for small restaurants, but due 

to the increased complexity resulting 

from the component-level approach and 

lack of data on reduced lifetimes on 

account of change of ownership of walkin equipment, DOE did not incorporate 

a shorter restaurant sector economic 

lifetime in the NOPR life cycle cost 

model. In many, if not most, cases when 

there is a change in ownership, 

equipment is not disassembled, but is 

sold ‘‘as is.’’ 

For any given efficiency level, DOE 

measures the PBP and the change in 

LCC relative to the base-case equipment 

efficiency levels. The base-case estimate 

reflects the market without new or 

amended energy conservation 

standards. For walk-ins, the base-case 

estimate assumes that newly 

manufactured walk-in equipment 

complies with the existing EPCA 

requirements and either equals or 

exceeds the efficiency levels achievable 

by EPCA-compliant equipment. Inputs 

to the economic analyses include the 

total installed operating, maintenance, 

and repair costs. 

Inputs to the calculation of total 

installed cost include the cost of the 

product—which consists of 

manufacturer costs, manufacturer 

markups, distribution channel markups, 

and sales taxes—and installation costs. 

Inputs to the calculation of operating 

expenses include annual energy 

consumption, energy prices and price 

projections, repair and maintenance 

costs, product lifetimes, discount rates, 

and the year that compliance with 

standards is required. DOE created 

probability distributions for product 

lifetime inputs to account for their 

uncertainty and variability. 

DOE developed refrigeration and 

envelope component spreadsheet 

models used for calculating the LCC and 

PBP. Chapter 8 of the TSD and its 

appendices provide details on the 

refrigeration and envelope 

subcomponent spreadsheet models and 

on all the inputs to the LCC and PBP 

analyses. 

Table IV–13 summarizes DOE’s 

approach and data used to derive inputs 

to the LCC and PBP calculations for 

both the preliminary TSD and the 

changes made for today’s NOPR. The 


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subsections that follow discuss the 

initial inputs and methods and the 

changes DOE made for the NOPR. 

For refrigeration systems, DOE 

analyzed all possible compressor 

technology options available for a given 

capacity of the refrigeration system. 

From the results of the individual 

compressor technology LCC analysis, 

DOE developed LCC savings plots in 

which the LCC savings over the LCC 

cost at the lowest total installed price 

option was plotted against the 

refrigeration system efficiency metric 

(AWEF). The LCC savings plots for the 

individual compressor technologies 

were superimposed into a single plot. A 

full range of optimal technology options 

were obtained by choosing the 

compressor technology available from 

the suite of available technologies that 

can reach a given efficiency level with 

the highest calculated LCC savings. The 

series of technology choices over the 

entire range of AWEF values from 

baseline to the highest achievable 

efficiency level obtained in this manner 

comprise the optimal path in 

developing higher efficiency equipment. 

TABLE IV–13—SUMMARY OF INPUTS AND METHODS IN THE LCC AND PBP ANALYSIS * 

Inputs Preliminary analysis Changes for the NOPR 

Installed Costs 

Equipment Cost ........... Derived by multiplying manufacturer cost by 

manufacturer and retailer markups and 

sales tax, as appropriate.

Included factor for estimating price trends due to manufacturer experience. 

Installation Costs .......... Based on RS Means Mechanical Cost Data 

2009. Assumed no change with efficiency 

level.

Based on RS Means Mechanical Cost Data 2012. Assumed no 

change with efficiency level. 

Operating Costs 

Annual Energy Use ...... DOE calculated the average annual energy 

use for each WICF envelope class matched 

with outdoor condenser systems using a 

load profile described in AHRI 1250–2009 

(8 hours of high load and 16 hours of low 

load per day).

Daily load profile of the refrigeration system revised to 13.3 hours 

runtime per day for coolers and 15 hours for freezers, at full rated 

capacity and at outside air temperatures corresponding to the reference rating temperatures. 

Energy Prices ............... EIA (Energy Information Administration). Form 

EIA–861 for 2006.

Source for Commercial and Industrial Retail Prices of Electricity: 

Form EIA–826 Database Monthly Electric Utility Sales and Revenue Data (EIA–826 Sales and Revenue Spreadsheets). 

www.eia.doe.gov/cneaf/electricity/page/eia826.html. Accessed September 30, 2012. 

Energy Price Trends .... Forecasted using AEO2009 price forecasts .... Forecasts updated using AEO2013. 

Repair and Maintenance Costs.Annualized repair and maintenance costs of 

the combined system were derived from RS 

Means 2009 walk-in cooler and freezer 

maintenance data. Doors and refrigeration 

systems were replaced during the lifetime.

Revised to RS Means 2012 walk-in cooler and freezer maintenance 

data and maintenance data; maintenance and repair costs for the 

refrigeration system and the envelope components were individually estimated. 

Present Value of Operating Cost Savings 

Equipment Lifetime ...... Based on manufacturer interviews. Variability: 

characterized using Weibull probability distributions.

Revised to reflect stakeholder comments. 

Discount Rates ............. Based on the 2009 commercial refrigeration 

equipment final rule (72 FR 1092); vary 

across commercial building types.

Based on Damodaran Online, October 2012. 

Compliance Date ......... 2015 .................................................................. 2017. 

* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the TSD. 

1. Equipment Cost 

To calculate consumer equipment 

costs, DOE multiplied the MSPs from 

the engineering analysis by the supplychain markups described above (along 

with sales taxes). DOE used different 

markups for baseline products and 

higher efficiency products because, as 

discussed previously, DOE applies an 

incremental markup to the MSP 

increase associated with higherefficiency products. 

On February 22, 2011, DOE published 

a notice of data availability (NODA, 76 

FR 9696) stating that DOE may consider 

improving its regulatory analysis by 

addressing equipment price trends. 

Consistent with the NODA, DOE 

examined historical producer price 

indices (PPI) for refrigeration equipment 

in general and found both positive and 

negative short-term real price trends. 

Over the historical long term DOE found 

slightly negative time real price trends. 

Therefore, DOE assumes in its price 

forecasts for this NOPR that the real 

prices of refrigeration equipment 

decrease slightly over time. DOE 

performed a sensitivity analysis of the 

NPV results for refrigeration equipment 

to the observed range of uncertainty in 

this long term price trend. DOE 

projected the price of the panels and 

doors using constant real 2012$ prices 

(See chapter 8 and chapter 10 of the 

TSD). DOE is aware that there have been 

significant changes in both the 

regulatory environment and equipment 

technologies during this period that 

create analytical challenges for 

estimating longer-term product price 

trends from the product-specific PPI 

data. DOE performed price trend 

sensitivity calculations to examine the 

dependence of the analysis results on 

different analytical assumptions. A 

more detailed discussion of price trend 

modeling and calculations is provided 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
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17The spreadsheet tool that DOE used to conduct 

the LCC and PBP analyses allows user0s to select 

price forecasts from either AEO’s High Economic 

Growth or Low Economic Growth Cases. Users can 

thereby estimate the sensitivity of the LCC and PBP 

results to different energy price forecasts. 18U.S. Energy Information Administration. 

Annual Energy Outlook 2013. May 2013. U.S. 

Energy Information Administration: Washington, 

DC. 

in Appendix 8D of the TSD. DOE invites 

comment on methods to improve its 

equipment price forecasting, as well as 

any data supporting alternate methods. 

2. Installation Cost 

Installation cost includes labor, 

overhead, and any miscellaneous 

materials and parts needed to install the 

equipment. For the preliminary 

analysis, DOE derived baseline 

installation costs for walk-in coolers and 

freezers from data in RS Means 

Mechanical Cost Data 2009. 

DOE estimated installation costs 

separately for panels, non-display doors, 

and display doors. Installation costs for 

panels were calculated per square foot 

of area while installation costs for nondisplay doors were calculated per door. 

Display door installation costs were 

omitted and assumed to be included in 

the panel installation costs for display 

walk-ins. DOE assumed that display 

doors are either installed by the 

assembler or manufacturer of the walkin unit, and the installation costs for the 

display doors are included in the 

‘‘mark-up’’ amounts for the OEM 

channel. 

For the NOPR analysis, DOE included 

refrigeration system component 

installation costs based on RS Means 

Mechanical Cost Data 2012. 

Refrigeration system installation costs 

included separate installation costs for 

the condensing unit and unit cooler. 

American Panel commented that these 

units are installed simultaneously by 

the same installation crew and quoted 

as a combined price. (American Panel, 

Public Meeting Transcript, No. 0045 at 

p. 246 and No. 0048.1 at p. 9) RS Means 

2012 provides these installation costs 

separately, although the installation 

activities may be performed by the same 

crew. DOE proposes to be consistent 

with the approach of the cost data 

source because this approach permits 

one to estimate the installation costs of 

many combinations of unit coolers and 

condensing units. 

In the preliminary analysis, DOE did 

not distinguish between installation 

costs for indoor and outdoor systems. 

Manitowoc stated that indoor and 

outdoor systems would likely incur 

different installation costs. (Manitowoc, 

Public Meeting Transcript, No. 0045 at 

p. 245) Installation cost differences 

between indoor and outdoor condensing 

units were not reported in the RS Means 

data because the costs shown are based 

only on unit capacity. DOE assumed 

that the installation costs reported in the 

RS Means data are based on a weighted 

average of outdoor and indoor units— 

accordingly, DOE used identical 

installation costs for indoor and outdoor 

condensing units. 

3. Annual Energy Consumption 

To estimate the annual energy 

consumption, DOE assumed that the 

installed refrigeration capacity is 20 

percent larger than the refrigeration load 

calculated in the sizing methodology. 

The prevailing industry practice is to 

recommend that the rated capacity for 

refrigeration equipment selection 

includes a 10 percent ‘‘safety factor’’. 

DOE chose to use a somewhat higher 

oversizing factor to account for the 

differences between the sizes calculated, 

using load estimation software 

programs, and the discrete sizes 

available in the market (that is, the 

mismatch factor). To determine annual 

energy consumption, DOE calculated, 

using the industry practice described 

above, that a refrigeration system with 

the selected oversizing factor would be 

required to run 13.3 hours per day for 

coolers and 15 hours per day for freezers 

at full rated capacity at the reference 

outside air temperatures to meet the 

aggregate refrigeration load of the paired 

walk-in envelope. These time periods 

were determined from DOE’s sizing 

methodology, as discussed in section 

IV.E.1. DOE used reference temperatures 

of 90 °F and 95 °F for indoor and 

outdoor condensing refrigeration 

systems, respectively, which is 

consistent with the standard rating 

conditions incorporated by DOE from 

AHRI 1250–2009. 

4. Energy Prices 

DOE calculated average commercial 

electricity prices using Form EIA–826 

Database Monthly Electric Utility Sales 

and Revenue Data (EIA–826 Sales and 

Revenue Spreadsheets) 

(www.eia.doe.gov/cneaf/electricity/

page/eia826.html; accessed September 

30, 2012). DOE calculated an average 

national commercial price by (1) 

estimating an average commercial price 

for each utility by dividing the 

commercial revenues by commercial 

sales; and (2) weighting each utility by 

the number of commercial consumers it 

served in that state, across the nation. 

For the preliminary TSD, DOE used the 

electricity price data from 2009. DOE 

updated the NOPR analysis using 2012 

data. 

5. Energy Price Projections 

To estimate energy prices in future 

years for the preliminary TSD, DOE 

multiplied the average state energy 

prices described above by the forecast of 

annual average commercial energy price 

indices developed in the Reference Case 

from AEO2013, which forecasted prices 

through 2040.17 AHRI supported DOE’s 

approach for estimating current and 

future energy prices. (AHRI, No. 0055.1 

at p. 3) DOE did not change its general 

approach, but today’s NOPR analysis 

updates the initial energy price forecasts 

using AEO2013, which has an end year 

of 2035.18 To estimate the price trends 

after 2035, DOE used the average annual 

rate of change in prices from 2026 to 

2035. 

6. Maintenance and Repair Costs 

DOE calculated both maintenance and 

repair costs for the analysis. 

Maintenance costs are associated with 

maintaining the equipment operation, 

whereas repair costs are associated with 

repairing or replacing components that 

have failed in the refrigeration system 

and the envelope (i.e. panels and doors). 

In the preliminary analysis, DOE 

considered only general maintenance 

costs (e.g., checking and maintaining 

refrigerant charge levels, checking 

settings, and cleaning heat exchanger 

coils) and lighting maintenance 

activities. The NOPR analysis applies 

the same lighting maintenance 

assumptions for display doors with 

lights as DOE previously applied during 

the preliminary analysis phases. The 

remaining data on general maintenance 

for an entire walk-in were apportioned 

between the refrigeration system and the 

envelope doors. Based on the 

descriptions of maintenance activities in 

the RS Means 2012 Facilities 

Maintenance and Repair Cost Data 

(available on CD–ROM) and 

manufacturer interviews, DOE assumed 

that the general maintenance associated 

with the panels is minimal and did not 

include any maintenance costs for 

panels in its analysis. RS Means 2012 

data provided general maintenance 

costs for display and storage walk-ins. 

In response to this approach, 

American Panel suggested that DOE 

contact the Commercial Food 

Equipment Service Association (CFESA) 

to obtain additional maintenance and 

repair information. (American Panel, 

No. 0048.1 at p. 8) At American Panel’s 

recommendation, DOE contacted 

CFESA, who explained that they did not 

have the information requested. 

Of the total annual maintenance costs 

for a walk-in unit, which ranges from 

$170–$262, DOE assumed $150 would 


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be spent on the refrigeration system and 

the rest would be spent on the display 

and passage doors of the envelope. DOE 

made this assumption as part of its 

preliminary analyses based on 

comments and research that pointed to 

this value as the likely amount that 

would need to be expended to cover 

refrigeration system-related costs. 

Maintenance costs were assumed to be 

the same across small, medium, and 

large door sizes in the case of both nondisplay doors and display doors. (DOE 

derived the envelope-related costs as the 

difference between the total 

maintenance costs for a walk-in and the 

assumed maintenance costs for the 

refrigeration system.) As stated 

previously, annual maintenance costs 

for the envelope wall and floor panels 

were assumed to be negligible and were 

not considered. 

Interested parties commented on 

maintenance costs associated with 

refrigerant leakage and refrigerant 

charge. Emerson stated that DOE’s 

estimated maintenance costs should 

account for higher refrigerant costs due 

to higher leakage rates and other issues 

in systems with higher refrigerant 

charge. (Emerson, Public Meeting 

Transcript, No. 0045 at p. 238) However, 

Emerson also commented that higher 

refrigerant costs could lead to the use of 

refrigerant leakage-reduction devices 

that offset the increased repair costs due 

to higher refrigerant charge and loss. 

(Emerson, Public Meeting Transcript, 

No. 0045 at p. 239) DOE did not receive 

any data for refrigeration maintenance 

costs, but based on the comments from 

Emerson, DOE assumes as part of the 

NOPR analysis that the $150 

maintenance cost for a refrigeration 

system would include expenses related 

to refrigerant charge maintenance costs. 

DOE seeks data from interested parties 

on refrigerant charge maintenance costs 

applicable to walk-ins. 

Other interested parties commented 

on potential climate change legislation. 

AHRI suggested that DOE study the 

impact of climate change legislation on 

the future availability and price of HFC 

refrigerants. (AHRI, No. 0055.1 at p. 3) 

Emerson also said that any future capand-trade bill would increase refrigerant 

costs significantly. (Emerson, Public 

Meeting Transcript, No. 0045 at p. 238) 

NEEA and NPCC suggested that 

refrigerant leakage and climate change 

responses should be evaluated in a 

manner that seeks to reduce refrigerant 

leakage rather than focusing solely on 

managing refrigerant replacement costs, 

particularly since maintenance costs are 

rising. (NEEA and NPCC, No. 0059.1 at 

p. 10) DOE acknowledges the concerns 

of interested parties regarding the effect 

of climate change legislation on 

refrigerant leakage and refrigerant costs. 

DOE does not speculate on pending 

legislation, which is outside the scope 

of this rulemaking. 

DOE also updated its methodology for 

determining repair costs for the NOPR 

in response to earlier comments. In the 

preliminary analysis, DOE assumed that 

both the unit cooler and the condensing 

unit of the refrigeration system are 

replaced when the refrigeration system 

fails. Master-Bilt commented that 

repairing a failed refrigeration system 

typically would require replacement of 

the compressors, not the entire system, 

and that approximately five percent of 

refrigeration systems would require a 

compressor replacement during a 10- 

year span. (Master-Bilt, Public Meeting 

Transcript, No. 0045 at p. 287) 

American Panel agreed and noted that, 

when a refrigeration system fails the 

entire refrigeration system is not 

typically replaced; rather, only 

compressors or fan motors are replaced. 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 11) After 

carefully considering these comments, 

DOE assumed for the NOPR analysis 

that 5 percent of systems require 

compressor replacement and 10 and 15 

percent of systems require fan motor 

replacement for evaporators and 

condensers, respectively, over the 

lifetime of the system. Aftermarket 

prices for fan motors and compressors 

were obtained from data collected 

during the engineering analysis and 

multiplied by a trade channel markup. 

DOE estimated installation costs using 

the RS Means Mechanical Cost Data 

2012 and calculated the total repair cost 

per occasion of replacement. DOE then 

calculated the annualized repair costs 

by multiplying the discounted total 

replacement cost per occasion by the 

replacement lifetime percentage. 

Under this approach, the NOPR 

analysis factored repair costs for lighting 

repairs pertaining to the lighting of the 

display doors. Data from the RS Means 

Electrical Cost Data 2012 were used to 

obtain the labor installation cost for 

lighting replacements. For refrigeration 

systems, DOE observed that estimated 

repair costs often increased with 

increasing efficiency levels, particularly 

for higher-efficiency compressors and 

fan motors. 

In the preliminary analysis, DOE 

assumed that annualized maintenance 

and repair costs were constant across all 

efficiency levels. Manitowoc and 

Master-Bilt stated that maintenance and 

repair cost increases across efficiency 

levels should not be negligible because 

more efficient equipment is more 

complex and may have design options 

that lead to the incorporation of 

additional or more expensive parts, 

which would cost more to maintain and 

replace. (Manitowoc, Public Meeting 

Transcript, No. 0045 at p. 241; MasterBilt, No. 0046.1 at p. 1) Heatcraft agreed 

that maintenance and repair costs may 

increase with higher efficiency levels, 

stating that more efficient equipment 

would incur higher maintenance and 

repair costs because higher efficiency 

evaporator and condenser coils are 

larger and heavier, making them more 

difficult and costly to maintain. 

(Heatcraft, No. 0069.1 at p. 1) AHRI 

stated that larger evaporator and 

condenser coils require more refrigerant 

and concluded that the maintenance 

and cost repair differences across 

efficiency levels are evident. (AHRI, No. 

0055.1 at p. 3 and 4) NEEA and NPCC 

stated, however, that there are no data 

available to support the contention that 

the complexity of electronics systems 

used in the controls of higher efficiency 

equipment leads to higher maintenance 

costs. (NEEA and NPCC, No. 0059.1 at 

p. 10) 

In the NOPR analysis, DOE 

considered these comments and 

examined whether each design option 

would have higher maintenance and 

repair costs associated with it. As stated 

earlier, DOE agreed with comments 

made by Master-Bilt and American 

Panel on repair costs and found that 

certain design options that entail 

substitution of either evaporator and 

condenser fan motors or higher 

efficiency compressors would likely 

incur higher maintenance and repair 

costs because of the higher cost of these 

components. The NOPR analysis 

accounts for these observations. In 

summary, DOE believes that repair costs 

will increase with efficiency level 

whereas all non-lighting maintenance 

costs will not increase with efficiency 

level. 

7. Product Lifetime 

In the preliminary analysis, DOE 

estimated an average product lifetime of 

15 years for envelopes and 7 years for 

refrigeration systems. The NOPR 

analysis alters this approach by 

estimating lifetimes for the individual 

components analyzed, instead of the 

entire envelope. DOE estimated an 

average lifetime of 15 years for panels 

and 14 years for display and nondisplay doors. DOE also revised the 

average refrigeration system lifetime to 

12 years. Weibull distributions were 

derived around average lifetime 

estimates to obtain specific failure rates 

at each year of equipment life. See 

chapter 8 of the NOPR TSD for further 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55830 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

19Harris, R.S. Applying the Capital Asset Pricing 

Model. UVA–F–1456. Available at SSRN: http://

ssrn.com/abstract=909893. 

details on the method and sources DOE 

used to develop product lifetimes. 

8. Discount Rates 

In calculating LCC, DOE applies 

discount rates to estimate the present 

value of future operating costs. DOE did 

not have sufficient information in 

preparing its preliminary analysis to 

derive discount rates for walk-ins. 

Instead, DOE used discount rates from 

the 2009 commercial refrigeration 

equipment final rule as a surrogate to 

approximate the rates that would apply 

to walk-ins. 72 FR at 1123 (January 9, 

2009). For the NOPR, DOE derived the 

discount rates for the walk-in cooler and 

freezer equipment analysis by 

estimating the cost of capital for a large 

number of companies similar to those 

that could purchase walk-in cooler and 

freezer equipment and then sampling 

them to characterize the effect of a 

distribution of potential customer 

discount rates. The cost of capital is 

commonly used to estimate the present 

value of cash flows to be derived from 

a typical company project or 

investment. Most companies use both 

debt and equity capital to fund 

investments, so their cost of capital is 

the weighted average of the cost to the 

company of equity and debt financing. 

Average discount rates (real) in these 

updated analyses by service building 

type are as follows: 

• Grocery: 3.7 percent 

• Food service: 3.9 percent 

• Convenience Store: 5.0 percent 

• Restaurant: 6.2 percent 

• Other Food Service: 3.8 percent 

DOE estimated the cost of equity 

financing by using the Capital Asset 

Pricing Model (CAPM).19 The CAPM, 

among the most widely used models to 

estimate the cost of equity financing, 

assumes that the cost of equity is 

proportional to the amount of 

systematic risk associated with a 

company. The cost of equity financing 

tends to be high when a company faces 

a large degree of systematic risk, and it 

tends to be low when the company faces 

a small degree of systematic risk. 

See chapter 8 of the TSD for further 

details on the development of 

commercial discount rates. 

9. Compliance Date of Standards 

EPCA prescribes that DOE establish 

performance-based standards for walkins by 2012. (42 U.S.C. 6313(f)(4)(A)) 

The standards apply to equipment 

manufactured beginning on the date 3 

years after the final rule is published 

unless DOE determines, by rule, that a 

3-year period is inadequate, in which 

case DOE may extend the compliance 

date for that standard by an additional 

2 years. (42 U.S.C. 6314(f)(4)(B)) In the 

absence of any information indicating 

that 3 years is inadequate, DOE 

proposes a compliance date for the 

standards of 2017. Therefore, DOE 

calculated the LCC and PBP for walk-in 

coolers and freezers under the 

assumption that compliant equipment 

would be purchased in the year when 

compliance with the new standard is 

required—2017. DOE seeks comments 

and information on the adequacy of the 

3-year compliance date. 

10. Base-Case and Standards-Case 

Efficiency Distributions 

To accurately estimate the share of 

consumers who would likely be 

impacted by a standard at a particular 

efficiency level, DOE’s LCC analysis 

considers the projected distribution of 

product efficiencies that consumers 

purchase under the base case (i.e., the 

case without new energy efficiency 

standards). DOE refers to this 

distribution of product efficiencies as a 

base-case efficiency distribution. DOE 

examined the range of standard and 

optional equipment features offered by 

manufacturers. For refrigeration 

systems, DOE estimated that 75 percent 

of the equipment sold under the base 

case would be at DOE’s assumed 

baseline level—that is, the equipment 

would comply with the existing 

standards in EPCA, but have no 

additional features that improve 

efficiency. The remaining 25 percent of 

equipment would have features that 

would increase its efficiency. While 

manufacturers could have many 

options, DOE assumed that the average 

efficiency level of this equipment would 

correspond to the efficiency level 

achieved by the baseline equipment 

with the first design option in the 

sequence of design options in the 

engineering analysis ordered by their 

relative cost-effectiveness. DOE 

estimated that for panels and nondisplay doors, 100 percent of the 

equipment sold under the base case 

would consist of equipment at DOE’s 

assumed baseline level—that is, 

minimally compliant with EPCA. For 

cooler display doors, DOE assumed that 

25 percent of the current shipments are 

minimally compliant with EISA and the 

remaining 75 percent are higherefficiency (45 percent are assumed to 

have LED lighting, corresponding to the 

first efficiency level above the baseline 

in the engineering analysis, and 30 

percent are assumed to have LED 

lighting plus anti-sweat heater wire 

controls, corresponding to the second 

efficiency level above the baseline). For 

freezer display doors, DOE assumed that 

80 percent of the shipments would be 

minimally compliant with EPCA and 

the remaining 20 percent have LED 

lighting, corresponding to the first 

efficiency level above the baseline. (See 

Section IV.C and chapter 5 of the TSD 

for a discussion of the efficiency levels 

and design options in the engineering 

analysis). The current analysis assumes 

that all consumers purchase only the 

minimally compliant equipment from 

2017 on, when the walk-in cooler and 

freezer standard is in effect. DOE 

requests comment on the distribution of 

product efficiencies in the absence of 

standards, particularly with respect to 

the magnitude of market penetration of 

any specific higher-efficiency 

technologies. For further information on 

DOE’s estimate of base-case efficiency 

distributions, see chapter 8 of the TSD. 

11. Inputs to Payback Period Analysis 

The payback period is the number of 

years that it takes the consumer to 

recover the additional installed cost of 

more efficient products, compared to 

baseline products, through energy cost 

savings. The simple payback period 

does not account for changes in 

operating expense over time or the time 

value of money. Payback periods that 

exceed the life of the product mean that 

the increased total installed cost is not 

recovered in reduced operating 

expenses (based on the first year’s 

estimated operating cost). 

The inputs to the PBP calculation are 

the total installed costs to the consumer 

of the equipment for each efficiency 

level and the average annual operating 

expenditures for each efficiency level in 

the first year. The PBP calculation uses 

the same inputs as the LCC analysis, 

except that discount rates are not used. 

Interested parties raised several 

concerns regarding the LCC and PBP 

analyses. American Panel commented 

that the LCC and PBP presented in the 

preliminary analysis may be inaccurate 

because the refrigeration systems were 

not properly matched to the walk-in 

envelope, and the refrigeration system 

would be oversized for food safety and 

have a shorter run time. American Panel 

recommended that DOE select the 

refrigeration system capacity based on 

the heat load of the envelope size to 

achieve realistic LCC and PBP results. 

(American Panel, No. 0048.1 at p. 8) To 

account for this possibility, the current 

analysis now assumes that the 

refrigeration system is oversized by 20 

percent over the aggregate refrigeration 

load of the walk-in unit. 


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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 55831 

American Panel submitted several 

comments relating to PBP issues for 

specific market segments. During the 

public meeting, American Panel 

commented that small business owners, 

such as non-chain restaurants or 

independent food service operators, 

generally attempt to avoid higher first 

costs due to the uncertainty of business 

success, while food service franchisees 

can afford to consider a longer term 

view of future savings. (American Panel, 

Public Meeting Transcript, No. 0045 at 

p. 252) American Panel cited data from 

the National Restaurant Association 

indicating that approximately 70 

percent of all restaurants and 90 percent 

of small restaurants that open in the 

same building as a previously failed 

business fail in the first year due to 

insufficient up-front capital. American 

Panel predicted from these data that 

increased equipment costs resulting 

from new energy standards would have 

a serious negative impact on the small 

business restaurant owner, especially 

during the first year of restaurant 

operation, and that these entities would 

be able to sustain equipment efficiency 

improvements with a payback period of 

only 1 year or less. (American Panel, 

No. 0048.1 at p. 10) Owners and 

operators of franchised restaurant 

chains could afford to consider a longer 

payback period (e.g., 2 years or more). 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 254) 

DOE will continue to use the standard 

LCC and PBP methods to convey the 

economic impacts of energy efficiency 

standards on walk-ins. DOE recognizes 

the particular PBP considerations of 

various market segments, however, 

including small businesses and 

independent restaurants. In preparing 

this NOPR, DOE examined the 

‘‘business lifetime’’ (also referred to as 

the ‘‘economic lifetime’’), which is an 

issue prevalent in the restaurant market 

sector. According to submitted 

comments, the economic lifetime of 

WICF equipment used in certain 

businesses may significantly differ from 

the operational lifetime. This issue 

could potentially impact the LCC and 

NIA analyses and is further discussed in 

section IV.G.1.b of this document. The 

walk-in lifetime details are also 

discussed in chapter 8 of the TSD. 

12. Rebuttable-Presumption Payback 

Period 

As noted above, EPCA, as amended, 

establishes a rebuttable presumption 

that a standard is economically justified 

if the Secretary finds that the additional 

cost to the consumer of purchasing a 

product that complies with an energy 

conservation standard level will be less 

than three times the value of the 

consumer’s first-year energy (and, as 

applicable, water) savings derived as a 

result of the standard, as calculated 

under the test procedure in place for 

that standard. (42 U.S.C. 

6295(o)(2)(B)(iii)) For each considered 

efficiency level, DOE determined the 

value of the first year’s energy savings 

by calculating the quantity of those 

savings in accordance with the 

applicable DOE test procedure, and 

multiplying that amount by the average 

energy price forecast for the year in 

which compliance with the new 

standard would be required. 

American Panel commented that the 

3-year PBP established in EPCA should 

be decreased to 1 or 1.5 years at the 

most. (American Panel, No. 0048.1 at p. 

11) DOE acknowledges the economic 

impacts on small businesses resulting 

from implementing energy efficiency 

standards but has maintained the 3-year 

PBP guideline as an initial step for 

determining economic justification, 

consistent with 42 U.S.C. 6295(o). 

However, DOE routinely conducts a full 

economic analysis that considers the 

full range of impacts to the consumer, 

manufacturer, nation, and environment 

and will consider other applicable 

criteria in determining whether a 

proposed standard is economically 

justified, including impacts on small 

businesses. For the results of DOE’s 

detailed analysis of economic impacts 

on commercial customers and 

manufacturers, see sections V.B.1 and 

V.B.2. 

For the NOPR analysis, DOE 

calculated a rebuttable presumption 

payback period at each TSL for WICF 

equipment. Rather than using 

distributions for input values, DOE used 

discrete values and, as required by 

EPCA, based the calculation on the 

assumptions in the DOE WICF test 

procedure. As a result, DOE calculated 

a single rebuttable presumption payback 

value, rather than a distribution of 

payback periods. Table IV–14 and Table 

IV–15 show the rebuttable presumption 

payback periods at TSL 4 for 

refrigeration systems and envelope 

components, respectively. 

TABLE IV–14—WICF REFRIGERATION

SYSTEMS REBUTTABLE PAYBACK PERIOD AT TSL 4 

Equipment class 

Compressor 

type 

analyzed 

Rebuttable 

payback 

period 

DC.M.I, < 9,000 .... SEM ........... 4.7 

DC.M.I, ≥ 9,000 .... SCR ........... 1.8 

DC.M.O, < 9,000 .. SEM ........... 3.9 

DC.M.O, ≥ 9,000 .. SCR ........... 3.1 

TABLE IV–14—WICF REFRIGERATION

SYSTEMS REBUTTABLE PAYBACK PERIOD AT TSL 4—Continued 

Equipment class 

Compressor 

type 

analyzed 

Rebuttable 

payback 

period 

DC.L.I, < 9,000 ..... SCR ........... 2.1 

DC.L.I, ≥ 9,000 ..... SCR ........... 2.3 

DC.L.O, < 9,000 ... SCR ........... 1.7 

DC.L.O, ≥ 9,000 ... SCR ........... 3.1 

MC.M .................... .................... 0.8 

MC.L ..................... .................... 0.7 

TABLE IV–15 WICF ENVELOPE COMPONENTS REBUTTABLE PAYBACK PERIOD AT TSL 4 

Equipment 

class 

Equipment 

size 

Rebuttable 

payback 

period 

SP.M ............. Small ............. 5.3 

Medium ......... 5.2 

Large ............. 5.1 

SP.L .............. Small ............. 3.1 

Medium ......... 3.8 

Large ............. 4.1 

FP.L ............... Small ............. 3.8 

Medium ......... 4.6 

Large ............. 5.1 

DD.M ............. Small ............. 2.5 

Medium ......... 2.2 

Large ............. 1.9 

DD.L .............. Small ............. N/A 

Medium ......... N/A 

Large ............. 0.4 

PD.M ............. Small ............. 6.2 

Medium ......... 6.1 

Large ............. 6.0 

PD.L .............. Small ............. 4.7 

Medium ......... 4.7 

Large ............. 4.6 

FD.M ............. Small ............. 6.0 

Medium ......... 6.0 

Large ............. 5.9 

FD.L .............. Small ............. 3.5 

Medium ......... 2.4 

Large ............. 2.4 

While DOE examined the rebuttablepresumption criterion, it considered 

whether the standard levels considered 

are economically justified through a 

more detailed analysis of the economic 

impacts of these levels consistent with 

the approach laid out in 42 U.S.C. 

6295(o)(2)(B)(i). The results of this 

analysis serve as the basis for DOE to 

evaluate the economic justification for a 

potential standard level (thereby 

supporting or rebutting the results of 

any preliminary determination of 

economic justification). 

G. National Impact Analysis—National 

Energy Savings and Net Present Value 

The NIA assesses the national energy 

savings (NES) and the net present value 

(NPV) of total consumer costs and 

savings that would be expected to result 


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55832 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

from the new energy conservation 

standards. (‘‘Consumer’’ in this context 

refers to customers of the product being 

regulated.) The NES and NPV are 

analyzed at specific efficiency levels 

separately for the refrigeration systems 

and components of the envelope 

(panels, non-display doors, and display 

doors). DOE calculates the NES and 

NPV based on projections of annual 

equipment shipments, along with the 

annual energy consumption and total 

installed cost data from the energy use 

and LCC analyses. For the NOPR 

analysis, DOE forecasted the energy 

savings, operating cost savings, product 

costs, and NPV of consumer benefits for 

products sold from 2017 through 2073— 

the year in which the last standards— 

compliant equipment shipped during 

the 30-year analysis period beginning in 

2017 operates. 

DOE evaluates the impacts of the new 

standards by comparing base-case 

projections with standards-case 

projections. The base-case projections 

characterize energy use and consumer 

costs for each equipment class in the 

absence of any new energy conservation 

standards. DOE compares these 

projections with projections 

characterizing the market for each 

equipment class if DOE adopted the 

new standard at specific energy 

efficiency levels (that is, the TSLs or 

standards cases) for that equipment 

class. For the base case forecast, DOE 

considered a mix of two levels of 

efficiency for the refrigeration systems 

and a single efficiency level for the 

components, except for cooler display 

doors as noted in Table IV–16. For the 

standards cases, DOE considered a ‘‘rollup’’ scenario in which DOE assumes 

that product efficiencies that do not 

meet the standard level under 

consideration would roll-up to meet the 

new standard level, and those already 

above the proposed standard level 

would remain unaffected. 

DOE uses a Microsoft Excel 

spreadsheet model to calculate the 

energy savings and the national 

consumer costs and savings from each 

TSL. The NOPR TSD and other 

documentation that DOE provides 

during the rulemaking helps explain the 

models and how to use them and also 

allow interested parties to review DOE’s 

analyses. The NIA spreadsheet model 

uses average values as inputs (as 

opposed to probability distributions of 

key input parameters from a set of 

possible values). 

For the current analysis, the NIA used 

projections of energy prices and 

commercial building starts from the 

AEO2013 Reference case. In addition, 

DOE analyzed scenarios that used 

inputs from the AEO2013 Low 

Economic Growth and High Economic 

Growth cases. These cases have higher 

and lower energy price trends compared 

to the Reference case, as well as higher 

and lower commercial building starts, 

which result in higher and lower walkin shipments to new commercial 

buildings. NIA results based on these 

cases are presented in appendix 10E of 

the NOPR TSD. 

Table IV–16 summarizes the inputs 

and key assumptions DOE used for both 

the preliminary analysis and NOPR with 

respect to the NIA analysis. Discussion 

of these inputs and changes follows the 

table. See chapter 10 of the NOPR TSD 

for further details. 

TABLE IV–16—SUMMARY OF INPUTS AND KEY ASSUMPTIONS FOR THE NATIONAL IMPACT ANALYSIS

Inputs Preliminary analysis Changes for the NOPR analysis 

Shipments ........................................................... Annual shipments from the shipments model 

for complete walk-in units.

Annual shipments from the shipments model 

calculated separately for refrigeration systems and components. 

Compliance Date of Standard ............................ 2015 ................................................................. 2017. 

Base-Case Forecasted Efficiencies ................... No efficiency distributions assumed for the 

base case and the current baseline level 

was assumed to represent the market for 

the forecasted shipments of complete walkin systems.

Refrigeration systems: For EISA * shipments, 

75 percent of shipments are assumed to be 

at the baseline and 25 percent of shipments 

are assumed to be equivalent to the first efficiency level in the engineering analysis. 

Panels and non-display doors: For EISA 

shipments, 100 percent of shipments are 

assumed to be at the baseline. 

Display doors: For EISA shipments, 25 percent of cooler display doors are assumed to 

be at the baseline and 75 percent are higher-efficiency (45 percent with LED lighting 

and 30 percent with LED lighting and lighting controls); and 80 percent of freezer 

doors are assumed to be at the baseline 

and 20 percent are higher-efficiency (with 

LED lighting). 

Standards-Case Forecasted Efficiencies ........... No efficiency distributions assumed for the 

standards case. A single efficiency level 

was assumed to represent the market for 

the forecasted shipments of complete walkin systems.

No efficiency distributions assumed for standards compliant shipments. Shipped efficiencies for the forecasted shipments of refrigeration systems and components are 

represented by a roll up to the minimum 

standard level being analyzed. 

Annual Energy Consumption per Unit ................ DOE calculated the average annual energy 

use for each WICF envelope class matched 

with outdoor condenser systems using a 

load profile described in AHRI 1250–2009 

(8 hours of high load and 16 hours of low 

load per day).

DOE changed the daily load profile of the refrigeration system to 13.3 hours runtime per 

day for coolers and 15 hours for freezers, 

at full rated capacity corresponding to the 

reference rating outside air temperatures. 

Total Installed Cost per Unit ............................... Manufacturer’s selling price is estimated from 

Engineering Analysis. Installation costs are 

based on RS Means Mechanical Cost Data 

2009. Assumed no change with efficiency 

level.

Updated to RS Means Mechanical Cost Data 

2012. 


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TABLE IV–16—SUMMARY OF INPUTS AND KEY ASSUMPTIONS FOR THE NATIONAL IMPACT ANALYSIS—Continued 

Inputs Preliminary analysis Changes for the NOPR analysis 

Annual Energy Cost per Unit ............................. Annual Energy consumption per unit was multiplied by the Annual energy cost. Costs 

were discounted and summed over the 

analysis period for the net present value 

calculations.

No change. 

Repair and Maintenance Cost per Unit .............. Annualized repair and maintenance costs of 

the combined system were derived from RS 

Means 2009 walk-in cooler and freezer 

maintenance data. Doors and refrigeration 

systems could be replaced during the lifetime of the envelope.

Updated to RS Means 2012 walk-in cooler 

and freezer repair and maintenance data; 

repair and maintenance costs for the refrigeration system and the envelope components were estimated separately. 

Energy Prices ..................................................... Forecasted using AEO2009 price forecasts .... Updated to AEO2013 forecasts. 

Energy Site-to-Source Conversion Factor ......... Varies yearly and is generated by NEMS–BT 

(2009); applied from 2014 through 2045.

Updated to modified NEMS–BT** (2012), and 

applied from 2017 through 2073. 

Discount Rate ..................................................... 3% and 7% real ............................................... No change. 

Present Year ...................................................... Future expenses discounted to 2010 .............. Future expenses discounted to 2013. 

* EISA 2007 amended EPCA to establish prescriptive standards for walk-in coolers and freezers manufactured on or after January 1, 2009. 

EISA shipments refer to the shipments complying with these prescriptive standards. This is in contrast to pre-EISA shipments, which would refer 

to shipments before 2009 when there was no Federal energy efficiency standard in place. 

** Site-to-source factors modified by Lawrence Berkley National Laboratories. 

American Panel noted that the NIA 

results in the preliminary analysis were 

not meaningful because the refrigeration 

system capacities were not properly 

matched to the walk-in envelope. As 

stated earlier in the LCC and PBP 

sections, American Panel contended 

that DOE should select the refrigeration 

system capacity based on the envelope 

heat load to make the economic 

analyses realistic. (American Panel, No. 

0048.1 at p. 11) In the NOPR, DOE 

conducted the NIA analysis for the 

refrigeration systems and the selected 

envelope components independent of 

each other and then combined the 

results to arrive at the trial standard 

levels. This approach did not directly 

pair the walk-in units with the matched 

capacity refrigeration system because 

minor inconsistencies in the matching 

of individual units could have large 

effects on the overall NIA results, as 

noted by American Panel. Rather, the 

NOPR analysis involved combining the 

results in the aggregate to arrive at a 

more accurate estimate of overall energy 

savings across the range of covered 

equipment. 

1. Shipments 

Forecasts of product shipments are 

used to calculate the national impacts of 

standards on energy use, NPV, and 

future manufacturer cash flows. DOE 

developed shipment forecasts for 

refrigeration systems and envelope 

components based on an analysis of 

growth trends of specific building types 

housing the walk-in units. In DOE’s 

shipments model, shipments of walk-in 

units and their components are driven 

by new purchases and stock 

replacements due to failures. The 

envelope component model and 

refrigeration system shipments model 

take an accounting approach, tracking 

market shares of each equipment class 

and the vintage of units in the existing 

stock. Stock accounting uses product 

shipments as inputs to estimate the age 

distribution of in-service product stocks 

for all years. The age distribution of inservice product stocks is a key input to 

calculations of both the NES and NPV 

because operating costs for any year 

depend on the age distribution of the 

stock. DOE also considers the impacts 

on shipments from changes in product 

purchase price and operating cost 

associated with higher energy efficiency 

levels. 

American Panel, NEEA and NPCC 

suggested that DOE contact the National 

Association of Food Equipment 

Manufacturers (NAFEM) and major 

refrigeration system manufacturers such 

as Heatcraft and Russell to obtain 

shipment information. (American Panel, 

Public Meeting Transcript, No. 0045 at 

pp. 274–275; NEEA and NPCC, Public 

Meeting Transcript, No. 0045 at p. 281) 

DOE contacted NAFEM, which 

provided DOE with copies of that 

organization’s ‘‘Size and Shape of the 

Industry’’ reports. These reports contain 

data on the annual sales of walk-in units 

in the food service sector for 2002–2010. 

DOE analyzed the data received from 

NAFEM and also obtained other data 

from manufacturer interviews and other 

sources. DOE used these data to develop 

equipment class size share distributions, 

and are documented in the current 

shipment models. 

a. Share of Shipments and Stock Across 

Equipment Classes 

In response to the shipments analysis 

results in the preliminary analysis, DOE 

received several comments regarding 

the share of shipments and stock across 

equipment classes, dedicated 

condensing and multiplex systems, 

indoor and outdoor systems, cooler and 

freezer envelopes, and envelope sizes. 

In the preliminary analysis, DOE 

estimated that 46 percent of the existing 

stock of walk-in systems is served by 

multiplex systems. American Panel 

commented that the ratio between 

multiplex to dedicated condensing 

refrigeration systems was too high and 

stated that, historically, 68 percent of 

their sales are for dedicated condensing 

refrigeration systems. American Panel 

suggested that DOE’s estimate of the 

share of stocks of dedicated condensing 

refrigeration systems should be 70 

percent. (American Panel, Public 

Meeting Transcript, No. 0045 at pp. 192 

and 275; American Panel, No. 0048.1 at 

p. 4) Heatcraft supported this 

observation by stating that multiplex 

medium temperature refrigeration 

system stock share should be only 15 

percent. (Heatcraft, Public Meeting 

Transcript, No. 0045 at p. 269) 

DOE considered these comments and 

re-examined its analyses in developing 

its revised analysis for the NOPR. As 

part of this revised analysis, DOE 

developed a shipment model that 

provided the key inputs required by the 

shipment models for the envelope 

components and refrigeration systems. 

Based on this shipment analysis, DOE 

estimated that dedicated condensing 

units account for approximately 70 

percent of the refrigeration market and 


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55834 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

the remaining 30 percent consists of 

unit coolers connected to multiplex 

condensing systems. DOE estimated that 

medium temperature unit coolers 

connected to multiplex systems account 

for about 25 percent of the shipments 

and stock. Regarding American Panel’s 

comment on the relative shares of stock 

between the multiplex and the 

dedicated condensing refrigeration 

systems shown in the preliminary TSD 

(Table 3.2.8), DOE noted that Table 3.2.8 

addressed shipments and not 

refrigeration system stock data. 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 269) 

DOE received two comments 

regarding the stock share for outdoor 

and indoor dedicated condensing 

refrigeration systems. Heatcraft stated 

that a 30 percent share for outdoor 

dedicated condensing refrigeration 

systems was a reasonable assumption 

for DOE’s economic analyses. (Heatcraft, 

Public Meeting Transcript, No. 0045 at 

p. 268) Manitowoc stated that the share 

of indoor dedicated condensing 

refrigeration systems should be higher 

than predicted, approximately 10 

percent. (Manitowoc, Public Meeting 

Transcript, No. 0045 at p. 274) DOE 

considered these comments in light of 

other available data and estimated for 

the NOPR analysis that approximately 

66 percent and 3 percent of the 

shipments and stocks of the 

refrigeration systems are accounted for 

by the outdoor and indoor dedicated 

condensing refrigeration systems, 

respectively. 

Regarding the relative shares of stock 

or shipment between walk-in coolers 

and freezers, American Panel 

commented that DOE’s estimates of 70 

percent and 30 percent shares for cooler 

and freezer envelopes, respectively, 

were reasonable. (American Panel, 

Public Meeting Transcript, No. 0045 at 

p. 275) DOE has slightly adjusted these 

estimates in the NOPR shipment model 

to 71 percent (coolers) and 29 percent 

(freezers) based on updated calculations 

and data. 

NEEA and NPCC stated that DOE 

correctly apportioned walk-ins by 

business type in the preliminary 

analysis, but noted that significant 

market shifts are taking place in the 

grocery and convenience store sectors. 

(NEEA and NPCC, No. 0059.1 at p. 11) 

NEEA and NPCC did not elaborate on 

the significance or nature of the market 

shifts. American Panel stated that DOE’s 

estimate of twice as many large walk-in 

coolers as small walk-in coolers seemed 

inaccurate, and stated it would provide 

data. (American Panel, Public Meeting 

Transcript, No. 0045 at p. 293) 

American Panel then submitted a 

written comment with its own historical 

shipment data showing that walk-in 

cooler and freezer shipments for small, 

medium, and large units are 40 percent, 

56 percent, and 4 percent, respectively, 

which differs significantly from DOE’s 

estimates of 14 percent, 58 percent, and 

28 percent for small, medium, and large 

units, respectively, in the preliminary 

analysis. (American Panel, No. 0048.1 at 

p. 11) In the NOPR analysis, DOE 

adjusted its estimates based in part on 

American Panel’s feedback. For the 

NOPR, DOE estimated that size 

distributions of stocks and shipments of 

walk-in units are 52 percent, 40 percent, 

and 8 percent for small, medium, and 

large, respectively. 

b. Lifetimes and Replacement Rates 

As discussed in the previous section 

on LCC and PBP analyses, the 

preliminary analysis assumed an 

envelope lifetime of approximately 15 

years. American Panel agreed with 

DOE’s 15-year lifetime estimate for the 

envelopes. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 283) 

Kysor mentioned that the envelope 

lifetime could vary depending on the 

traffic within it. For example, an 8- to 

10-year envelope lifetime can be 

expected if pallet jack or forklifts are 

used in the walk-in, while a longer 

envelope lifetime is likely if activity is 

limited to foot traffic or lighter hand 

trucks. (Kysor, Public Meeting 

Transcript, No. 0045 at p. 287) MasterBilt suggested that most envelopes have 

a 20-year lifetime. (Master-Bilt, No. 

0046.1 at p. 1) American Panel 

concurred with the 5 percent 

replacement rate for walk-in cooler and 

freezer envelopes, which corresponds to 

a 20-year lifetime. (American Panel, No. 

0048.1 at p. 11) AHRI commented that 

based on its own experience, it believes 

envelope wall and floor panels tend to 

have a longer lifetime—12 to 25 years 

would be typical—but provided no data 

in support of this view. (AHRI, No. 

0055.1 at p. 4) Hill Phoenix noted that 

failure of envelope components is 

usually evident by visual inspection, 

and panels would not usually fail from 

condensation or ice formation in the 

insulation. (Hill Phoenix, No. 0066.1 at 

p. 3) Given that most of these comments 

provided only anecdotal evidence and 

not supporting data, DOE continues to 

assume a 15-year average lifetime for 

panels in the current analysis. 

DOE assumed the typical lifetime of 

envelope doors to be 5 years in the 

preliminary analysis. American Panel 

commented that the door replacement 

rate of 5 years is not supported by its inhouse data, which show a door 

replacement rate of 5 percent, with the 

door lasting throughout the walk-in 

cooler and freezer envelope lifetime. 

(American Panel, No. 0048.1 at p. 9) In 

addition, American Panel stated that the 

number of replacement non-display 

doors represented 5 percent of their 

annual door shipments, which is 

inconsistent with the assumption that 

doors only last 5 years. (American 

Panel, Public Meeting Transcript, No. 

0045 at p. 14 and p. 284) In light of 

these comments on the door 

replacement rates, DOE has revised its 

assumptions of door lifetimes to more 

closely match envelope lifetimes. The 

NOPR shipment model assumes an 

average lifetime of approximately 14 

years for both display and non-display 

doors. 

For refrigeration systems, DOE 

assumed an average lifetime of 7 years 

in the preliminary analysis. Master-Bilt 

stated that refrigeration system lifetimes 

were comparable to the envelope 

lifetime of approximately 20 years—it 

estimated that refrigeration system 

lifetimes would be about 80–100 

percent of envelope lifetimes. (MasterBilt, Public Meeting Transcript, No. 

0045 at p. 287) Master-Bilt also stated 

that a 15 percent replacement rate for 

the refrigeration systems, which 

corresponds to a lifetime of 7 years, is 

too high, and actual replacement rates 

should be only half as much. (MasterBilt, No. 0046.1 at p. 1) AHRI stated that 

a typical mechanical equipment lifetime 

is between 8 and 12 years. (AHRI, No. 

0055.1 at p. 4) Master-Bilt also 

mentioned that the economy has 

reduced the frequency at which walk-in 

coolers and freezers are completely 

replaced with new equipment because 

of the high cost. Instead, existing 

equipment is often being refurbished 

with users typically replacing only one 

or a few individual components. 

(Master-Bilt, No. 0046.1 at p. 1) MasterBilt also stated that doors are the most 

commonly repaired or replaced 

envelope component, while the most 

common replacement part for a 

refrigeration system is the compressor. It 

noted that only 5 percent of refrigeration 

systems require replacement 

compressors over a 10-year span. 

(Master-Bilt, Public Meeting Transcript, 

No. 0045 at p. 287) American Panel 

agreed that the entire refrigeration 

system is not typically replaced and 

only a compressor or fan motor is 

replaced when the system fails. 

Consequently, American Panel 

disagreed with the 15 percent average 

replacement rate used in the 

preliminary analysis for the refrigeration 

systems and suggested DOE use a 

refrigeration system replacement rate of 


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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 55835 

10 percent. (American Panel, No. 0048.1 

at p. 11) In view of the comments 

received from interested parties, DOE 

revised its assumption of the average 

lifetime of the refrigeration system to 12 

years, corresponding to a replacement 

rate of about 8 percent. 

In the preliminary analysis, DOE 

assumed a higher replacement rate for 

refrigeration systems than for envelopes. 

American Panel commented that DOE’s 

estimated shipment ratio of 3 to 1 

between refrigeration systems and 

envelopes was too high and that a more 

appropriate shipment ratio between 

refrigeration systems and envelopes 

would be about 1.3 to 1. (American 

Panel, Public Meeting Transcript, No. 

0045 at p. 192 and No. 0048.1 at p. 4) 

As explained, in the NOPR shipment 

model, the refrigeration system lifetime 

has been revised downward from 15 to 

12 years. (DOE has retained the 15-year 

lifetime for envelopes.) In the revised 

shipment model, refrigeration system 

replacements account for about 30–41 

percent of all refrigeration system 

shipments. While this estimate exceeds 

the suggested shipment ratio of 1.3, DOE 

believes that the average lifetimes of 

walk-in envelopes and refrigeration 

systems, which are based on 

manufacturer interviews and 

stakeholder comments, are reasonable. 

NEEA and NPCC stated that economic 

lifetimes are different from physical 

lifetimes and suggested that DOE use 

both economic and physical lifetimes 

depending on the building type in 

which the walk-in cooler and freezer 

resides. (NEEA and NPCC, No. 0059.1 at 

p. 11) The physical lifetime refers to the 

duration before the equipment fails or is 

replaced, whereas the economic lifetime 

refers to the duration before the walk-in 

cooler and freezer equipment is taken 

out of service because the owner is no 

longer in business. In the event of an 

economic lifetime failure, however, a 

WICF would likely not leave the 

national stock, but would instead be 

sold to a third party, which would 

represent a transfer of goods and would 

not impact WICF shipments or stock at 

a national level. For a more detailed 

discussion of economic lifetimes see 

life-cycle cost discussion in section 

IV.F.7. 

c. Growth Rates 

The preliminary analysis used a 

shipments growth rate of approximately 

2 percent. Several interested parties 

commented on this assumption. 

American Panel agreed with DOE’s 

assumption that walk-in growth will 

match growth seen in building stock 

square footage. (American Panel, No. 

0048.1 at p. 11) Others stated that the 

preliminary analysis shipment growth 

rate was overestimated. AHRI, NEEA 

and NPCC predicted that the walk-in 

market would be flat and any growth 

would be less than 1 percent. (AHRI, 

No. 0055.1 at p. 4; NEEA and NPCC, 

Public Meeting Transcript, No. 0045 at 

p. 292) Master-Bilt, NEEA and NPCC 

stated that the shipment analysis should 

use a maximum growth rate of 1 

percent. (Master-Bilt, No. 0046.1 at p.1; 

NEEA and NPCC, Public Meeting 

Transcript, No. 0045 at p. 292) One 

stakeholder stated that its business has 

grown annually at a simple rate of 10 

percent, although it added that this may 

not be representative and may have 

been driven by gaining market share 

from other manufacturers. (American 

Panel, Public Meeting Transcript, No. 

0045 at pp. 290–291) American Panel 

suggested that NAFEM may provide 

walk-in growth rates across industry. 

American Panel observed that 

shipments grow about 7 percent in 

normal financial times; however, they 

can decline 10 percent per year during 

a recession. In particular, the restaurant 

sector business has dropped by 60 

percent while walk-in cooler and freezer 

business in the school sector has grown. 

(American Panel, No. 0048.1 at p. 11) 

Considering these stakeholder 

comments, DOE modeled its growth rate 

projections for the NOPR analysis using 

the commercial building floor space 

growth rates from the AEO 2013 NEMS– 

BT model. 

d. Other Issues 

DOE developed a core shipment 

model for estimating the annual 

shipments and stocks of complete 

WICFs that formed the basis for the 

shipment analysis of refrigeration 

systems and envelope components. DOE 

expressed annual shipments and stocks 

of refrigeration systems in terms of 

installed refrigeration capacity (Btu/h) 

which required DOE to estimate the 

required refrigeration capacity for the 

WICF units shipped. As part of the 

process, product loads were estimated 

for different envelope sizes and types. 

In the preliminary analysis, product 

load estimates were central to the 

annual energy consumption projections 

and were presented in the same context. 

American Panel stated that while the 

product-specific heat and product pulldown temperature values used in the 

preliminary analysis were correct, it 

disagreed with the product-loading 

values assumed for various types of 

equipment. American Panel suggested 

that the product-loading estimates 

should be 2 pounds per cubic foot for 

small coolers and 1 pound per cubic 

foot for medium and large coolers (not 

4 and 2 respectively, as DOE had 

assumed), and 1 pound per cubic foot 

for small, medium, and large freezers 

(not 1 for small freezers and 0.5 for 

medium and large freezers, as DOE had 

assumed). (American Panel, Public 

Meeting Transcript, No. 0045 at p. 209) 

Master-Bilt stated that it is difficult to 

have product load assumptions that are 

valid for all applications and DOE 

should explicitly state that the product 

load assumptions currently used are 

valid only for specific situations but 

may not necessarily be representative of 

all applications. (Master-Bilt, No. 0046.1 

at p. 1) 

DOE agrees with Master-Bilt’s 

observation that it is difficult to make 

assumptions on product load that are 

valid for all sizes and all applications. 

DOE revisited the issue and concluded 

that the loading ratios indicated by 

American Panel could be representative 

of the food service segment of the 

market, which accounts for about 35 

percent of the aggregate installed 

refrigeration capacity for the walk-ins. 

From the available product brochures 

and indicated product loads for 

different sizes of WICF equipment, DOE 

believes that the loading ratios used for 

the other market segments are closer to 

ratios used in the preliminary analysis. 

Consequently, DOE did not change the 

loading ratios for the NOPR analysis. 

2. Forecasted Efficiency in the Base Case 

and Standards Cases 

A key component of the NIA is the 

trend in energy efficiency forecasted for 

the base and standards cases. Using data 

collected from manufacturers and an 

analysis of market information, DOE 

developed a base-case energy efficiency 

distribution (which yields a shipmentweighted average efficiency) for each of 

the considered equipment classes for 

the first year of the forecast period. To 

project the efficiency trend over the 

entire forecast period, DOE considered 

the current market distribution and 

recent trends. For envelope 

components, all base case shipments are 

assumed to have only a single EPCAcompliant efficiency level except for 

display doors. For cooler display doors, 

shipments would be a mix of 25 percent 

EPCA-compliant equipment and 75 

percent higher efficiency equipment. 

For freezer display doors, shipments 

would be a mix of 80 percent EPCAcompliant equipment and 20 percent 

higher efficiency equipment. For 

refrigeration systems, DOE assumed, 

based on manufacturer interviews, that 

in the absence of standards (the base 

case), shipments would be a mix of 75 

percent EPCA-compliant equipment and 

25 percent higher efficiency equipment. 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55836 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

20 Docket ID: EERE–2010–BT–NOA–0028, 

comment by Kirk Lundblade. 

21OMB Circular A–4 (Sept. 17, 2003), section E, 

‘‘Identifying and Measuring Benefits and Costs.’’ 

Available at: www.whitehouse.gov/omb/ 

memoranda/m03-21.html. 

For both refrigeration systems and 

envelope components, DOE assumed no 

improvement of energy efficiency in the 

base case and held the base-case energy 

efficiency distribution constant 

throughout the forecast period. DOE 

requests comment on this assumption. 

To estimate efficiency trends in the 

standards cases, DOE has used a ‘‘rollup’’ scenario in its standards 

rulemakings. The roll-up scenario 

represents a standards case in which all 

product efficiencies in the base case that 

do not meet the standard would roll up 

to meet the new standard level. 

Consumers in the base case who 

purchase walk-in equipment above the 

standard level are not affected as they 

are assumed to continue to purchase the 

same equipment. The roll-up scenario 

characterizes consumers primarily 

driven by the first-cost of the analyzed 

products and characterizes the 

efficiency trends currently found in the 

market. 

In summary, under the roll-up 

scenario DOE assumes: (1) Product 

efficiencies in the base case that do not 

meet the standard level under 

consideration would ‘‘roll-up’’ to meet 

the new standard level and (2) product 

efficiencies above the standard level 

under consideration would not be 

affected. 

3. National Energy Savings 

For each year in the forecast period, 

DOE calculates the NES for each 

standard level by multiplying the stock 

of equipment affected by the energy 

conservation standards by the per-unit 

annual energy savings. DOE typically 

considers the impact of a rebound effect, 

introduced in the energy-use analysis, 

in its calculation of national energy 

savings for a given product. A rebound 

effect occurs when users operate higher 

efficiency equipment more frequently 

and/or for longer durations, thus 

offsetting estimated energy savings. 

However, DOE assumed a rebound 

factor of one, or no effect, because walkins must cool their contents at all times 

and it is not possible for consumers to 

operate them more frequently. For a 

further discussion of the rebound effect, 

see chapter 10 of the TSD. DOE seeks 

comment on the assumption that there 

is no rebound effect associated with 

these products. 

To estimate the national energy 

savings expected from appliance 

standards, DOE uses a multiplicative 

factor to convert site energy 

consumption (at the home or 

commercial building) into primary or 

source energy consumption (the energy 

required to convert and deliver the site 

energy). These conversion factors 

account for the energy used at power 

plants to generate electricity and losses 

in transmission and distribution, as well 

as for natural gas losses from pipeline 

leakage and energy used for pumping. 

For electricity, the conversion factors 

vary over time due to projected changes 

in generation sources (that is, the power 

plant types projected to provide 

electricity to the country). The factors 

that DOE developed are marginal 

values, which represent the response of 

the system to an incremental decrease in 

consumption associated with appliance 

standards. 

In the preliminary analysis, DOE used 

annual site-to-source conversion factors 

based on the version of NEMS that 

corresponds to AEO2009. For this 

NOPR, DOE updated its conversion 

factors based on the U.S. energy sector 

model NEMS–BT corresponding to 

AEO2013. 

DOE has historically presented NES 

in terms of primary energy savings. In 

response to the recommendations of a 

committee on ‘‘Point-of-Use and FullFuel-Cycle Measurement Approaches to 

Energy Efficiency Standards’’ appointed 

by the National Academy of Science, 

DOE announced its intention to use fullfuel-cycle (FFC) measures of energy use 

and greenhouse gas and other emissions 

in the national impact analyses and 

emissions analyses included in future 

energy conservation standards 

rulemakings. 76 FR 51281 (August 18, 

2011) While DOE stated in that notice 

that it intended to use the Greenhouse 

Gases, Regulated Emissions, and Energy 

Use in Transportation (GREET) model to 

conduct the analysis, it also said it 

would review alternative methods, 

including the use of NEMS. After 

evaluating both models and the 

approaches discussed in the August 18, 

2011 notice, DOE published a statement 

of amended policy in the Federal 

Register in which DOE explained its 

determination that NEMS is a more 

appropriate tool for its FFC analysis and 

its intention to use NEMS for that 

purpose. 77 FR 49701 (August 17, 2012). 

DOE received one comment, which was 

supportive of the use of NEMS for 

DOE’s FFC analysis.20

The approach used for today’s NOPR, 

and the FFC multipliers that were 

applied, are described in appendix 10G 

of the NOPR TSD. NES results are 

presented in both primary and 

summarized by TSL in terms of FFC 

savings in section V.B.3.a. 

4. Net Present Value of Consumer 

Benefit 

The inputs for determining the NPV 

of the total costs and benefits 

experienced by walk-in equipment 

consumers are: (1) Total annual 

installed cost; (2) total annual savings in 

operating costs; and (3) a discount 

factor. DOE calculates net savings each 

year as the difference between the base 

case and each standards case in total 

savings in operating costs and total 

increases in installed costs. DOE 

calculates operating cost savings over 

the life of each product shipped during 

the forecast period. 

DOE multiplies the net savings in 

future years by a discount factor to 

determine their present value. For the 

preliminary analysis, DOE estimated the 

NPV of appliance consumer benefits 

using both a 3 percent and a 7 percent 

real discount rate. The 7 percent real 

value is an estimate of the average 

before-tax rate of return to private 

capital in the U.S. economy. The 3 

percent real value represents the 

‘‘societal rate of time preference,’’ which 

is the rate at which society discounts 

future consumption flows to their 

present. NEEA and NPCC urged DOE to 

focus on the 3-percent discount rate as 

the primary basis for the analyses 

because the issues largely pertain to the 

aggregate costs and benefits accruing to 

society at large. (NEEA and NPCC, No. 

0059.1 at p. 12) DOE uses these discount 

rates in accordance with guidance 

provided by the Office of Management 

and Budget (OMB) to Federal agencies 

on the development of regulatory 

analysis.21 Therefore, for today’s NOPR, 

DOE continued to estimate the NPV of 

appliance consumer benefits using both 

a 3 percent and a 7 percent real discount 

rate as directed by OMB. 

5. Benefits From Effects of Standards on 

Energy Prices 

The reduction in electricity 

consumption associated with new 

standards for walk-ins could reduce the 

electricity prices charged to consumers 

in all sectors of the economy and 

thereby reduce their electricity 

expenditures. In chapter 2 of the 

preliminary TSD, DOE explained that, 

because the power industry is a 

complex mix of fuel and equipment 

suppliers, electricity producers and 

distributors, it did not plan to estimate 

the value of potentially reduced 

electricity costs for all consumers 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 55837 

associated with new or amended 

standards for walk-ins. 

For this rule, DOE used NEMS–BT to 

assess the impacts of the reduced need 

for new electric power plants and 

infrastructure projected to result from 

standards. In NEMS–BT, changes in 

power generation infrastructure affect 

utility revenue requirements, which in 

turn affect electricity prices. DOE 

estimated the impact on electricity 

prices associated with each considered 

TSL. Although the aggregate benefits for 

electricity users are potentially large, 

there may be negative effects on some 

entities involved in electricity supply, 

particularly power plant providers and 

fuel suppliers. Given the uncertainty 

about the extent to which the benefits 

for electricity users from reduced 

electricity prices would be a transfer 

from those involved in electricity 

supply to electricity users, DOE 

continues to investigate the extent to 

which electricity price changes 

projected to result from standards 

represent a net gain to society. 

H. Consumer Subgroup Analysis 

In analyzing the potential impact of 

new or amended standards on 

commercial consumers, DOE evaluates 

the impact on identifiable groups (i.e., 

subgroups) of consumers, such as 

different types of businesses that may be 

disproportionately affected by an energy 

conservation standard. DOE gathered 

data for all business types identified in 

the analysis: grocery stores; convenience 

stores (including specialty food stores); 

convenience stores without gasoline 

stations; and restaurants that purchase 

their own walk-in coolers or freezers. 

Comments submitted by American 

Panel and Manitowoc recommended 

that DOE consider non-chain restaurants 

independently of chain restaurants. 

(American Panel, Public Meeting 

Transcript, No. 0045 at p. 252; 

Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 254) Further comments 

by American Panel suggested that small 

restaurants are more vulnerable to 

potential economic consequences of an 

efficiency standard. (American Panel, 

No. 0048.1 at p. 10) DOE agrees with 

these comments and believes that its 

current models accurately represent 

chain restaurants because data used to 

characterize the restaurant business type 

is dominated by multi-establishment 

chain restaurants. Hence, small, nonchain restaurants are included in the 

subgroup analysis. 

After reviewing the data and 

submitted comments (see TSD chapter 

11 for more details), DOE identified 

small restaurant owners because this 

subgroup likely includes owners of 

high-cost walk-in coolers and freezers, 

has the highest capital costs of all 

subgroups, and potentially experiences 

the shortest equipment economic 

lifetimes. These conditions make it 

likely that this subgroup will have the 

lowest life-cycle cost savings of any 

major consumer group. 

DOE estimated the impact on the 

identified consumer subgroup using the 

LCC spreadsheet model. The standard 

LCC and PBP analyses (described in 

section IV.F) include various types of 

businesses that own and use walk-in 

coolers and freezers. The LCC 

spreadsheet model allows for the 

identification of one or more subgroups 

of businesses, which can then be 

analyzed by sampling only each 

subgroup. The results of DOE’s LCC 

subgroup analysis are summarized in 

section V.B and described in detail in 

chapter 11 of the TSD. 

I. Manufacturer Impact Analysis 

1. Overview 

DOE performed an MIA to estimate 

the financial impact of energy 

conservation standards on 

manufacturers of walk-in equipment 

and to calculate the impact of such 

standards on employment and 

manufacturing capacity. Manufacturers 

of panels, doors, and refrigeration, as 

well as manufacturers of completed 

walk-ins, were considered in the 

analysis. 

The MIA has both quantitative and 

qualitative aspects. The quantitative 

portion of the MIA primarily relies on 

the Government Regulatory Impact 

Model (GRIM), an industry cash-flow 

model customized for this rulemaking. 

The key GRIM inputs are data on the 

industry cost structure, product costs, 

shipments, and assumptions about 

markups and conversion expenditures. 

The key output is the industry net 

present value (INPV). Different sets of 

assumptions (markup scenarios) will 

produce different results. The 

qualitative portion of the MIA addresses 

factors such as product characteristics 

and industry and market trends. Chapter 

12 of the NOPR TSD describes the 

complete MIA. 

DOE conducted the MIA for this 

rulemaking in three phases. In Phase 1 

of the MIA, DOE prepared a profile of 

the walk-in cooler and freezer industry, 

which includes a top-down cost 

analysis of manufacturers that DOE used 

to derive preliminary financial inputs 

for the GRIM (e.g., sales general and 

administration (SG&A) expenses; 

research and development (R&D) 

expenses; and tax rates). DOE used 

public sources of information, including 

company Securities and Exchange 

Commission (SEC) 10–K filings, 

Moody’s company data reports, 

corporate annual reports, the U.S. 

Census Bureau’s Economic Census, and 

Dun and Bradstreet reports. 

In Phase 2 of the MIA, DOE prepared 

an industry cash-flow analysis to 

quantify the impacts of a new energy 

conservation standard. In general, new 

or more stringent energy conservation 

standards can affect manufacturer cash 

flow in three distinct ways: (1) Create a 

need for increased investment, (2) raise 

production costs per unit, and (3) alter 

revenue due to higher per-unit prices 

and possible changes in sales volumes. 

In Phase 3 of the MIA, DOE 

conducted interviews with a 

representative cross-section of 

manufacturers. During these interviews, 

DOE discussed engineering, 

manufacturing, procurement, and 

financial topics to validate assumptions 

used in the GRIM and to identify key 

issues or concerns. See section IV.I.4 for 

a description of the key issues 

manufacturers raised during the 

interviews. 

Phase 3 also includes an evaluation of 

sub-groups of manufacturers that may 

be disproportionately impacted by 

standards or that may not be accurately 

represented by the average cost 

assumptions used to develop the 

industry cash-flow analysis. For 

example, small manufacturers, niche 

players, or manufacturers exhibiting a 

cost structure that largely differs from 

the industry average could be more 

negatively affected. Thus, during Phase 

3, DOE analyzed small manufacturers as 

a subgroup. 

The Small Business Administration 

(SBA) defines a small business for North 

American Industry Classification 

System (NAICS) 333415 ‘‘AirConditioning and Warm Air Heating 

Equipment and Commercial and 

Industrial Refrigeration Equipment 

Manufacturing’’ as having 750 

employees or fewer. During its research, 

DOE identified multiple companies that 

manufacture products covered by this 

rulemaking and qualify as a small 

business under the SBA definition. The 

small businesses were further subdivided into small manufacturers of 

panels, doors, and refrigeration 

equipment to better understand the 

impacts of the rulemaking on those 

entities. The small business subgroup is 

discussed in sections V.B.2.d and VI.B 

of today’s notice and in Chapter 12 of 

the NOPR TSD. 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55838 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

2. Government Regulatory Impact Model 

Analysis 

As discussed previously, DOE uses 

the GRIM to quantify the changes in 

cash flow that result in a higher or lower 

industry value from new standards. The 

GRIM analysis uses a discounted cashflow methodology that incorporates 

manufacturer costs, markups, 

shipments, and industry financial 

information as inputs. The GRIM 

models changes in costs, distribution of 

shipments, investments, and 

manufacturer margins that could result 

from new energy conservation 

standards. The GRIM spreadsheet uses 

the inputs to arrive at a series of annual 

cash flows beginning in 2013 (the base 

year of the analysis) and continuing to 

2046. DOE calculated INPVs by 

summing the stream of annual 

discounted cash flows during these 

periods. DOE applied discount rates 

derived from industry financials and 

then modified them according to 

feedback during manufacturer 

interviews. Discount rates ranging from 

9.4 to 10.5 percent were used depending 

on the component being manufactured. 

The GRIM calculates cash flows using 

standard accounting principles and 

compares changes in INPV between the 

base case and each TSL (the standards 

case). Essentially, the difference in INPV 

between the base case and a standards 

case represents the financial impact of 

the new standard on manufacturers. 

Additional details about the GRIM, the 

discount rate, and other financial 

parameters can be found in chapter 12 

of the TSD. 

DOE typically presents its estimates of 

industry impacts by grouping the major 

equipment classes served by the same 

manufacturers. For the WICF industry, 

DOE groups results by panels, doors, 

and refrigeration systems. 

a. Government Regulatory Impact Model 

Key Inputs 

i. Manufacturer Production Costs 

Manufacturing a higher-efficiency 

product is typically more expensive 

than manufacturing a baseline product 

due to the use of more expensive 

components and larger quantities of raw 

materials. The changes in the 

manufacturer production cost (MPC) of 

the analyzed products can affect 

revenues, gross margins, and cash flow 

of the industry, making these product 

cost data key GRIM inputs for DOE’s 

analysis. 

In the MIA, DOE used the MPCs for 

each considered efficiency level 

calculated in the engineering analysis, 

as described in section IV.C and further 

detailed in chapter 5 of the TSD. In 

addition, DOE used information from its 

teardown analysis, described in section 

IV.C.3.a, to disaggregate the MPCs into 

material, labor, and overhead costs. To 

calculate the MPCs for products above 

the baseline, DOE added the 

incremental material, labor, and 

overhead costs from the engineering 

cost-efficiency curves to the baseline 

MPCs. These cost breakdowns and 

product mark-ups were validated with 

manufacturers during manufacturer 

interviews. 

ii. Shipments Forecast 

The GRIM estimates manufacturer 

revenues based on total unit shipment 

forecasts and the distribution of 

shipments by equipment class. For the 

base-case analysis, the GRIM uses the 

NIA base-case shipment forecasts from 

2013, the base year for the MIA analysis, 

to 2046, the last year of the analysis 

period. 

For the standards case shipment 

forecast, the GRIM uses the NIA 

standards case shipment forecasts. The 

NIA assumes zero elasticity in demand 

as explained in section 9.3.1 in chapter 

9 of the TSD. Therefore, the total 

number of shipments per year in the 

standards case is equal to the total 

shipments per year in the base case. 

DOE assumes a new efficiency 

distribution in the standards case, 

however, based on the energy 

conservation standard. DOE assumed 

that product efficiencies in the base case 

that did not meet the standard under 

consideration would ‘‘roll up’’ to meet 

the new standard in the standard year. 

iii. Product and Capital Conversion 

Costs 

New energy conservation standards 

will cause manufacturers to incur 

conversion costs to bring product 

designs into compliance. DOE evaluated 

the level of conversion-related capital 

expenditures needed to comply with 

each efficiency level in each equipment 

class. For the purpose of the MIA, DOE 

classified these conversion costs into 

two major groups: (1) Product 

conversion costs and (2) capital 

conversion costs. Product conversion 

costs are investments in research, 

development, testing, and marketing 

focused on making product designs 

comply with the new energy 

conservation standards. Capital 

conversion costs are investments in 

property, plant, and equipment to adapt 

or change existing production facilities 

so that new equipment designs can be 

fabricated and assembled. 

To evaluate the level of capital 

conversion expenditures manufacturers 

would likely incur to comply with 

energy conservation standards, DOE 

used the manufacturer interviews to 

gather data on the level of capital 

investment required at each efficiency 

level. DOE validated manufacturer 

comments through estimates of capital 

expenditure requirements derived from 

the product teardown analysis and 

engineering model described in sections 

IV.C.2 and IV.C.3. 

DOE assessed the product conversion 

costs at each level by integrating data 

from quantitative and qualitative 

sources. DOE considered feedback from 

multiple manufacturers at each 

efficiency level to determine conversion 

costs such as R&D expenditures and 

certification costs. Manufacturer 

numbers were aggregated to better 

reflect the industry as a whole and to 

protect confidential information. 

In general, DOE assumes that all 

conversion-related investments occur 

between the year of publication of the 

final rule and the year by which 

manufacturers must comply with the 

standard. The investment figures used 

in the GRIM can be found in section 

V.B.2.a of today’s notice. For additional 

information on the estimated product 

conversion and capital conversion costs, 

see chapter 12 of the TSD. 

b. Government Regulatory Impact Model 

Scenarios 

i. Markup Scenarios 

As discussed above, MSPs include 

direct manufacturing production costs 

(i.e., labor, material, and overhead 

estimated in DOE’s MPCs) and all nonproduction costs (i.e., SG&A, R&D, and 

interest), along with profit. To calculate 

the MSPs in the GRIM, DOE applied 

non-production cost markups to the 

MPCs estimated in the engineering 

analysis for each equipment class and 

efficiency level. Modifying these 

markups in the standards case yields 

different sets of impacts on 

manufacturers. For the MIA, DOE 

modeled two standards case markup 

scenarios to represent the uncertainty 

regarding the potential impacts on 

prices and profitability for 

manufacturers following the 

implementation of new energy 

conservation standards: (1) A 

preservation of gross margin percentage 

and (2) a preservation of operating 

profit. These scenarios lead to different 

markups values which, when applied to 

the input MPCs, result in varying 

revenue and cash flow impacts. 

Under the ‘‘preservation of gross 

margin percentage’’ scenario, DOE 

applied a single uniform gross margin 

percentage markup across all efficiency 

levels. As production costs increase 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 55839 

22 DOE estimates that walk-ins meeting the 

statutory definition would likely use between 5 and 

40 pounds of refrigerant, below the threshold 

established under the California regulations. 

with efficiency, this scenario implies 

that the absolute dollar markup will 

increase as well. DOE assumed the nonproduction cost markup—which 

includes SG&A expenses, research and 

development expenses, interest, and 

profit—to be 1.32 for panels, 1.50 for 

solid doors, 1.62 for display doors, and 

1.35 for refrigeration. These markups are 

consistent with the ones DOE assumed 

in the engineering analysis. 

Manufacturers have indicated that it is 

optimistic to assume that, as 

manufacturer production costs increase 

in response to an energy conservation 

standard, manufacturers would be able 

to maintain the same gross margin 

percentage markup. Therefore, DOE 

assumes that this scenario represents a 

high bound to industry profitability 

under an energy conservation standard. 

In the preservation of operating profit 

scenario, manufacturer markups are set 

so that operating profit one year after 

the compliance date of the new energy 

conservation standards is the same as in 

the base case. Under this scenario, as 

the cost of production and the cost of 

sales rise, manufacturers are generally 

required to reduce their markups to a 

level that maintains base case operating 

profit. The implicit assumption behind 

this markup scenario is that the industry 

can maintain only its operating profit in 

absolute dollars after the standard. 

Operating margin in percentage terms is 

reduced between the base case and 

standards case. 

3. Discussion of Comments 

Interested parties commented on the 

assumptions and results of the 

preliminary analysis, particularly on the 

cumulative regulatory burden, inventory 

levels, and scope of the manufacturer 

impact analysis. 

a. Cumulative Regulatory Burden 

AHRI stated that DOE must take into 

account the impact of new regulations 

that California is working on as part of 

Title 20 that will establish new 

prescriptive design requirements for 

walk-in coolers and freezers in 2011. 

(AHRI, Public Meeting Transcript, No. 

0045 at p. 5) 

DOE reviewed California Code of 

Regulations Title 20, Section 1605, 

which establishes walk-in requirements 

for insulation levels, motor types, and 

use of automatic door-closers. The latest 

set of regulations, published in the 2010 

Appliance Efficiency Regulations and 

effective 2011, includes design 

standards required for all walk-ins 

manufactured on or after January 1, 

2009. These state regulations are 

identical to Federal regulations that are 

set forth in EPCA (see 42 U.S.C. 6313(f)), 

and that are already in place. As a 

practical matter, the Federal regulations 

mirror those that the State of California 

had previously prescribed. As a result 

there was no incremental cost 

differential between the Federal 

standards promulgated in 2007 and 

California standards. The energy 

conservation standards that DOE is 

considering in this standards 

rulemaking are more stringent than the 

already-prescribed levels. 

AHRI also expressed concern over 

California regulations to limit 

greenhouse gas emissions, in particular 

the California Air Resources Board 

(CARB) provisions to reduce the use of 

high global warming potential 

refrigerants, such as hydrofluorocarbons 

(HFCs). (AHRI, Public Meeting 

Transcript, No. 0045 at p. 5) 

CARB is currently limiting the in-state 

use of high-GWP refrigerants in nonresidential refrigeration systems through 

its Refrigerant Management Program, 

effective January 1, 2011. According to 

this new regulation, facilities with 

refrigeration systems that have a 

refrigerant capacity exceeding 50 

pounds must repair leaks within 14 

days of detection, maintain on-site 

records of all leak repairs, and keep 

receipts of all refrigerant purchases. The 

regulation applies to any person or 

company that installs, services, or 

disposes of appliances with high-GWP 

refrigerants. According to EPCA, walkin coolers and freezers are enclosed 

storage spaces that can be walked into 

and have a total chilled storage area of 

less than 3,000 square feet. (42 U.S.C. 

6311(20) (defining the term ‘‘walk-in 

cooler; walk-in freezer’’)) Due to this 

size limit, it is unlikely that a walk-in 

refrigeration system will contain over 50 

pounds of refrigerant, making 

application of the CARB provisions 

unlikely.22

b. Inventory Levels 

In the preliminary analysis, DOE 

determined from U.S. Census data that 

the end-of-year inventory for the airconditioning and warm air heating 

equipment and commercial and 

industrial refrigeration equipment 

manufacturing industry (NAICS code 

333415) was approximately 10 percent 

of shipment value from 2002 to 2007 

(U.S. Census Bureau Annual Survey of 

Manufacturers) and presented these data 

in Table 12.3.3 of chapter 12 in the 

preliminary TSD. American Panel 

expressed concerns that the inventory 

percentages shown in Table 12.3.3 of 

chapter 12 in the Preliminary TSD are 

inaccurate and noted that their end-ofyear inventory value has been only 2.5 

percent of annual shipment value on 

average. (American Panel, No. 0048.1 at 

p. 11) The U.S. Census percentages 

represent values for the air-conditioning 

and warm-air heating equipment and 

commercial and industrial refrigeration 

equipment manufacturing industry, 

which includes a wide range of 

products and companies. DOE agrees 

that the U.S. Census figures may not 

necessarily be representative of 

inventory levels for specific walk-in 

cooler and freezer manufacturers. The 

figure is used to characterize the 

industry and is not a component of any 

quantitative analysis. DOE has factored 

American Panel’s inventory number 

into its qualitative understanding of the 

walk-in industry. 

c. Manufacturer Subgroup Analysis 

AHRI suggested that DOE should 

enlarge the scope of the manufacturer 

impact analysis to examine the impact 

of the rulemaking on all manufacturers 

of different equipment classes— 

including panel, door, and refrigeration 

system manufacturers. (AHRI, Public 

Meeting Transcript, No. 0045 at p. 4) 

To better reflect the structure of the 

rulemaking, DOE has expanded its 

analysis of manufacturers to include the 

impact of the rulemaking on key 

component suppliers, including panel 

manufacturers, door manufacturers, and 

refrigeration system manufacturers. 

Additionally, small manufacturers of 

panels, doors, and refrigeration systems 

are considered as separate sub-groups in 

the MIA. 

4. Manufacturer Interviews 

As part of the MIA, DOE discussed 

potential impacts of standards with 

eight panel manufacturers, six door 

manufacturers, and three refrigeration 

systems manufacturers. In the 

interviews, DOE asked manufacturers to 

describe their major concerns about this 

rulemaking. The following sections 

discuss manufacturers’ most significant 

concerns. 

a. Cost of Testing 

All door, panel, and refrigeration 

manufacturers expressed concern 

regarding the cost of testing. The 

majority of walk-ins sold are not 

standard combinations of box sizes, 

refrigeration components, and doors. 

Almost every walk-in unit is tailored to 

meet consumer specifications. 

According to manufacturers, DOEmandated testing of every configuration 

sold is not realistic and could become 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55840 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

a financial burden that would negatively 

impact manufacturers’ profitability. 

The cost of compliance testing 

includes the engineering support 

necessary to design and run tests, the 

cost of the units tested, and the cost of 

third-party testing support. Some 

manufacturers indicated that it may be 

necessary to set up new test labs to deal 

with compliance requirements. Beyond 

DOE compliance testing, energy 

conservation standards may lead to 

product redesigns that require new 

certifications, such as Underwriters 

Laboratories (UL) fire safety, NSF 2 food 

service, and NSF 7 commercial 

refrigerator and freezer standards 

compliance. 

Multiple door, panel, and 

refrigeration manufacturers expressed 

concern that these compliance and 

certification testing costs may lead to 

less customization in the industry. As 

an example, one door manufacturer was 

concerned that walk-in manufacturers 

would offer fewer door choices and 

partner with fewer door companies to 

reduce testing burden. As another 

example, a manufacturer that produces 

only unit coolers indicated that the need 

to certify the complete refrigeration 

system would force them to leave the 

WICF market. As the unit cooler 

supplier, the manufacturer does not 

have the ability to certify the entire 

system because they do not supply the 

condensing unit portion of the system. 

Today, the manufacturer’s consumers 

pair the unit coolers with condensing 

units from other suppliers to assemble 

a walk-in refrigeration system. The 

manufacturer speculated that, in a 

regulated environment, their consumers 

would switch from buying refrigeration 

components from manufacturers of unit 

coolers to buying complete systems with 

matched unit coolers and condensing 

units from larger competitors that build 

complete systems rather than 

components. Their customers would 

make this change to avoid the test 

burden on refrigeration systems. Other 

manufacturers mentioned that the cost 

of testing could ultimately lead to 

conditions in which small panel 

manufacturers would be forced out of 

the market. 

Finally, walk-in manufacturers were 

concerned about pricing and availability 

of third-party testing. Several walk-in 

manufacturers noted that it is unclear 

whether a sufficient number of qualified 

third parties exist to carry out the 

performance testing mandated by DOE 

for the entire industry. One 

manufacturer was concerned that an 

insufficient number of test facilities 

would lead to higher testing costs and 

delays in achieving compliance. 

b. Enforcement and Compliance 

All of the interviewed manufacturers 

expressed concern that an energy 

conservation standard rulemaking could 

result in unfair competition if the 

standard is not properly enforced. 

Interviewed manufacturers claimed that 

numerous manufacturers, particularly 

small one-to-two person operations, are 

not currently complying with the 

existing walk-in regulations in EPCA, 

which took effect January 1, 2009. The 

manufacturers explained that smaller 

operations often have an incentive to be 

non-compliant. By using materials that 

do not comply with existing regulations, 

the non-compliant manufacturers 

maintain a price advantage over 

compliant manufacturers. 

Manufacturers emphasized the need 

to have well-defined compliance 

responsibilities. WICF units can be 

manufactured and delivered as per 

standard by the manufacturer, but the 

end user may decide to remove some of 

the efficiency features, such as strip 

curtains. Additionally, the quality of 

installation at the client site is often a 

factor that manufacturers cannot control 

because field assembly is managed by 

contractors. Manufacturers also noted 

that, for some installations, the 

contractors purchase the walk-in 

envelope and refrigeration equipment 

from separate suppliers, making it 

impossible for the equipment 

manufacturers to determine the 

efficiency of the installed product. 

Multiple manufacturers requested 

clarification to better understand which 

party bears responsibility for ensuring 

field-assembled walk-ins meet federal 

standards. 

In this NOPR, DOE discusses issues 

surrounding compliance and 

enforcement. In particular, DOE 

proposes that each component 

manufacturer would be responsible for 

certifying to DOE that the components 

they manufacture comply with the 

standards. DOE believes that the 

component-based approach provides for 

effective certification and enforcement 

of any standards while ensuring that the 

walk-in industry has sufficient 

flexibility to meet the applicable 

standards. For more details on DOE’s 

proposed approach, see section III.D. 

c. Profitability Impacts 

Walk-in manufacturers discussed how 

new energy conservation standards 

could affect profit levels. Manufacturers 

considered the walk-in industry to be a 

low margin-business. Price competition 

can be very aggressive, particularly for 

large orders and for name-brand client 

accounts. Manufacturers stated that low 

margins leave little room for the added 

costs that energy conservation standards 

could impose. Manufacturers noted that 

they will have to absorb the additional 

costs or pass the costs onto the 

consumer. 

Specifically, manufacturers 

emphasized their concerns about the 

impact of thicker panels, thicker doors, 

and more efficient refrigeration on 

profitability. Thicker panels require 

more material and longer processing 

times. The end result could be a 

reduction in factory throughput coupled 

with increased cost. Additionally, 

manufacturers noted that thicker panels 

are heavier, which leads to higher 

shipping costs. Similar concerns exist 

for solid doors. To achieve higher 

refrigeration efficiencies, manufacturers 

would have to purchase larger coils, 

more efficient compressors, and more 

expensive control systems. All these 

components increase the cost of goods 

sold for the completed walk-in. 

Manufacturers speculated that passing 

all these costs onto their customers 

would lead to lower-volume orders, as 

consumers with set budgets would not 

be able to purchase as many walk-ins (in 

the case of chain stores) or as much 

walk-in space (in the case of individual 

operations) for the same dollar amount. 

Alternatively, absorbing these costs 

would significantly reduce profit 

margins. 

In the manufacturer impact analysis, 

DOE has examined the impacts of 

standards on manufacturers’ profit 

margins. For the results of DOE’s 

analysis, see section V.B.2.a. 

d. Excessive Conversion Cost 

According to panel manufacturers, a 

new energy conservation standard that 

requires increased levels of thickness 

could result in high conversion costs. 

Much of the existing production 

equipment is designed to produce 

panels 3.5–5 inches thick. Panels that 

are 6 or more inches thick are less 

common in the industry. Any standard 

that results in the market moving to 5- 

inch thick panels would require some 

conversion cost as factories that use 

foam-in-place technology must 

accommodate increased curing times. 

Manufacturers indicated that the 

conversion costs could range from 

$100,000 to $500,000, depending on the 

manufacturer’s existing equipment. Any 

standard that requires 6-inch thick 

panels would involve significant 

additional investment by most 

manufacturers. At this level of 

thickness, manufacturers estimate 

conversion costs would range from 

$200,000 to $1 million. Any standard 

that requires 7-inch thick panels would 


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require all manufacturers to reevaluate 

their manufacturing process. Conversion 

costs would range from $1.5 million to 

$4 million. Based on manufacturer 

statements, any standard that moved the 

industry to 6-inch thick panels would 

likely put some of the top 10 panel 

manufacturers out of business. 

DOE considers conversion costs in the 

manufacturer impact analysis. For 

details on DOE’s findings, see section 

V.B.2.a. 

e. Disproportionate Impact on Small 

Businesses 

Most interviewed manufacturers 

noted that new energy conservation 

standards could have a disproportionate 

impact on small businesses as compared 

to larger businesses. The cost of testing, 

the potential increase in materials, and 

the potential need to obtain financing 

are the factors that could affect small 

business manufacturers producing 

refrigeration systems, panels, and doors 

more severely. 

Manufacturers voiced concerns 

regarding the cost of both compliance 

testing and certification testing (e.g., UL 

and NSF certifications) on small 

businesses. According to manufacturers, 

the price tag for testing is likely to be 

similar for both small and large 

companies due to the high level of 

product customization in the industry. 

For small businesses, the cost will 

spread across smaller sales volumes, 

making recuperation of the testing 

investment more difficult. Some 

manufacturers thought that compliance 

testing costs alone could force small 

manufacturers to exit the industry. 

Additionally, small manufacturers 

indicated that they face a significant 

price disadvantage for foaming agents 

(used for insulation) and components 

due to their small purchasing quantities 

when compared to large manufacturers. 

Any standard that requires small 

manufacturers to use more foam or more 

expensive components will exacerbate 

the pricing gap. Given the pricesensitive nature and low margin of the 

industry, the small envelope 

manufacturers were concerned that 

requiring thicker panels provided a 

competitive advantage to large 

manufacturers that could obtain 

foaming agents at a lower price based on 

order quantities that are of larger 

magnitude. 

Several interviewed manufacturers 

expressed concern that the current 

tightness in financial markets and 

reduced economic activity could 

negatively impact their ability to obtain 

the financing necessary to cover 

compliance costs, particularly for small 

business operations, which generally 

have greater difficulty obtaining 

financing. 

DOE has examined the impact on 

small manufacturers in its manufacturer 

sub-group analysis and regulatory 

flexibility analysis. For the results of 

these analyses, see sections V.B.2.d and 

VI.B. 

f. Refrigerant Phase-Out 

Interviewed manufacturers noted the 

impacts of mandated changes in 

blowing agents and refrigerants. 

Currently, walk-in manufacturers use 

HFC–404 and HFC–134a refrigerants. 

While HFC–404 is used exclusively as a 

refrigerant, HFC–134a is used as both a 

refrigerant and a blowing agent in the 

walk-in manufacturing industry. 

Several manufacturers expressed 

concern about the impact of a potential 

phase-down or phase-out of HFCs. The 

concern is acute because manufacturers 

stated that there is no clear alternative 

or substitute to HFCs for the industry. 

Without a clear replacement, 

manufacturers are concerned that any 

phase-out would create a period of 

uncertainty as the industry identifies 

suitable alternatives and then redesigns 

both products and processes around the 

replacement. In the manufacturers’ 

experience, past phase-outs have led to 

more expensive and less efficient 

refrigerant replacements. 

Panel manufacturers expressed 

concern that conversion to a new 

blowing agent would be costly as they 

would have to go through a transition 

period in which foam would need to be 

reformulated. Production processes and 

facilities would need to adapt to the 

new foam blend. Manufactures stated 

that previous, replacement blowing 

agents have been more expensive and 

have presented challenges to the 

production process because of different 

flow characteristics from the agents they 

replace. They also noted that blowing 

agent substitutes have led to foam 

blends with lower R-value, providing 

less insulation. Panel manufacturers 

were concerned that lower insulation 

effectiveness results in thicker panels 

needed to meet a standard, which leads 

to increased production cost and lower 

profit margins. 

Refrigeration system manufacturers 

expressed that an HFC phase-out would 

be costly as it would require redesign of 

all products. Some manufacturers stated 

that an HFC phase-out would force them 

to use flammable refrigerants. 

Manufacturers noted that some 

alternative refrigerants may require 

substantially larger systems to achieve 

the same levels of performance. 

As discussed in section IV.A.2.b, DOE 

has only considered HFC refrigerants in 

the analysis. DOE did not consider 

whether foam blowing agents would 

cost more, less or stay the same and 

DOE understands there is a range of 

non-HFC foam blowing used already in 

these applications. 

J. Employment Impact Analysis 

Employment impacts are one factor 

DOE considers in selecting an efficiency 

standard. Employment impacts include 

direct and indirect impacts. Direct 

employment impacts are any changes 

that affect employment of WICF 

manufacturers. Indirect impacts are 

those employment changes in the larger 

economy that occur because of the shift 

in expenditures and capital investment 

caused by the purchase and operation of 

more efficient walk-ins. The MIA results 

in section V.B.2.b of this notice and 

chapter 12 of the TSD address only the 

direct employment impacts on walk-in 

manufacturers. Chapter 13 of the TSD 

provides further information about 

other, primarily indirect, employment 

impacts discussed in this section. 

Indirect employment impacts from 

WICF standards consist of the net jobs 

created or eliminated in the national 

economy, excluding the manufacturing 

sector being regulated, as a consequence 

of (1) reduced spending by end-users on 

electricity, which could potentially be 

offset by the increased spending on 

maintenance and repair of higher 

efficiency equipment); (2) reduced 

spending on new energy supply by the 

utility industry; (3) increased spending 

on the purchase price of new walk-in 

coolers and freezers; and (4) the effects 

of those three factors throughout the 

economy. DOE expects the net monetary 

savings from standards to stimulate 

other forms of economic activity. DOE 

also expects these shifts in spending 

and economic activity to affect the 

demand for labor. 

In developing this analysis in the 

NOPR, DOE estimated indirect national 

employment impacts using an input/

output model of the U.S. economy, 

called ImSET (Impact of Sector Energy 

Technologies) developed by DOE’s 

Building Technologies Program. ImSET 

is a personal-computer based, economic 

analysis model that characterizes the 

interconnections among 188 sectors of 

the economy as national input/output 

structural matrices using data from the 

U.S. Department of Commerce’s 1997 

Benchmark U.S. input-output table. The 

ImSET model estimates changes in 

employment, industry output, and wage 

income in the overall U.S. economy 

resulting from changes in expenditures 

in various sectors of the economy. DOE 

estimated changes in expenditures using 

the NIA model. ImSET then estimated 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55842 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

23On July 20, 2012, EPA announced a partial 

stay, for a limited duration, of the effectiveness of 

national new source emission standards for 

hazardous air pollutants from coal- and oil-fired 

electric utility steam generating units. http://

www.epa.gov/airquality/powerplanttoxics/pdfs/

20120727staynotice.pdf. 

the net national indirect employment 

impacts efficiency standards would 

have on employment by sector. 

The ImSET input/output model 

suggests that the proposed standards 

could increase the net demand for labor 

in the economy, and the gains would 

most likely be very small relative to 

total national employment. For more 

details on the employment impact 

analysis and its results, see chapter 13 

of the TSD and section IV.J of this 

notice. 

K. Utility Impact Analysis 

The utility impact analysis estimates 

several important effects on the utility 

industry of the adoption of new or 

amended standards. For this analysis, 

DOE used the NEMS–BT model to 

generate forecasts of electricity 

consumption, electricity generation by 

plant type, and electric generating 

capacity by plant type, that would result 

from each considered TSL. DOE 

obtained the energy savings inputs 

associated with efficiency 

improvements to considered products 

from the NIA. DOE conducts the utility 

impact analysis as a scenario that 

departs from the latest AEO Reference 

case. In the analysis for today’s rule, the 

estimated impacts of standards are the 

differences between values forecasted 

by NEMS–BT and the values in the 

AEO2013 Reference case. For more 

details on the utility impact analysis, 

see chapter 14 of the TSD. 

L. Emissions Analysis 

In the emissions analysis, DOE 

estimates the reduction in power sector 

emissions of carbon dioxide (CO2), 

nitrogen oxides (NOX), sulfur dioxide 

(SO2), and mercury (Hg) from potential 

energy conservation standards for walkin coolers and freezers. In addition, DOE 

estimates emissions impacts in 

production activities (extracting, 

processing, and transporting fuels) that 

provide the energy inputs to power 

plants. These are referred to as 

‘‘upstream’’ emissions. Together, these 

emissions account for the full-fuel-cycle 

(FFC). In accordance with DOE’s FFC 

Statement of Policy (76 FR 51282 (Aug. 

18, 2011)), the FFC analysis includes 

impacts on emissions of methane (CH4) 

and nitrous oxide (N2O), both of which 

are recognized as greenhouse gases. 

DOE conducted the emissions 

analysis using emissions factors that 

were derived from data in EIA’s Annual 

Energy Outlook 2013 (AEO 2013), 

supplemented by data from other 

sources. DOE developed separate 

emissions factors for power sector 

emissions and upstream emissions. The 

method that DOE used to derive 

emissions factors is described in chapter 

15 of the NOPR TSD. 

EIA prepares the Annual Energy 

Outlook using the National Energy 

Modeling System (NEMS). Each annual 

version of NEMS incorporates the 

projected impacts of existing air quality 

regulations on emissions. AEO 2013 

generally represents current legislation 

and environmental regulations, 

including recent government actions, for 

which implementing regulations were 

available as of December 31, 2011. 

SO2 emissions from affected electric 

generating units (EGUs) are subject to 

nationwide and regional emissions capand-trade programs. Title IV of the 

Clean Air Act sets an annual emissions 

cap on SO2 for affected EGUs in the 48 

contiguous States and the District of 

Columbia (DC). SO2 emissions from 28 

eastern states and DC were also limited 

under the Clean Air Interstate Rule 

(CAIR; 70 FR 25162 (May 12, 2005)), 

which created an allowance-based 

trading program that operates along 

with the Title IV program. CAIR was 

remanded to the U.S. Environmental 

Protection Agency (EPA) by the U.S. 

Court of Appeals for the District of 

Columbia Circuit but it remained in 

effect. See North Carolina v. EPA, 550 

F.3d 1176 (DC Cir. 2008); North 

Carolina v. EPA, 531 F.3d 896 (DC Cir. 

2008). On August 21, 2012, the DC 

Circuit issued a decision to vacate 

CSAPR. See EME Homer City 

Generation, LP v. EPA, 696 F.3d 7, 38 

(DC Cir. 2012). The court ordered EPA 

to continue administering CAIR. The 

AEO 2013 emissions factors used for 

today’s NOPR assume that CAIR 

remains a binding regulation through 

2040. 

The attainment of emissions caps is 

typically flexible among EGUs and is 

enforced through the use of emissions 

allowances and tradable permits. Under 

existing EPA regulations, any excess 

SO2 emissions allowances resulting 

from the lower electricity demand 

caused by the adoption of an efficiency 

standard could be used to permit 

offsetting increases in SO2 emissions by 

any regulated EGU. In past rulemakings, 

DOE recognized that there was 

uncertainty about the effects of 

efficiency standards on SO2 emissions 

covered by the existing cap-and-trade 

system, but it concluded that negligible 

reductions in power sector SO2

emissions would occur as a result of 

standards. 

Beginning in 2015, however, SO2

emissions will fall as a result of the 

Mercury and Air Toxics Standards 

(MATS) for power plants, which were 

announced by EPA on December 21, 

2011. 77 FR 9304 (Feb. 16, 2012).23 In 

the final MATS rule, EPA established a 

standard for hydrogen chloride as a 

surrogate for acid gas hazardous air 

pollutants (HAP), and also established a 

standard for SO2 (a non-HAP acid gas) 

as an alternative equivalent surrogate 

standard for acid gas HAP. The same 

controls are used to reduce HAP and 

non-HAP acid gas; thus, SO2 emissions 

will be reduced as a result of the control 

technologies installed on coal-fired 

power plants to comply with the MATS 

requirements for acid gas. AEO 2013 

assumes that, in order to continue 

operating, coal plants must have either 

flue gas desulfurization or dry sorbent 

injection systems installed by 2015. 

Both technologies, which are used to 

reduce acid gas emissions, also reduce 

SO2 emissions. Under the MATS, NEMS 

shows a reduction in SO2 emissions 

when electricity demand decreases (e.g., 

as a result of energy efficiency 

standards). Emissions will be far below 

the cap that would be established by 

CSAPR, so it is unlikely that excess SO2

emissions allowances resulting from the 

lower electricity demand would be 

needed or used to permit offsetting 

increases in SO2 emissions by any 

regulated EGU. Therefore, DOE believes 

that efficiency standards will reduce 

SO2 emissions in 2015 and beyond. 

CSAPR established a cap on NOX

emissions in 28 eastern States and the 

District of Columbia. Energy 

conservation standards are expected to 

have little effect on NOX emissions in 

those States covered by CSAPR because 

excess NOX emissions allowances 

resulting from the lower electricity 

demand could be used to permit 

offsetting increases in NOX emissions. 

However, standards would be expected 

to reduce NOX emissions in the States 

not affected by the caps, so DOE 

estimated NOX emissions reductions 

from the standards considered in 

today’s NOPR for these States. 

The MATS limit mercury emissions 

from power plants, but they do not 

include emissions caps and, as such, 

DOE’s energy conservation standards 

would likely reduce Hg emissions. DOE 

estimated mercury emissions reduction 

using emissions factors based on AEO 

2013, which incorporates the MATS. 


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24National Research Council. Hidden Costs of 

Energy: Unpriced Consequences of Energy 

Production and Use. National Academies Press: 

Washington, DC (2009). 

25See Average Fuel Economy Standards 

Passenger Cars and Light Trucks Model Year 2011, 

74 FR 14196 (March 30, 2009) (Final Rule); Final 

Environmental Impact Statement Corporate Average 

Fuel Economy. 

26See, Average Fuel Economy Standards, 

Passenger Cars and Light Trucks, Model Years 

2011–2015, 73 FR 24352 (May 2, 2008) (Proposed 

Rule); Draft Environmental Impact Statement 

Corporate Average Fuel Economy Standards, 

Passenger Cars and Light Trucks, Model Years 

2011–2015 at 3–58 (June 2008) (Available at: 

http://www.nhtsa.gov/fuel-economy) 

M. Monetizing Carbon Dioxide and 

Other Emissions Impacts 

As part of the development of this 

amended rule, DOE considered the 

estimated monetary benefits likely to 

result from the reduced emissions of 

CO2 and NOX that are expected to result 

from each of the TSLs considered. In 

order to make this calculation similar to 

the calculation of the NPV of consumer 

benefit, DOE considered the reduced 

emissions expected to result over the 

lifetime of products shipped in the 

forecast period for each TSL. This 

section summarizes the basis for the 

monetary values used for each of these 

emissions and presents the values 

considered in this rulemaking. 

For today’s NOPR, DOE is relying on 

a set of values for the social cost of 

carbon (SCC) that was developed by an 

interagency process. A summary of the 

basis for these values is provided below, 

and a more detailed description of the 

methodologies used is provided as an 

appendix to chapter 16 of the TSD. 

1. Social Cost of Carbon 

The SCC is an estimate of the 

monetized damages associated with an 

incremental increase in carbon 

emissions in a given year. It is intended 

to include (but is not limited to) changes 

in net agricultural productivity, human 

health, property damages from 

increased flood risk, and the value of 

ecosystem services. Estimates of the 

SCC are provided in dollars per metric 

ton of carbon dioxide. A domestic SCC 

value is meant to reflect the value of 

damages in the United States resulting 

from a unit change in carbon dioxide 

emissions, while a global SCC value is 

meant to reflect the value of damages 

worldwide. 

Under section 1(b) of Executive Order 

12866, agencies must, to the extent 

permitted by law, ‘‘assess both the costs 

and the benefits of the intended 

regulation and, recognizing that some 

costs and benefits are difficult to 

quantify, propose or adopt a regulation 

only upon a reasoned determination 

that the benefits of the intended 

regulation justify its costs.’’ The purpose 

of the SCC estimates presented here is 

to allow agencies to incorporate the 

monetized social benefits of reducing 

CO2 emissions into cost-benefit analyses 

of regulatory actions that have small, or 

‘‘marginal,’’ impacts on cumulative 

global emissions. The estimates are 

presented with an acknowledgement of 

the many uncertainties involved and 

with a clear understanding that they 

should be updated over time to reflect 

increasing knowledge of the science and 

economics of climate impacts. 

As part of the interagency process that 

developed these SCC estimates, 

technical experts from numerous 

agencies met on a regular basis to 

consider public comments, explore the 

technical literature in relevant fields, 

and discuss key model inputs and 

assumptions. The main objective of this 

process was to develop a range of SCC 

values using a defensible set of input 

assumptions grounded in the existing 

scientific and economic literatures. In 

this way, key uncertainties and model 

differences transparently and 

consistently inform the range of SCC 

estimates used in the rulemaking 

process. 

a. Monetizing Carbon Dioxide Emissions 

When attempting to assess the 

incremental economic impacts of carbon 

dioxide emissions, the analyst faces a 

number of serious challenges. A report 

from the National Research Council 24

points out that any assessment will 

suffer from uncertainty, speculation, 

and lack of information about (1) future 

emissions of greenhouse gases, (2) the 

effects of past and future emissions on 

the climate system, (3) the impact of 

changes in climate on the physical and 

biological environment, and (4) the 

translation of these environmental 

impacts into economic damages. As a 

result, any effort to quantify and 

monetize the harms associated with 

climate change will raise serious 

questions of science, economics, and 

ethics and should be viewed as 

provisional. 

Despite the serious limits of both 

quantification and monetization, SCC 

estimates can be useful in estimating the 

social benefits of reducing carbon 

dioxide emissions. Most Federal 

regulatory actions can be expected to 

have marginal impacts on global 

emissions. For such policies, the agency 

can estimate the benefits from reduced 

(or costs from increased) emissions in 

any future year by multiplying the 

change in emissions in that year by the 

SCC value appropriate for that year. The 

net present value of the benefits can 

then be calculated by multiplying each 

of these future benefits by an 

appropriate discount factor and 

summing across all affected years. This 

approach assumes that the marginal 

damages from increased emissions are 

constant for small departures from the 

baseline emissions path, an 

approximation that is reasonable for 

policies that have effects on emissions 

that are small relative to cumulative 

global carbon dioxide emissions. For 

policies that have a large (non-marginal) 

impact on global cumulative emissions, 

there is a separate question of whether 

the SCC is an appropriate tool for 

calculating the benefits of reduced 

emissions. This concern is not 

applicable to this notice, however. 

It is important to emphasize that the 

interagency process is committed to 

updating these estimates as the science 

and economic understanding of climate 

change and its impacts on society 

improves over time. In the meantime, 

the interagency group will continue to 

explore the issues raised by this analysis 

and consider public comments as part of 

the ongoing interagency process. 

b. Social Cost of Carbon Values Used in 

Past Regulatory Analyses 

Economic analyses for Federal 

regulations have used a wide range of 

values to estimate the benefits 

associated with reducing carbon dioxide 

emissions. The model year 2011 

Corporate Average Fuel Economy final 

rule, the U.S. Department of 

Transportation (DOT) used both a 

‘‘domestic’’ SCC value of $2 per metric 

ton of CO2 and a ‘‘global’’ SCC value of 

$33 per metric ton of CO2 for 2007 

emission reductions (in 2007$), 

increasing both values at 2.4 percent per 

year. DOT also included a sensitivity 

analysis at $80 per metric ton of CO2.25

A 2008 regulation proposed by DOT 

assumed a domestic SCC value of $7 per 

metric ton of CO2 (in 2006$) for 2011 

emission reductions (with a range of $0– 

$14 for sensitivity analysis), also 

increasing at 2.4 percent per year.26 A 

regulation for packaged terminal air 

conditioners and packaged terminal 

heat pumps finalized by DOE in 2008 

used a domestic SCC range of $0 to $20 

per metric ton CO2 for 2007 emission 

reductions (in 2007$). 73 FR 58772, 

58814 (Oct. 7, 2008) In addition, EPA’s 

2008 Advance Notice of Proposed 

Rulemaking on Regulating Greenhouse 

Gas Emissions Under the Clean Air Act 

identified what it described as ‘‘very 

preliminary’’ SCC estimates subject to 

revision. 73 FR 44354 (July 30, 2008). 

EPA’s global mean values were $68 and 


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27 It is recognized that this calculation for 

domestic values is approximate, provisional, and 

highly speculative. There is no a priori reason why 

domestic benefits should be a constant fraction of 

net global damages over time. 28Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United 

States Government, February 2010. http://

www.whitehouse.gov/sites/default/files/omb/

inforeg/for-agencies/Social-Cost-of-Carbon-forRIA.pdf. 29Technical Update of the Social Cost of Carbon 

for Regulatory Impact Analysis Under Executive 

Order 12866. Interagency Working Group on Social 

Cost of Carbon, United States Government. May 

2013. http://www.whitehouse.gov/sites/default/

files/omb/inforeg/social_cost_of_carbon_for_ria_

2013_update.pdf. 

$40 per metric ton CO2 for discount 

rates of approximately 2 percent and 3 

percent, respectively (in 2006$ for 2007 

emissions). 

In 2009, an interagency process was 

initiated to offer a preliminary 

assessment of how best to quantify the 

benefits from reducing carbon dioxide 

emissions. To ensure consistency in 

how benefits are evaluated across 

agencies, the Administration sought to 

develop a transparent and defensible 

method, specifically designed for the 

rulemaking process, to quantify avoided 

climate change damages from reduced 

CO2 emissions. The interagency group 

did not undertake any original analysis. 

Instead, it combined SCC estimates from 

the existing literature to use as interim 

values until a more comprehensive 

analysis could be conducted. The 

outcome of the preliminary assessment 

by the interagency group was a set of 

five interim values: global SCC 

estimates for 2007 (in 2006$) of $55, 

$33, $19, $10, and $5 per metric ton of 

CO2. These interim values represented 

the first sustained interagency effort 

within the U.S. government to develop 

an SCC for use in regulatory analysis. 

The results of this preliminary effort 

were presented in several proposed and 

final rules. 

c. Current Approach and Key 

Assumptions 

Since the release of the interim 

values, the interagency group 

reconvened on a regular basis to 

generate improved SCC estimates. 

Specifically, the group considered 

public comments and further explored 

the technical literature in relevant 

fields. The interagency group relied on 

three integrated assessment models 

commonly used to estimate the SCC: the 

FUND, DICE, and PAGE models. These 

models are frequently cited in the peerreviewed literature and were used in the 

last assessment of the Intergovernmental 

Panel on Climate Change. Each model 

was given equal weight in the SCC 

values that were developed. 

Each model takes a slightly different 

approach to model how changes in 

emissions result in changes in economic 

damages. A key objective of the 

interagency process was to enable a 

consistent exploration of the three 

models while respecting the different 

approaches to quantifying damages 

taken by the key modelers in the field. 

An extensive review of the literature 

was conducted to select three sets of 

input parameters for these models: 

climate sensitivity, socio-economic and 

emissions trajectories, and discount 

rates. A probability distribution for 

climate sensitivity was specified as an 

input into all three models. In addition, 

the interagency group used a range of 

scenarios for the socio-economic 

parameters and a range of values for the 

discount rate. All other model features 

were left unchanged, relying on the 

model developers’ best estimates and 

judgments. 

The interagency group selected four 

sets of SCC values for use in regulatory 

analyses. Three sets of values are based 

on the average SCC from the three 

integrated assessment models, at 

discount rates of 2.5, 3, and 5 percent. 

The fourth set, which represents the 

95th percentile SCC estimate across all 

three models at a 3-percent discount 

rate, is included to represent higherthan-expected impacts from temperature 

change further out in the tails of the 

SCC distribution. The values estimated 

for 2010 grow in real terms over time, 

as depicted in Table IV–17. 

Additionally, the interagency group 

determined that a range of values from 

7 percent to 23 percent should be used 

to adjust the global SCC to calculate 

domestic effects,27 although preference 

is given to consideration of the global 

benefits of reducing CO2 emissions. 

Table IV–17 presents the values in the 

2010 interagency group report,28 which 

is reproduced in appendix 16–A of the 

NOPR TSD. 

TABLE IV–17—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050 

[In 2007 dollars per metric ton] 

Discount rate 

5% 3% 2.5% 3% 

Average Average Average 

95th 

percentile 

2010 ................................................................................................................................. 4.7 21.4 35.1 64.9 

2015 ................................................................................................................................. 5.7 23.8 38.4 72.8 

2020 ................................................................................................................................. 6.8 26.3 41.7 80.7 

2025 ................................................................................................................................. 8.2 29.6 45.9 90.4 

2030 ................................................................................................................................. 9.7 32.8 50.0 100.0 

2035 ................................................................................................................................. 11.2 36.0 54.2 109.7 

2040 ................................................................................................................................. 12.7 39.2 58.4 119.3 

2045 ................................................................................................................................. 14.2 42.1 61.7 127.8 

2050 ................................................................................................................................. 15.7 44.9 65.0 136.2 

The SCC values used for today’s 

notice were generated using the most 

recent versions of the three integrated 

assessment models that have been 

published in the peer-reviewed 

literature.29 Table IV–18 shows the 

updated sets of SCC estimates in five 

year increments from 2010 to 2050. The 

full set of annual SCC estimates between 

2010 and 2050 is reported in appendix 

16–A of the NOPR TSD. The central 

value that emerges is the average SCC 

across models at the 3 percent discount 

rate. However, for purposes of capturing 

the uncertainties involved in regulatory 

impact analysis, the interagency group 

emphasizes the importance of including 

all four sets of SCC values. 


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30For additional information, refer to U.S. Office 

of Management and Budget, Office of Information 

and Regulatory Affairs, 2006 Report to Congress on 

the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal 

Entities, Washington, DC. 

31OMB, Circular A–4: Regulatory Analysis (Sept. 

17, 2003). 

TABLE IV–18—ANNUAL SCC VALUES FROM 2013 INTERAGENCY UPDATE, 2010–2050 

[In 2007 dollars per metric ton CO2] 

Year 

Discount rate % 

5 3 2.5 3 

Average Average Average 

95th 

percentile 

2010 ................................................................................................................................. 11 33 52 90 

2015 ................................................................................................................................. 12 38 58 109 

2020 ................................................................................................................................. 12 43 65 129 

2025 ................................................................................................................................. 14 48 70 144 

2030 ................................................................................................................................. 16 52 76 159 

2035 ................................................................................................................................. 19 57 81 176 

2040 ................................................................................................................................. 21 62 87 192 

2045 ................................................................................................................................. 24 66 92 206 

2050 ................................................................................................................................. 27 71 98 221 

It is important to recognize that a 

number of key uncertainties remain, and 

that current SCC estimates should be 

treated as provisional and revisable 

since they will evolve with improved 

scientific and economic understanding. 

The interagency group also recognizes 

that the existing models are imperfect 

and incomplete. The National Research 

Council report mentioned above points 

out that there is tension between the 

goal of producing quantified estimates 

of the economic damages from an 

incremental ton of carbon and the limits 

of existing efforts to model these effects. 

There are a number of concerns and 

problems that should be addressed by 

the research community, including 

research programs housed in many of 

the Federal agencies participating in the 

interagency process to estimate the SCC. 

The interagency group intends to 

periodically review and reconsider 

those estimates to reflect increasing 

knowledge of the science and 

economics of climate impacts, as well as 

improvements in modeling. 

In summary, in considering the 

potential global benefits resulting from 

reduced CO2 emissions, DOE used the 

values from the 2013 interagency report, 

adjusted to 2012$ using the GDP price 

deflator. For each of the four cases 

specified, the values used for emissions 

in 2015 were $12.9, $40.8, $62.2, and 

$117 per metric ton avoided (values 

expressed in 2012$). DOE derived 

values after 2050 using the relevant 

growth rates for the 2040–2050 period 

in the interagency update. 

DOE multiplied the CO2 emissions 

reduction estimated for each year by the 

SCC value for that year in each of the 

four cases. To calculate a present value 

of the stream of monetary values, DOE 

discounted the values in each of the 

four cases using the specific discount 

rate that had been used to obtain the 

SCC values in each case. 

2. Valuation of Other Emissions 

Reductions 

DOE investigated the potential 

monetary benefit of reduced NOX

emissions from the potential standards 

it considered. As noted above, DOE has 

taken into account how new or 

amended energy conservation standards 

would reduce NOX emissions in those 

22 states not affected by the CAIR. DOE 

estimated the monetized value of NOX

emissions reductions resulting from 

each of the TSLs considered for today’s 

NOPR based on estimates found in the 

relevant scientific literature. Available 

estimates suggest a very wide range of 

monetary values per ton of NOX from 

stationary sources, ranging from $468 to 

$4809 per ton in 2012$).30 In 

accordance with OMB guidance,31 DOE 

calculated the monetary benefits using 

each of the economic values for NOX

and real discount rates of 3 percent and 

7 percent. 

DOE is evaluating appropriate 

monetization of SO2 and Hg emissions 

in energy conservation standards 

rulemakings. It has not included 

monetization in the current analysis. 

V. Analytical Results 

A. Trial Standard Levels 

As discussed in section III.B, DOE is 

proposing to set separate performance 

standards for the refrigeration system 

and for the envelope’s doors and panels. 

The manufacturers of these components 

would be required to comply with the 

applicable performance standards. For a 

fully assembled WICF unit in service, 

the aggregate energy consumption 

would depend on the individual 

efficiency levels of both the refrigeration 

system and the components of the 

envelope. 

The refrigeration system removes heat 

from the interior of the envelope and 

accounts for most of the walk-in’s 

energy consumption. However, the 

refrigeration system and envelope 

interact with each other and affect each 

other’s energy performance. On the one 

hand, because the envelope components 

reduce the transmission of heat from the 

exterior to the interior of the walk-in, 

the energy savings benefit for any 

efficiency improvement for these 

envelope components depends on the 

efficiency level of the refrigeration 

system. Thus, any potential standard 

level for the refrigeration system would 

affect the energy that could be saved 

through standards for the envelope 

components. On the other hand, the 

economics of higher-efficiency 

refrigeration systems depend on the 

refrigeration load profile of the WICF 

unit as a whole, which is partially 

impacted by the envelope components. 

To accurately characterize the total 

benefits and burdens for each of its 

proposed standard levels, DOE 

developed TSLs that each consist of a 

combination of standard levels for both 

the refrigeration system and the set of 

envelope components that comprise a 

walk-in. In other words, each TSL DOE 

proposes in this NOPR consists of a 

standard for refrigeration systems, a 

standard for panels, a standard for nondisplay doors, and a standard for 

display doors. 

1. Trial Standard Level Selection 

Process 

The paragraphs that follow describe 

how DOE selected the TSLs. First, DOE 

selected seven potential levels for 

refrigeration systems by performing LCC 

and NIA analyses for refrigeration 


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systems. Second, DOE selected four 

levels for the envelope components by 

performing LCC and NIA analyses for 

the envelope components paired with 

each of the seven selected refrigeration 

system levels alone. Third, DOE chose 

six composite TSLs from the 

combinations of the seven potential 

levels for the refrigeration systems and 

the four potential levels for the envelope 

components. This process accounts for 

the fact that, as described above, the 

choice of refrigeration efficiency level 

affects the energy savings and NPV of 

the envelope component levels. These 

steps are described below. 

In selecting potential levels for the 

refrigeration systems, DOE focused on 

certain capacity points in the range it 

considered in the engineering analysis. 

(For a list of all points considered in the 

engineering analysis, see section 

IV.C.1.b.) In selecting the refrigeration 

capacity points for further analysis, DOE 

chose capacities with the highest 

relative shares of shipments in each 

equipment class. The proposed standard 

levels for each equipment class were 

then based on the analyzed capacities in 

each capacity range. The cost-efficiency 

tradeoff for the design options is similar 

over the range of sizes analyzed in the 

engineering analysis. 

TABLE V–1—REFRIGERATION

EQUIPMENT CLASS CAPACITIES

Equipment class 

Analyzed 

capacities 

(kBtu/hr) 

DC.M.I, < 9,000 ........................ 6 

DC.M.I, ≥ 9,000 ........................ 18 

DC.M.O, < 9,000 ...................... 6 

DC.M.O, ≥ 9,000 ...................... 18,54 

DC.L.I, < 9,000 ......................... 6 

DC.L.I, ≥ 9,000 ......................... 9 

DC.L.O, < 9,000 ....................... 6 

DC.L.O, ≥ 9,000 ....................... 9,54 

MC.M ........................................ 9 

MC.L ......................................... 9 

DOE enumerated seven potential 

levels for each of the refrigeration 

system classes. Each analyzed capacity 

point in any refrigeration system class 

has between 3 and 13 efficiency levels, 

each corresponding to an added 

applicable design option (described in 

section IV.C). DOE also analyzed three 

competing compressor technologies for 

each dedicated condensing refrigeration 

system class. These compressor 

technologies are: hermetic reciprocating, 

semi-hermetic, and scroll. 

At a given efficiency level, the 

compressor with the best life-cycle cost 

result was selected to represent the 

equipment at that efficiency level. From 

the set of possible efficiency levels for 

a given class, DOE selected seven for 

further analysis. For analyzed 

equipment having less than seven 

engineering design options (e.g., in the 

multiplex refrigeration system classes), 

the same efficiency level appeared more 

than once in the suite of seven 

efficiency levels. Five of the seven 

refrigeration system levels were based 

on their relative energy saving potential. 

The other two were based on 

maximizing the national net present 

value (‘‘Max NPV’’), and on achieving 

the maximum energy savings that is 

possible using all of the compressor 

technologies (‘‘All Compressors’’). 

DOE decided to include an allcompressors criterion for the 

refrigeration systems in response to 

stakeholder comments that DOE did not 

consider all types of compressors in the 

preliminary analysis (these comments 

were discussed in sections IV.C.4.b and 

IV.C.5.b). In particular, interested 

parties noted that the choice of 

compressor could affect the potential 

energy savings, but that it was 

inappropriate to treat compressor choice 

as a design option because not all 

compressor types are available at all 

capacities for all types of equipment. In 

response to these comments, DOE 

developed performance curves in the 

engineering analysis for refrigeration 

systems with each compressor type 

independently—identifying the 

maximum efficiency level for systems 

with each compressor type. The highest 

refrigeration system efficiency level that 

could be obtained by any compressor 

type for a given capacity unit was 

identified. In its set of TSL options, DOE 

included a highest efficiency level for 

the refrigeration systems at which all 

compressor technologies can compete 

(‘‘All Compressors’’). See chapter 10 of 

the TSD for further details on DOE’s 

process for selecting potential TSLs. 

After the seven potential efficiency 

levels for each refrigeration system class 

were selected as described above, DOE 

proceeded with the LCC and NIA 

analysis of the envelope components 

(panels and doors). DOE conducted the 

LCC and NIA analyses on the envelope 

components by pairing them with each 

of the seven refrigeration system 

efficiency levels. Each panel and door 

class has between five and nine 

potential efficiency levels, each 

corresponding to an engineering design 

option applicable to that class 

(described in section IV.C). These LCC 

and NPV results represent the entire 

range of the economic benefits to the 

consumer at various combinations of 

efficiency levels of the refrigeration 

systems and the envelope components. 

The pairing of refrigeration system 

efficiency levels with the efficiency 

levels of envelope component classes is 

discussed in detail in chapter 10 of the 

TSD. 

DOE selected envelope component 

levels for further analysis based on the 

following criteria: maximum NPV, 

maximum NES with positive NPV, and 

Max Tech. DOE also considered a fourth 

criterion: maximum NES with positive 

NPV for display doors only, and no new 

standard for panels and non-display 

doors. DOE considered this level 

because it observed that, due to the 

nature of the panel and non-display 

door industry, any standard could have 

a large effect on small panel and door 

manufacturers. This effect is described 

in detail in chapter 12 of the TSD, 

Manufacturer Impact Analysis. 

Finally, DOE chose six composite 

TSLs by selecting from the 

combinations of the seven potential 

levels for the refrigeration systems and 

the four potential levels for the envelope 

components. The composite TSLs and 

criteria for each one are shown in Table 

V–2. 

TABLE V–2—CRITERIA DESCRIPTION FOR THE COMPOSITE TSLS

Component criteria 

Refrigeration system criteria 

All compressors Max NPV Max NES with NPV>0 * Max tech 

Display Doors Only ............ ........................................... 2: All display doors only at 

NPV>0.

Maximum NPV ................... 1: All compressors, max 

NPV.

4: Maximum NPV for both 

refrigeration system and 

components.


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TABLE V–2—CRITERIA DESCRIPTION FOR THE COMPOSITE TSLS—Continued 

Component criteria 

Refrigeration system criteria 

All compressors Max NPV Max NES with NPV>0 * Max tech 

Maximum NES with NPV>0 3: All compressors, NPV>0 ........................................... 5: Max NES with NPV>0 

for both Refrigeration 

system and Components.

Max–Tech .......................... ........................................... ........................................... ........................................... 6: Max-tech for both Refrigeration system and 

Components. 

* Not counted as a separate efficiency level for the refrigeration system, as it corresponds to the Max Tech level in the current analysis. 

In Table V–2, the column headings 

identify the criteria for the TSL option 

for the refrigeration system and the row 

headings identify the criteria for the 

TSL option for the envelope 

components. The intersection of the row 

and the column define the respective 

choices for the composite TSL. The 

composite TSLs are numbered from 1 to 

6 in order of least to most energy 

savings. 

DOE describes each TSL, from highest 

to lowest energy savings, as follows. 

TSL 6 is the max-tech level for each 

equipment class for all components. 

TSL 5 represents the maximum 

efficiency level of the refrigeration 

system equipment classes with a 

positive NPV at a 7-percent discount 

rate, combined with the maximum 

efficiency level with a positive NPV at 

a 7-percent discount rate for each 

envelope component (panel, nondisplay door, or display door). TSL 4 

corresponds to the efficiency level with 

the maximum NPV for refrigeration 

system classes and the efficiency level 

with the maximum NPV for envelope 

component classes. TSL 3 is the highest 

efficiency level for refrigeration systems 

at which all compressor technologies 

can compete, combined with the 

maximum efficiency level with a 

positive NPV at a 7-percent discount 

rate for each envelope component. TSL 

2 is the efficiency level with the 

maximum NPV at a 7-percent discount 

rate for refrigeration systems, combined 

with the efficiency level with a 

maximum NPV at a 7-percent discount 

rate for display doors only, and does not 

include a new energy standard for 

panels and non-display doors. DOE is 

considering TSL 2 because a standard 

for panels and non-display doors may 

be unduly burdensome to a large 

number of small business manufacturers 

(see sections V.B.2.d and VI.B for 

further discussion of the impact of the 

rule on small manufacturers). TSL 1 is 

the highest efficiency level for 

refrigeration systems at which all 

compressor technologies can compete, 

combined with the efficiency level with 

the maximum NPV at a 7-percent 

discount rate for each envelope 

component when the components are 

combined with the selected refrigeration 

efficiency level. For more details on the 

criteria for the proposed TSLs, see 

chapter 10 of the TSD. 

2. Trial Standard Level Equations 

For panels and doors, DOE expresses 

the TSLs in terms of a normalization 

metric. For panels, the normalization 

metric is the ratio of the edge area to the 

core area. The TSLs are expressed in 

terms of polynomial equations that 

establish maximum U-factor limits in 

the form of: 

The form of the equation allows the 

efficiency requirements to be 

determined for panels of any dimension 

within an equipment class. Coefficients 

A, B, and C were uniquely derived for 

each equipment class by plotting the Ufactor of each representative size in an 

equipment class versus the edge area to 

core area ratio of the representative size 

and modeling the relationship as a 

polynomial equation. The core and edge 

areas for both floor and structural panels 

are defined in the walk-in cooler and 

freezer test procedure final rule. 76 FR 

at 33632 (June 9, 2011). 

For display and non-display doors, 

respectively, the normalization metric is 

the surface area of the door. The TSLs 

are expressed in terms of linear 

equations that establish maximum daily 

energy consumption (MEC) limits in the 

form of: 

MEC = D × (Surface Area) + E 

Coefficients D and E were uniquely 

derived for each equipment class by 

plotting the energy consumption at a 

given performance level versus the 

surface area of the door and determining 

the slope of the relationship, D, and the 

offset, E, where the offset represents the 

theoretical energy consumption of a 

door with no surface area (the offset is 

necessary because not all energyconsuming components of the door 

scale directly with surface area). The 

surface area is defined in the walk-in 

cooler and freezer test procedure final 

rule. 76 FR at 33632. 

For refrigeration systems, the 

proposed TSLs are expressed as a 

minimum efficiency level (AWEF) that 

the system must meet. For dedicated 

condensing systems, DOE calculated the 

AWEF differently for small and large 

classes based DOE’s expectation that 

small sized equipment may have 

difficulty meeting the same efficiency 

standard as large equipment (see section 

IV.A.3.b for details). Specifically, DOE 

observed that higher-capacity 

equipment tended to be more efficient 

because of the availability of scroll 

compressors above a certain capacity. 

DOE expressed the AWEF for large 

capacity dedicated condensing systems 

as a single value corresponding to the 

AWEF of the lowest capacity system 

analyzed in the large capacity class. 

DOE expressed the AWEF for the small 

capacity dedicated condensing systems 

as a linear equation normalized to the 

system gross capacity, where the 

equation was based on the AWEFs for 

the smallest two capacities analyzed but 

adjusted such that the equation would 

be continuous with the standard level 


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for the large capacity class at the 

boundary capacity point between the 

classes (i.e., 9,000 Btu/h). DOE 

calculated a single minimum efficiency 

for each class of multiplex condensing 

systems because DOE found that 

equipment capacity did not have a 

significant effect on the efficiency of the 

equipment. See appendix 10D of the 

TSD for further details on how the 

AWEF values were calculated. DOE 

requests comment on the AWEF 

equations and the methodology for 

determining them. In particular, DOE 

asks interested parties to submit data on 

how the efficiency of typical 

refrigeration systems varies by capacity. 

Based on comments and additional data 

DOE receives on the NOPR, DOE may 

consider other methods of calculating 

the minimum AWEF associated with the 

TSLs for each equipment class. 

The following tables present the 

equations and AWEFs for all TSLs 

under consideration. Table V–3, Table 

V–4, Table V–5, Table V–6, Table V–7, 

and Table V–8 show the standards 

equations for structural cooler panels, 

structural freezer panels, freezer floor 

panels, display doors, non-display 

passage doors, and non-display freight 

doors, respectively. Table V–9 shows 

the AWEFs for refrigeration systems and 

indicates that the equations and AWEFs 

for a particular class of equipment may 

be the same across more than one TSL. 

This occurs when the criteria for two 

different TSLs are satisfied by the same 

efficiency level for a particular 

component. For example, for all 

refrigeration classes the max-tech level 

has a positive NPV; thus, the efficiency 

level with the maximum energy savings 

with positive NPV (TSL 5) is the same 

as the efficiency level corresponding to 

max-tech (TSL 6). 


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TABLE V–6—EQUATIONS FOR ALL DISPLAY DOOR TSLS

TSL 

Equations for maximum energy consumption 

(kWh/day) 

DD.M DD.L 

Baseline .................................................................................................................................. 0.14 × Add + 0.82 0.36 × Add + 0.88 

TSL 1 ...................................................................................................................................... 0.049 × Add + 0.39 0.33 × Add + 0.38 

TSL 2 ...................................................................................................................................... 0.049 × Add + 0.39 0.33 × Add + 0.38 

TSL 3 ...................................................................................................................................... 0.049 × Add + 0.39 0.06 × Add + 3.8 

TSL 4 ...................................................................................................................................... 0.049 × Add + 0.39 0.33 × Add + 3.8 

TSL 5 ...................................................................................................................................... 0.049 × Add + 0.39 0.33 × Add + 0.38 

TSL 6 ...................................................................................................................................... 0.0080 × Add + 0.29 0.11 × Add + 0.32 

TABLE V–7—EQUATIONS FOR ALL PASSAGE DOOR TSLS

TSL 

Equations for maximum energy consumption 

(kWh/day) 

PD.M PD.L 

Baseline .................................................................................................................................. 0.0040 × And + 0.24 0.141 × And + 4.81 

TSL 1 ...................................................................................................................................... 0.0032 × And + 0.22 0.138 × And + 4.04 

TSL 2 ...................................................................................................................................... 0.0040 × And + 0.24 0.141 × And + 4.81 

TSL 3 ...................................................................................................................................... 0.0032 × And + 0.22 0.135 × And + 3.91 

TSL 4 ...................................................................................................................................... 0.0032 × And + 0.22 0.138 × And + 4.04 

TSL 5 ...................................................................................................................................... 0.0032 × And + 0.22 0.135 × And + 3.91 

TSL 6 ...................................................................................................................................... 0.00093 × And + 0.0083 0.131 × And + 3.88 

TABLE V–8—EQUATIONS FOR ALL FREIGHT DOOR TSLS

TSL 

Equations for maximum energy consumption 

(kWh/day) 

FD.M FD.L 

Baseline .................................................................................................................................. 0.0078 × And + 0.11 0.12 × And + 5.6 

TSL 1 ...................................................................................................................................... 0.0073 × And + 0.082 0.11 × And + 5.3 

TSL 2 ...................................................................................................................................... 0.0078 × And + 0.11 0.12 × And + 5.6 

TSL 3 ...................................................................................................................................... 0.0073 × And + 0.082 0.10 × And + 5.2 

TSL 4 ...................................................................................................................................... 0.0073 × And + 0.082 0.11 × And + 5.4 

TSL 5 ...................................................................................................................................... 0.0073 × And + 0.082 0.10 × And + 5.2 

TSL 6 ...................................................................................................................................... 0.00092 × And + 0.13 0.094 × And + 5.2 

TABLE V–9—AWEFS FOR ALL REFRIGERATION SYSTEM TSLS

Equipment class 

Equations for minimum AWEF (Btu/W-h) 

Baseline TSLs 1 and 3 TSLs 2 and 4 TSLs 5 and 6 

DC.M.I, < 9,000 ............................. 2.47 × 10¥4 × Q + 2.30 4.37 × 10¥4 × Q + 2.26 2.63 × 10¥4 × Q + 4.53 2.63 × 10¥4 × Q + 4.53 

DC.M.I, ≥ 9,000 .............................. 4.52 6.19 6.90 6.90 

DC.M.O, < 9,000 ............................ 2.50 × 10¥4 × Q + 2.66 6.10 × 10¥4 × Q + 3.57 1.34 × 10¥3 × Q + 0.12 9.23 × 10¥4 × Q + 3.90 

DC.M.O, ≥ 9,000 ............................ 4.91 9.06 12.21 12.21 

DC.L.I, < 9,000 .............................. 1.43 × 10¥4 × Q + 1.48 1.10 × 10¥4 × Q + 2.16 1.93 × 10¥4 × Q + 1.89 1.93 × 10¥4 × Q + 1.93 

DC.L.I, ≥ 9,000 ............................... 2.77 3.15 3.63 3.67 

DC.L.O, < 9,000 ............................. 1.70 × 10¥4 × Q + 1.38 2.43 × 10¥4 × Q + 2.16 5.70 × 10¥4 × Q + 1.02 4.53 × 10¥4 × Q + 2.17 

DC.L.O, ≥ 9,000 ............................. 2.91 4.35 6.15 6.25 

MC.M .............................................. 6.80 10.82 10.74 10.82 

MC.L ............................................... 4.66 5.91 5.53 5.91 

B. Economic Justification and Energy 

Savings 

1. Economic Impacts on Commercial 

Customers 

a. Life-Cycle Cost and Payback Period 

Consumers affected by new or 

amended standards usually incur higher 

purchase prices and experience lower 

operating costs. DOE evaluates these 

impacts on individual consumers by 

calculating changes in LCC and the PBP 

associated with the TSLs. Using the 

approach described in section IV.F, DOE 

calculated the LCC impacts and PBPs 

for the efficiency levels considered in 

this NOPR. Inputs used for calculating 

the LCC include total installed costs 

(i.e., equipment price plus installation 

costs), annual energy savings, and 

average electricity costs by consumer, 

energy price trends, repair costs, 

maintenance costs, equipment lifetime, 

and consumer discount rates. DOE 

based the LCC and PBP analyses on 

energy consumption under conditions 

of actual product use. DOE created 


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distributions of values for some inputs, 

with probabilities attached to each 

value, to account for their uncertainty 

and variability. DOE used probability 

distributions to characterize equipment 

lifetime, discount rates, sales taxes and 

several other inputs to the LCC model. 

The computer model DOE uses to 

calculate the LCC and PBP, which 

incorporates Crystal Ball (a 

commercially available software 

program), relies on a Monte Carlo 

simulation to incorporate uncertainty 

and variability into the analysis. The 

Monte Carlo simulations randomly 

sample input values from the 

probability distributions of the input 

variables and calculate the LCC and PBP 

from these. Details of the spreadsheet 

model, and of all the inputs to the LCC 

and PBP analyses, are contained in TSD 

chapter 8 and its appendices. 

DOE’s LCC and PBP analysis results 

for each refrigeration system are 

reported in Table V–10 through Table 

IV–14 at each TSL for the representative 

sizes of walk-in refrigeration systems in 

each equipment class. Each table 

includes the installed cost, total LCC, 

average LCC savings, the median 

payback period, and also the percentage 

of customers who will experience a 

benefit, cost, or no change under a 

proposed standard by performing a 

Monte Carlo analysis. DOE noted that 

for all classes of refrigeration systems, 

consumer LCCs were positive up 

through TSL 6, which corresponds to 

the maximum technologically feasible 

level (max-tech) refrigeration level. The 

median PBP values vary between 2–6 

years for the dedicated condensing unit 

(DC) classes and were less than 1 year 

for the multiplex classes for all TSLs for 

medium temperature systems and for 

TSL2 and TSL 4 for low temperature 

systems. The median PBP exceeded 2 

year only for the other TSLs considered. 

DOE also noted that higher benefits are 

experienced by users of larger capacity 

systems than by the smaller capacity 

systems. The LCC savings and PBP for 

all the sizes analyzed by DOE are shown 

in TSD chapter 8. 

DOE’s LCC and PBP analysis results 

for all envelope component equipment 

classes at each TSL are reported in 

Table V–15 through Table V–17. DOE 

analyzed three sizes (small, medium 

and large) in each component 

equipment class. Results for the 

components of different sizes in the 

equipment class are averaged on the 

basis of their shipment weights and 

reported in these tables. LCC and PBP 

results for all sizes may be found in 

chapter 8 of the TSD. Table V–10 

through Table V–17 show that for all the 

components, LCC savings are 

significantly negative and payback 

periods are very high at the max-tech 

level (TSL 6). 

TABLE V–10—SUMMARY LCC AND PBP RESULTS FOR MEDIUM TEMPERATURE DEDICATED CONDENSING REFRIGERATION

SYSTEMS—OUTDOOR CONDENSER

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of Consumers that experience 

Net cost No impact Net benefit Median 

Baseline ........................... 4,368 7,363 11,731 .................... .................... .................... .................... ....................

TSL1 ................................. 4,891 5,791 10,682 1,048 0 0 100 1.3 

TSL2 ................................. 5,387 4,766 10,153 1,577 0 0 100 2.5 

TSL3 ................................. 4,992 5,622 10,614 1,117 0 0 100 1.8 

TSL4 ................................. 5,286 4,936 10,222 1,509 0 0 100 2.0 

TSL5 ................................. 5,532 4,591 10,123 1,608 1 0 99 3.0 

TSL6 ................................. 5,532 4,591 10,123 1,608 1 0 99 3.0 

TABLE V–11—SUMMARY LCC AND PBP RESULTS FOR MEDIUM-TEMPERATURE DEDICATED CONDENSING REFRIGERATION

SYSTEMS—INDOOR CONDENSER

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of Consumers that experience 

Net cost No impact Net benefit Median 

Baseline ........................... 4,033 7,746 11,779 .................... .................... .................... .................... ....................

TSL1 ................................. 4,501 6,998 11,499 280 1 0 99 3.2 

TSL2 ................................. 4,931 6,238 11,169 611 4 0 96 4.4 

TSL3 ................................. 4,501 6,998 11,499 280 1 0 99 3.2 

TSL4 ................................. 4,931 6,238 11,169 611 4 0 96 4.4 

TSL5 ................................. 4,931 6,238 11,169 611 4 0 96 4.4 

TSL6 ................................. 4,931 6,238 11,169 611 4 0 96 4.4 

TABLE V–12—SUMMARY OF LCC AND PBP RESULTS FOR LOW-TEMPERATURE DEDICATED-CONDENSING REFRIGERATION

SYSTEMS—OUTDOOR CONDENSER

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of Consumers that experience 

Net cost No impact Net benefit Median 

Baseline ........................... 4,093 10,471 14,564 .................... .................... .................... .................... ....................

TSL1 ................................. 4,673 8,564 13,236 1,328 5 0 95 1.2 

TSL2 ................................. 5,377 6,791 12,168 2,001 5 0 95 2.3 

TSL3 ................................. 4,673 8,564 13,236 1,328 5 0 95 1.2 


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TABLE V–12—SUMMARY OF LCC AND PBP RESULTS FOR LOW-TEMPERATURE DEDICATED-CONDENSING REFRIGERATION

SYSTEMS—OUTDOOR CONDENSER—Continued 

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of Consumers that experience 

Net cost No impact Net benefit Median 

TSL4 ................................. 5,377 6,791 12,168 2,001 5 0 95 2.3 

TSL5 ................................. 5,591 6,584 12,175 1,994 5 0 95 2.8 

TSL6 ................................. 5,591 6,584 12,175 1,994 5 0 95 2.8 

TABLE V–13—SUMMARY OF LCC AND PBP RESULTS FOR LOW-TEMPERATURE DEDICATED-CONDENSING REFRIGERATION

SYSTEMS—INDOOR CONDENSER

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of Consumers that experience 

Net cost No impact Net benefit Median 

Baseline ........................... 4,161 13,051 17,212 .................... .................... .................... .................... ....................

TSL1 ................................. 4,688 12,019 16,707 505 0 0 100 2.8 

TSL2 ................................. 5,187 11,018 16,205 1,117 0 0 100 2.7 

TSL3 ................................. 4,688 12,019 16,707 505 0 0 100 2.8 

TSL4 ................................. 5,187 11,018 16,205 1,117 0 0 100 2.7 

TSL5 ................................. 5,272 10,970 16,242 1,080 0 0 100 3.1 

TSL6 ................................. 5,272 10,970 16,242 1,080 0 0 100 3.1 

TABLE V–14—SUMMARY LCC AND PBP RESULTS FOR MEDIUM- AND LOW-TEMPERATURE MULTIPLEX REFRIGERATION

SYSTEMS

[Unit coolers only] 

Trial standard level Efficiency 

level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of Consumers that experience 

Net cost No impact Net benefit Median 

Medium Temperature Multiplex 

.............. Baseline 1,583 6,143 7,726 .................... .................... .................... .................... ....................

TSL1 ......... EL2 2,251 3,759 6,010 1,715 0 0 100 0.6 

TSL2 ......... EL2 2,231 3,771 6,002 1,724 0 0 100 0.5 

TSL3 ......... EL2 2,251 3,759 6,010 1,715 0 0 100 0.6 

TSL4 ......... EL2 2,231 3,771 6,002 1,724 0 0 100 0.5 

TSL5 ......... EL3 2,251 3,759 6,010 1,715 0 0 100 0.6 

TSL6 ......... EL3 2,251 3,759 6,010 1,715 0 0 100 0.6 

Low Temperature Multiplex 

.............. Baseline 1,583 10,295 11,878 .................... .................... .................... .................... ....................

TSL1 ......... EL2 2,776 7,252 10,028 1,849 0 0 100 2.5 

TSL2 ......... EL2 2,231 7,585 9,817 2,061 0 0 100 0.4 

TSL3 ......... EL2 2,776 7,252 10,028 1,849 0 0 100 2.5 

TSL4 ......... EL2 2,231 7,585 9,817 2,061 0 0 100 0.4 

TSL5 ......... EL5 2,776 7,252 10,028 1,849 0 0 100 2.5 

TSL6 ......... EL5 2,776 7,252 10,028 1,849 0 0 100 2.5 

TABLE V–15—SUMMARY LCC AND PBP RESULTS FOR STRUCTURAL AND FLOOR PANELS

[Weighted across all sizes] 

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of Consumers that experience 

Net cost No impact Net benefit Median 

Medium Temperature Structural Panel 

Baseline ........................... 1,007 97 1,104 .................... .................... .................... .................... ....................

TSL1 ................................. 1,007 97 1,104 16 14 0 86 3.8 

TSL2 ................................. 977 119 1,095 0 0 100 0 0.0 


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TABLE V–15—SUMMARY LCC AND PBP RESULTS FOR STRUCTURAL AND FLOOR PANELS—Continued 

[Weighted across all sizes] 

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of Consumers that experience 

Net cost No impact Net benefit Median 

TSL3 ................................. 1,043 85 1,128 ¥9 75 0 25 6.8 

TSL4 ................................. 1,007 80 1,088 8 34 0 66 4.5 

TSL5 ................................. 1,043 65 1,109 ¥22 93 0 7 9.0 

TSL6 ................................. 3,206 19 3,225 ¥2,139 100 0 0 146.4 

Low Temperature Structural Panel 

Baseline ........................... 1,122 278 1,400 .................... .................... .................... .................... ....................

TSL1 ................................. 1,122 278 1,400 122 2 0 98 2.9 

TSL2 ................................. 1,010 399 1,410 0 0 100 0 0.0 

TSL3 ................................. 1,373 215 1,588 ¥66 79 0 21 7.4 

TSL4 ................................. 1,122 216 1,338 72 7 0 93 3.6 

TSL5 ................................. 1,373 161 1,533 ¥140 94 0 6 10.0 

TSL6 ................................. 3,208 76 3,284 ¥1,890 100 0 0 43.0 

Low Temperature Floor Panel 

Baseline ........................... 1,202 243 1,445 .................... .................... .................... .................... ....................

TSL1 ................................. 1,202 243 1,445 66 6 0 94 3.5 

TSL2 ................................. 1,103 318 1,421 0 0 100 0 0.0 

TSL3 ................................. 1,348 166 1,515 ¥4 62 0 38 6.0 

TSL4 ................................. 1,202 189 1,390 30 28 0 72 4.5 

TSL5 ................................. 1,348 124 1,473 ¥65 88 0 12 8.0 

TSL6 ................................. 2,982 79 3,061 ¥1,653 100 0 0 48.7 

TABLE V–16—SUMMARY LCC AND PBP RESULTS FOR DISPLAY DOORS

[Weighted across all sizes] 

Trial standard level 

Life-cycle cost (2012$) Life-Cycle Cost Savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of consumers that experience 

Net cost No impact Net benefit Median 

Medium Temperature Display Door 

Baseline ........................... 1,100 530 1,630 .................... .................... .................... .................... ....................

TSL1 ................................. 1,205 186 1,391 239 0 0 100 2.1 

TSL2 ................................. 1,205 180 1,385 228 0 0 100 2.2 

TSL3 ................................. 1,205 186 1,391 239 0 0 100 2.1 

TSL4 ................................. 1,205 180 1,385 228 0 0 100 2.2 

TSL5 ................................. 1,205 177 1,382 222 0 0 100 2.2 

TSL6 ................................. 4,182 73 4,255 ¥2,650 100 0 0 37.6 

Low Temperature Display Door 

Baseline ........................... 1,594 1,412 3,006 .................... .................... .................... .................... ....................

TSL1 ................................. 1,756 1,033 2,789 217 0 0 100 N/A 

TSL2 ................................. 1,756 954 2,710 200 0 0 100 N/A 

TSL3 ................................. 2,046 972 3,019 ¥12 64 0 36 6.0 

TSL4 ................................. 1,756 954 2,710 200 0 0 100 N/A 

TSL5 ................................. 1,756 942 2,698 198 0 0 100 N/A 

TSL6 ................................. 4,242 371 4,613 ¥1,717 100 0 0 18.5 

TABLE V–17—SUMMARY LCC AND PBP RESULTS FOR NON-DISPLAY DOORS

[Weighted across all sizes] 

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of consumers that experience 

Net cost No impact Net benefit Median 

Medium Temperature Passage Door 

Baseline ........................... 691 89 780 .................... .................... .................... .................... ....................


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32Small Business Administration. ‘‘Table of 

Small business Size Standards.’’ SBA.gov. http://

www.sba.gov/content/guide-size-standards. 

Accessed July 2011. 

33U.S. CENSUS. 2007. U.S. Census Bureau 

American Fact Finder, 2002 Economic CensusSector 44: Retail Trade: Subject Series–Estab & Firm 

Size: Single Unit and Multiunit Firms for the 

United States: 2007, Washington, DC, Accessed July 

2011. http://www.census.gov/econ/census07/www/

data_release_schedule/whats_been_

released.html#44. 

TABLE V–17—SUMMARY LCC AND PBP RESULTS FOR NON-DISPLAY DOORS—Continued 

[Weighted across all sizes] 

Trial standard level 

Life-cycle cost (2012$) Life-cycle cost savings (2012$) Payback 

period 

(years) Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

% of consumers that experience 

Net cost No impact Net benefit Median 

TSL1 ................................. 691 89 780 2 27 0 73 4.5 

TSL2 ................................. 683 91 774 0 0 100 0 0.0 

TSL3 ................................. 691 89 780 2 27 0 73 4.5 

TSL4 ................................. 691 83 774 0 52 0 48 5.5 

TSL5 ................................. 691 80 772 0 64 0 36 6.0 

TSL6 ................................. 1,637 19 1,655 ¥884 100 0 0 78.7 

Low Temperature Passage Door 

Baseline ........................... 1,070 2,205 3,274 .................... .................... .................... .................... ....................

TSL1 ................................. 1,070 2,205 3,274 74 14 0 86 4.3 

TSL2 ................................. 880 2,261 3,142 0 0 100 0 0.0 

TSL3 ................................. 1,226 2,138 3,364 ¥16 66 0 34 6.2 

TSL4 ................................. 1,070 2,020 3,090 52 27 0 73 4.7 

TSL5 ................................. 1,226 1,937 3,163 ¥52 75 0 25 7.0 

TSL6 ................................. 1,863 1,913 3,776 ¥665 100 0 0 18.3 

Medium Temperature Freight Door 

Baseline ........................... 1,277 147 1,424 .................... .................... .................... .................... ....................

TSL1 ................................. 1,277 143 1,420 3 25 0 75 4.5 

TSL2 ................................. 1,265 144 1,409 0 0 100 0 0.0 

TSL3 ................................. 1,277 143 1,420 3 25 0 75 4.5 

TSL4 ................................. 1,277 131 1,408 1 50 0 50 5.4 

TSL5 ................................. 1,277 126 1,403 0 62 0 38 5.9 

TSL6 ................................. 2,511 49 2,560 ¥1,157 100 0 0 81.5 

Low Temperature Freight Door 

Baseline ........................... 1,670 3,424 5,094 .................... .................... .................... .................... ....................

TSL1 ................................. 1,670 3,424 5,094 152 6 0 94 3.8 

TSL2 ................................. 1,426 3,491 4,917 0 0 100 0 0.0 

TSL3 ................................. 1,914 3,305 5,219 28 56 0 44 5.8 

TSL4 ................................. 1,543 3,237 4,780 136 1 0 99 2.9 

TSL5 ................................. 1,914 2,987 4,901 ¥32 69 0 31 6.5 

TSL6 ................................. 3,273 2,932 6,205 ¥1,337 100 0 0 21.7 

b. Life-Cycle Cost Subgroup Analysis 

Using the LCC spreadsheet model, 

DOE estimated the impact of increased 

WICF efficiency standards at each TSL 

on the following consumer subgroup: 

small restaurants that purchase their 

own walk-in units. These restaurants are 

typically identified by the Small 

Business Administration as restaurants 

with annual receipts of $10 million or 

less.32 The small restaurant subgroup 

was analyzed because in the ‘‘food 

service and drinking places’’ business 

class in the 2007 Census,33 almost 60 

percent of employment and sales can be 

attributed to small restaurants and more 

than 78 percent of these establishments 

are considered small businesses. 

Furthermore, DOE received comments 

suggesting small restaurant owners 

could be particularly vulnerable to 

potential negative consequences of 

higher efficiency standards and 

potentially face shorter equipment 

lifetimes. DOE’s LCC analysis shows 

that restaurants had among the highest 

financing costs (based on weighted 

average cost of capital of entities using 

walk-in coolers and freezers). Therefore, 

this group was expected to have the 

least LCC savings and longest PBP of 

any identifiable consumer group. 

DOE estimated the LCC and PBP for 

the small restaurants subgroup. Table 

V–18 and Table V–19 show the LCC 

savings for refrigeration systems and 

envelope component equipment, 

respectively, which meet the proposed 

energy conservation standards for the 

small restaurant subgroup. Table V–20 

and Table V–21 show the corresponding 

PBPs (in years) for this subgroup. 

For example, DOE’s analysis shows 

that at TSL 4, structural cooler panels 

for small restaurants have lower LCC 

savings and longer payback periods than 

other business types; however, LCC 

savings values are still positive for this 

subgroup at this TSL for panels. In 

addition, payback periods are typically 

increased by less than 10 percent 

compared with the walk-in market as a 

whole. For a more detailed discussion 

on the LCC subgroup analysis and its 

results, see chapter 11 of the TSD. 


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TABLE V–18—LIFE-CYCLE COST SAVINGS FOR WICF REFRIGERATION SYSTEMS

[2012$] 

Equipment class Business TSL1 TSL2 TSL3 TSL4 TSL5 TSL6 

DC.M.I.006 ........ Small Business ................................. $67.25 $352.58 $67.25 $352.58 $352.58 $352.58 

All Business Types ........................... 70.30 370.28 70.30 370.28 370.28 370.28 

DC.M.I.018 ........ Small Business ................................. 1,294.98 1,762.74 1,294.98 1,762.74 1,762.74 1,762.74 

All Business Types ........................... 1,350.45 1,837.93 1,350.45 1,837.93 1,837.93 1,837.93 

DC.M.O.006 ...... Small Business ................................. 567.37 718.28 567.37 718.28 784.16 784.16 

All Business Types ........................... 589.85 748.02 748.02 589.85 818.57 818.57 

DC.M.O.018 ...... Small Business ................................. 1,749.53 2,761.13 1,749.53 2,761.13 2,761.13 2,761.13 

All Business Types ........................... 1,817.33 2,874.34 1,817.33 2,874.34 2,874.34 2,874.34 

DC.M.O.054 ...... Small Business ................................. 12,021.21 12,566.27 12,021.21 12,566.27 12,566.27 12,566.27 

All Business Types ........................... 12,493.74 13,068.28 12,493.74 13,068.28 13,068.28 13,068.28 

DC.L.I.006 ......... Small Business ................................. 754.45 1,073.48 754.45 1,073.48 1,035.60 1,035.60 

All Business Types ........................... 788.39 1,120.12 788.39 1,120.12 1,081.45 1,081.45 

DC.L.I.009 ......... Small Business ................................. 136.23 1,031.11 136.23 1,031.11 1,031.11 1,031.11 

All Business Types ........................... 142.04 1,112.07 142.04 1,112.07 1,077.14 1,077.14 

DC.L.O.006 ....... Small Business ................................. 1,764.83 1,747.88 1,764.83 1,747.88 1,773.85 1,773.85 

All Business Types ........................... 1,833.48 1,814.48 1,833.48 1,814.48 1,843.63 1,843.63 

DC.L.O.009 ....... Small Business ................................. 1,022.91 2,218.75 1,022.91 2,218.75 2,184.74 2,184.74 

All Business Types ........................... 1,059.59 2,307.72 1,059.59 2,307.72 2,273.00 2,273.00 

DC.L.O.054 ....... Small Business ................................. 13,619.19 14,061.17 13,619.19 14,061.17 13,231.20 13,231.20 

All Business Types ........................... 14,125.72 14,590.39 14,125.72 14,590.39 13,760.51 13,760.51 

* Multiplex refrigeration systems are not typically used in small restaurants. 

TABLE V–19—LIFE-CYCLE COST SAVINGS FOR WICF ENVELOPE COMPONENTS (PANELS AND DOORS) 

[2012$] 

Equipment class Business TSL1 TSL2 TSL3 TSL4 TSL5 TSL6 

SP.M ................. Small Business ................................. $12.65 .................... ($8.05) $6.20 ($16.17) ($2,141.42) 

All Business Types ........................... 15.55 .................... (8.98) 7.63 (22.44) (2,138.75) 

SP.L .................. Small Business ................................. 109.66 .................... (75.54) 67.73 (92.45) (1,901.81) 

All Business Types ........................... 121.93 .................... (65.50) 71.61 (139.77) (1,890.34) 

FP.L .................. Small Business ................................. 58.43 .................... (12.64) 26.98 (52.29) (1,661.22)

All Business Types ........................... 65.59 .................... (4.45) 30.28 (64.89) (1,652.86) 

DD.M ................. Small Business ................................. 225.18 214.71 225.17 214.71 209.52 (2,660.23) 

All Business Types ........................... 238.77 227.69 238.77 227.69 222.46 (2,650.38) 

DD.L .................. Small Business ................................. 210.44 193.37 (11.78) 193.37 191.01 (1,739.58) 

All Business Types ........................... 217.30 200.08 (12.17) 200.08 197.59 (1,716.84) 

PD.M ................. Small Business ................................. 1.80 .................... 1.80 0.11 (0.88) (886.46) 

All Business Types ........................... 2.13 .................... 2.13 0.32 (0.30) (883.91) 

PD.L .................. Small Business ................................. 64.25 .................... (37.17) 42.91 (65.11) (677.42) 

All Business Types ........................... 73.75 .................... (15.74) 51.91 (51.65) (664.59) 

FD.M ................. Small Business ................................. 2.96 .................... 2.96 0.35 (6.14) (1,160.14) 

All Business Types ........................... 3.46 .................... 3.46 0.70 (0.24) (1,156.91) 

FD.L .................. Small Business ................................. 137.63 .................... 13.37 126.39 (58.05) (1,357.39)

All Business Types ........................... 152.18 .................... 27.62 136.42 (32.13) (1,337.03) 

Note: Dashes represent components at baseline efficiency and therefore do not have a payback period. Numbers in parentheses indicate negative values. 

TABLE V–20—PAYBACK PERIOD FOR WICF REFRIGERATION SYSTEMS

[Years] 

Equipment Business TSL1 TSL2 TSL3 TSL4 TSL5 TSL6 

DC.M.I.006 ........ Small Business ................................. 3.63 5.20 3.63 5.20 5.20 5.46 

All Business Types ........................... 3.40 4.88 3.40 4.88 4.88 4.88 

DC.M.I.018 ........ Small Business ................................. 2.31 2.28 2.31 2.28 2.28 2.28 

All Business Types ........................... 2.17 2.14 2.17 2.14 2.14 2.14 

DC.M.O.006 ...... Small Business ................................. 2.20 3.35 5.52 0.02 4.46 4.46 

All Business Types ........................... 2.11 3.21 3.21 2.11 4.30 4.30 

DC.M.O.018 ...... Small Business ................................. 1.02 2.64 1.02 2.64 2.64 2.64 

All Business Types ........................... 0.98 2.54 0.98 2.54 2.54 2.54 

DC.M.O.054 ...... Small Business ................................. 1.02 1.79 1.02 1.79 1.79 1.79 

All Business Types ........................... 0.98 1.74 0.98 1.74 1.74 1.74 

DC.L.I.006 ......... Small Business ................................. 3.52 2.74 3.52 2.74 3.16 3.16 

All Business Types ........................... 3.32 2.58 3.32 2.58 2.98 2.98 

DC.L.I.009 ......... Small Business ................................. 2.19 2.22 2.19 2.22 3.35 3.35 

All Business Types ........................... 2.07 2.78 2.07 2.78 3.16 3.16 

DC.L.O.006 ....... Small Business ................................. 2.10 1.77 2.10 1.77 2.88 2.88 


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TABLE V–20—PAYBACK PERIOD FOR WICF REFRIGERATION SYSTEMS—Continued 

[Years] 

Equipment Business TSL1 TSL2 TSL3 TSL4 TSL5 TSL6 

All Business Types ........................... 2.03 1.72 2.03 1.72 2.80 2.80 

DC.L.O.009 ....... Small Business ................................. 0.76 2.93 0.76 2.93 3.12 3.12 

All Business Types ........................... 0.74 2.84 0.74 2.84 3.02 3.02 

DC.L.O.054 ....... Small Business ................................. 0.50 0.63 0.50 0.63 3.23 3.23 

All Business Types ........................... 0.48 0.61 0.48 0.61 3.15 3.15 

* Multiplex refrigeration systems are not typically used in small restaurants. 

TABLE V–21—PAYBACK PERIOD FOR WICF ENVELOPE COMPONENTS (PANELS AND DOORS) 

[Years] 

Equipment Business TSL1 TSL2 TSL3 TSL4 TSL5 TSL6 

SP.M ................. Small Business ................................. 3.77 .................... 6.77 4.46 8.92 146.06 

All Business Types ........................... 3.81 .................... 6.80 4.49 8.95 146.40 

SP,L .................. Small Business ................................. 2.82 .................... 7.33 3.60 9.86 42.58 

All Business Types ........................... 2.85 .................... 7.43 3.63 9.95 42.97 

FP.L .................. Small Business ................................. 3.47 .................... 5.88 4.42 7.92 48.28 

All Business Types ........................... 3.50 .................... 5.96 4.46 7.99 48.69 

DD.M ................. Small Business ................................. 2.10 2.17 2.10 2.17 2.21 37.28 

All Business Types ........................... 2.13 2.19 2.13 2.19 2.22 37.56 

DD.L .................. Small Business ................................. N/A N/A 6.20 N/A N/A 18.91 

All Business Types ........................... N/A N/A 6.01 N/A N/A 18.48 

PD.M ................. Small Business ................................. 4.52 .................... 4.52 5.48 6.01 78.77 

All Business Types ........................... 4.54 .................... 4.54 5.51 6.03 78.73 

PD.L .................. Small Business ................................. 4.26 .................... 6.22 4.70 7.02 18.26 

All Business Types ........................... 4.27 .................... 6.23 4.69 7.02 18.31 

FD.M ................. Small Business ................................. 4.44 .................... 4.44 5.38 5.90 81.55 

All Business Types ........................... 4.46 .................... 4.46 5.41 5.92 81.51 

FD.L .................. Small Business ................................. 3.76 .................... 5.76 2.92 6.54 21.62 

All Business Types ........................... 3.76 .................... 5.77 2.92 6.54 21.70 

Note: Dashes represent components at baseline efficiency and therefore do not have a payback period. 

2. Economic Impacts on Manufacturers 

DOE performed a manufacturer 

impact analysis (MIA) to estimate the 

impact of new energy conservation 

standards on manufacturers of walk-in 

cooler and freezer refrigeration, panels, 

and doors. The section below describes 

the expected impacts on manufacturers 

at each considered TSL. Chapter 12 of 

the TSD explains the analysis in further 

detail. 

a. Industry Cash-Flow Analysis Results 

Table V–22 through Table V–24 

depict the financial impacts on 

manufacturers and the conversion costs 

DOE estimates manufacturers would 

incur at each TSL. The financial impacts 

on manufacturers are represented by 

changes in industry net present value 

(INPV). 

The impact of energy efficiency 

standards were analyzed under two 

markup scenarios: (1) The preservation 

of gross margin percentage and (2) the 

preservation of operating profit. As 

discussed in section IV.I.2.b, DOE 

considered the preservation of gross 

margin percentage scenario by applying 

a uniform ‘‘gross margin percentage’’ 

markup across all efficiency levels. As 

production cost increases with 

efficiency, this scenario implies that the 

absolute dollar markup will increase. 

DOE assumed the nonproduction cost 

markup—which includes SG&A 

expenses; research and development 

expenses; interest; and profit to be 1.32 

for panels, 1.50 for solid doors, 1.62 for 

display doors, and 1.35 for refrigeration. 

These markups are consistent with the 

ones DOE assumed in the engineering 

analysis and the base case of the GRIM. 

Manufacturers have indicated that it is 

optimistic to assume that as their 

production costs increase in response to 

an efficiency standard, they would be 

able to maintain the same gross margin 

percentage markup. Therefore, DOE 

assumes that this scenario represents a 

high bound to industry profitability 

under an energy-conservation standard. 

The preservation of earnings before 

interest and taxes (EBIT) scenario 

reflects manufacturer concerns about 

their inability to maintain their margins 

as manufacturing production costs 

increase to reach more-stringent 

efficiency levels. In this scenario, while 

manufacturers make the necessary 

investments required to convert their 

facilities to produce new standardscompliant equipment, operating profit 

does not change in absolute dollars and 

decreases as a percentage of revenue. 

Each of the modeled scenarios results 

in a unique set of cash flows and 

corresponding industry values at each 

TSL. In the following discussion, the 

INPV results refer to the difference in 

industry value between the base case 

and each standards case that result from 

the sum of discounted cash flows from 

the base year 2013 through 2046, the 

end of the analysis period. To provide 

perspective on the short-run cash flow 

impact, DOE includes in the discussion 

of the results a comparison of free cash 

flow between the base case and the 

standards case at each TSL in the year 

before new standards take effect. 

Table V–22 through Table V–24 show 

the MIA results for each TSL using the 

markup scenarios described above for 

WICF panel, door and refrigeration 

manufacturers, respectively: 


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34Free cash flow (FCF) is a metric commonly 

used in financial valuation. DOE calculates this 

value by adding back depreciation to net operating 

profit after tax and subtracting increases in working 

capital and capital expenditures. 

TABLE V–22—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF PANELS

Units Base 

case 

Trial standard level 

1 2 3 4 5 6 

INPV .................. 2012 $M 207.3 182.2 to 195.8 ..... 207.3 to 207.3 ..... 144.1 to 177.0 ..... 182.2 to 195.8 ..... 144.1 to 177.0 ...... ¥212.9 to 441.9. 

Change in INPV 2012 $M ............ ¥25.0 to ¥11.5 .. 0.0 to 0.0 ............. ¥63.1 to ¥30.2 .. ¥25.0 to ¥11.5 .. ¥63.1 to ¥30.2 ... ¥420.2 to 234.7. 

% ........... ............ ¥12.1 to ¥5.6 .... 0.0 to 0.0 ............. ¥30.5 to ¥14.6 .. ¥12.1 to ¥5.6 .... ¥30.5 to ¥14.6 ... ¥202.7 to 113.2. 

Free Cash Flow 

(FCF) (2016).

2012 $M 18.4 10.7 ..................... 18.4 ..................... ¥3.4 .................... 10.7 ..................... ¥3.4 ..................... ¥54.6. 

Change in FCF 

(2016).

2012 $M ............ ¥7.7 .................... 0.0 ....................... ¥21.8 .................. ¥7.7 .................... ¥21.8 ................... ¥73.0. 

% ........... ............ ¥41.6 .................. 0.0 ....................... ¥118.7 ................ ¥41.6 .................. ¥118.7 ................. ¥396.9. 

Conversion 

Costs.

2012 $M ............ 21 ........................ 0 .......................... 58 ........................ 21 ........................ 58 ......................... 195. 

TABLE V–23—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF DOORS

Units Base 

case 

Trial standard level 

1 2 3 4 5 6 

INPV .................. 2012 $M 454.6 437.6 to 470.7 ..... 446.2 to 470.2 ..... 428.2 to 467.8 ..... 437.8 to 470.6 ..... 427.3 to 466.4 ...... 260.8 to 1145.1. 

Change in INPV 2012 $M ............ ¥17.0 to 16.1 ..... ¥8.4 to 15.6 ....... ¥26.4 to 13.2 ..... ¥16.8 to 16.0 ..... ¥27.3 to 11.8 ...... ¥193.8 to 690.5. 

% ........... ............ ¥3.7 to 3.5 ......... ¥1.8 to 3.4 ......... ¥5.8 to 2.9 ......... ¥3.7 to 3.5 ......... ¥6.0 to 2.6 .......... ¥42.6 to 151.9. 

FCF (2016) ....... 2012 $M 36.1 34.1 ..................... 36.1 ..................... 30.4 ..................... 34.1 ..................... 30.5 ...................... 0.6. 

Change in FCF 

(2016).

2012 $M ............ ¥2.07 .................. 0.00 ..................... ¥5.7 .................... ¥2.1 .................... ¥5.7 ..................... ¥35.6. 

% ........... ............ ¥5.7 .................... 0.0 ....................... ¥15.8 .................. ¥5.7 .................... ¥15.7 ................... ¥98.5. 

Conversion 

Costs.

2012 $M ............ 6 .......................... 0.0 ....................... 15 ........................ 6 .......................... 15 ......................... 92. 

TABLE V–24—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF REFRIGERATION SYSTEMS

Units Base 

case 

Trial standard level 

1 2 3 4 5 6 

INPV .................. 2012 $M 189.1 170.9 to 183.3 ..... 153.6 to 184.8 ..... 170.9 to 183.3 ..... 153.6 to 184.8 ..... 145.8 to 188.3 ...... 145.8 to 188.3. 

Change in INPV 2012 $M ............ ¥18.3 to ¥5.9 .... ¥35.5 to ¥4.4 .... ¥18.3 to ¥5.9 .... ¥35.5 to ¥4.4 .... ¥43.3 to ¥0.8 ..... ¥43.3 to ¥0.8. 

% ........... ............ ¥9.7 to ¥3.1 ...... ¥18.8 to ¥2.3 .... ¥9.7 to ¥3.1 ...... ¥18.8 to ¥2.3 .... ¥22.9 to ¥0.4 ..... ¥22.9 to ¥0.4. 

FCF (2016) ....... 2012 $M 16.3 11.7 ..................... 9.1 ....................... 11.7 ..................... 9.1 ....................... 8.0 ........................ 8.0. 

Change in FCF 

(2016).

2012 $M ............ ¥4.6 .................... ¥7.2 .................... ¥4.6 .................... ¥7.2 .................... ¥8.3 ..................... ¥8.3. 

% ........... ............ ¥28.2 .................. ¥44.0 .................. ¥28.2 .................. ¥44.0 .................. ¥51.0 ................... ¥51.0. 

Conversion 

Costs.

2012 $M ............ 15 ........................ 24 ........................ 15 ........................ 24 ........................ 28 ......................... 28. 

Walk-In Cooler and Freezer Panel MIA 

Results 

At TSL 1, DOE models the impacts on 

panel INPV to be negative under both 

mark-up scenarios. The change in panel 

INPV ranges from ¥$25.0 million to 

¥$11.5 million, or a change in INPV of 

¥12.1 percent to ¥5.6 percent. At this 

level, panel industry free cash flow 34 is 

estimated to decrease by as much as 

$7.7 million, or 41.6 percent compared 

to the base-case value of $18.4 million 

in 2016, the year before the compliance 

date. The primary driver of the drop in 

INPV is the standard for lowtemperature side panels, which goes up 

to EL 2. At EL 2, manufacturers would 

likely use 5-inch thick side panels for 

low-temperature applications to meet 

the panel standard. At this level, DOE 

estimates conversion costs to be $21 

million for the industry. 

At TSL 2, the standard for all panel 

equipment classes are set to the baseline 

efficiency. As a result, there are no 

changes to INPV, no changes in industry 

free cash flow, and no conversion costs. 

At TSL 3, DOE estimates impacts on 

panel INPV to range from ¥$63.1 

million to ¥$30.2 million, or a change 

in INPV of ¥30.5 percent to ¥14.6 

percent. At this level, panel industry 

free cash flow is estimated to decrease 

by as much as $21.8 million, or 118.7% 

compared to the base-case value of 

$18.4 million in the year before the 

compliance date. The large percentage 

drop in cash flow in the GRIM indicates 

that conversion costs are high relative to 

the size of the industry and relative to 

annual operating profits. Conversion 

costs are expected to total $58 million. 

The conversion costs are driven by the 

need for 6-inch panels for both low 

temperature floor and side panels, as 

described in section 12.4.8 of the TSD. 

During manufacturer interviews, some 

panel manufacturers stated they would 

evaluate leaving the industry rather than 

make the required investments to meet 

the standard. 

At TSL 4, the standard for all panel 

equipment classes are identical to those 

at TSL 1. 

DOE estimates TSL 5 impacts on 

panel INPV to be range from ¥$63.1 

million to ¥$30.2 million, or a change 

in INPV of ¥30.5 percent to ¥14.6 

percent. At this level, panel industry 

free cash flow is estimated to decrease 

by as much as $21.8 million, or 118.7 

percent compared to the base-case value 

of $18.4 million in the year before the 

compliance date. At this TSL, 

conversion costs total $58 million for 

the industry. These conversion costs are 

based on DOE’s analysis indicating that 

industry would likely adopt 6-inch side 

floor panels to meet the standard. As in 

TSL 3, some panel manufacturers would 

likely leave the industry at this level of 

burden. 


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TSL 6 represents the use of max-tech 

design options for all equipment classes. 

DOE estimates impacts on panel INPV 

to be range from ¥$420.2 million to 

$234.7 million, or a change in INPV of 

¥202.7 percent to 113.2 percent. At this 

level, panel industry free cash flow is 

estimated to decrease by as much as 

$73.0 million, or 396.9 percent 

compared to the base-case value of 

$18.4 million in the year before the 

compliance date. Impacts at the most 

negative end of the range would likely 

force many manufacturers out of the 

industry. 

Walk-In Cooler and Freezer Door MIA 

Results 

For TSL 1, DOE models the change in 

INPV for doors to range from ¥$17.0 

million to $16.1 million, or a change in 

INPV of ¥3.7 percent to 3.5 percent. At 

this standard level, door industry free 

cash flow is estimated to decrease by as 

much as $2.1 million, or 5.7 percent 

compared to the base case value of $36.1 

million in the year before the 

compliance date. DOE expects solid 

door manufacturers to pursue design 

options that reduce the loss of heat 

through door frames and through 

embedded windows. Changes to door 

frame design may require new tooling. 

Total conversion costs for the door 

industry are expected to reach $6 

million. 

At TSL 2, DOE estimates the impacts 

on door INPV to range from ¥$8.4 

million to $15.6 million, or a change in 

INPV of ¥1.8 percent to 3.4 percent. At 

this level, door industry free cash flow 

is estimated to decrease by a negligible 

amount in the year before the 

compliance year. Furthermore, there are 

minimal conversion costs. To meet the 

standard, display door manufacturers 

would need to replace existing lighting 

with LEDs and reduce anti-sweat wire 

energy consumption. For solid door 

manufacturers, the standard is set at the 

baseline. Total conversion costs are 

expected to total $0.1 million for the 

industry. These costs are primarily 

product conversion costs associated 

incorporating heater wire controls and 

updating marketing literature. 

For TSL 3, DOE estimates the change 

in door INPV to range from ¥$26.4 

million to $13.2 million, or a change in 

INPV of ¥5.8 percent to 2.9 percent. At 

this level, door industry free cash flow 

is estimated to decrease by as much as 

$5.7 million, or 15.8 percent compared 

to the base-case value of $36.1 million 

in the year before the compliance date. 

At this level, display doors would need 

to incorporate lighting sensors. Solid 

doors for low temperature walk-ins 

would likely need to be redesigned to 6- 

inches of thickness. The additional 

production equipment and the cost of 

product redesigns drive conversion 

costs up to $15 million, more than 

double the conversion costs at TSL 1 

and TSL 2. This conversion cost number 

assumes that manufacturers that 

produce both panels and solid doors 

would use the same foaming equipment 

and presses to produce both products 

since DOE models panel manufacturers 

also going to 6-inch side panels for low 

temperature applications at TSL 3. 

Manufacturers that exclusively produce 

freight doors and passage doors will not 

be able to spread their investment over 

as many equipment classes. 

For TSL 4, DOE estimates impacts on 

door INPV to range from ¥$16.8 million 

to $16.0 million, or a change in INPV of 

¥3.7 percent to 3.5 percent. At this 

considered level, door industry free 

cash flow is estimated to decrease by as 

much as $2.1 million, or 5.7 percent 

compared to the base-case value of 

$36.1 million in the year before the 

compliance date. The standard levels for 

doors at TSL 4 are nearly identical to 

the standard levels at TSL 2, except that 

the standard is one efficiency level 

lower for the low temperature freight 

door equipment class. As mentioned 

above, DOE expects display door 

manufacturers to pursue design changes 

that do not require new manufacturing 

equipment. Manufacturers are expected 

to use LEDs in display doors and reduce 

anti-sweat wire energy consumption for 

medium temperature applications. DOE 

expects solid door manufacturers to 

pursue design options that reduce the 

loss of heat through door frames and 

through embedded windows. Changes 

to door frame design may require new 

tooling. Total conversion costs are 

expected to reach $6 million for the 

industry. 

For TSL 5, DOE estimates impacts on 

door INPV to range from ¥$27.3 million 

to $11.8 million, or a change in INPV of 

¥6.0 percent to 2.6 percent, at TSL 5. 

At this level, door industry free cash 

flow is estimated to decrease by as 

much as $5.7 million, or 15.7 percent 

compared to the base-case value of 

$36.1 million in the year before the 

compliance date. This standard level for 

doors at TSL 5 is nearly identical to the 

standard levels at TSL 3. Total 

conversion costs are expected to reach 

$15 million. 

For TSL 6, DOE estimates impacts on 

door INPV to range from ¥$193.8 

million to $690.5 million, or a change in 

INPV of ¥42.6 percent to 151.9 percent. 

At this level, door industry free cash 

flow is estimated to decrease by as 

much $35.6 million, or 98.5 percent 

compared to the base-case value of 

$36.1 million in the year before the 

compliance date. Conversion costs 

would total $92 million. At this level, 

some door manufacturers would likely 

choose to leave the industry rather than 

make the necessary investments to 

comply with standards. 

Walk-In Cooler and Freezer 

Refrigeration MIA Results 

At TSL 1, DOE estimates impacts on 

refrigeration INPV to range from ¥$18.3 

million to ¥$5.9 million, or a change in 

INPV of ¥9.7 percent to ¥3.1 percent. 

At this level, refrigeration industry free 

cash flow is estimated to decrease by as 

much as $4.6 million, or 28.2 percent 

compared to the base-case value of 

$16.3 million in 2016, the year before 

the compliance year. For dedicated 

condensing, medium temperature, 

indoor refrigeration systems, DOE’s 

engineering analysis indicates that 

manufacturers would need to 

incorporate multiple design options to 

achieve this standard. The design 

options would likely include variable 

speed evaporator fan motors and larger 

condensing coils. For dedicated 

condensing, low temperature, indoor 

refrigeration systems, manufacturers 

may need to further include improved 

condenser fan, improved evaporator fan 

blades, and electronically commutated 

motors. For dedicated condensing, 

medium temperature, outdoor 

refrigeration systems, design options 

necessary to meet TSL 1 would include 

variable speed evaporator fan motors, 

improved condenser fan blades, 

electronically commutated condenser 

fan motors, and improved evaporator 

fan blades. For dedicated condensing, 

low temperature, outdoor refrigeration 

systems, additional design options 

required to meet the trial standard level 

include ambient sub-cooling, variable 

speed condenser fans, and defrost 

control strategies. For multiplex 

refrigeration, manufacturers would need 

to evaluate design improvements, such 

as variable speed evaporator fan motors, 

improved fan blade designs, defrost 

control, and hot gas defrost. Integration 

of these design options across 

equipment classes will require extensive 

engineering investments. As a result, 

conversion costs total $15 million for 

the industry. 

At TSL 2, DOE estimates impacts on 

refrigeration INPV to range from ¥$35.5 

million to ¥$4.4 million, or a change in 

INPV of ¥18.8 percent to ¥2.3 percent. 

At this level, refrigeration industry free 

cash flow is estimated to decrease by as 

much as $7.2 million, or 44.0 percent 

compared to the base-case value of 

$16.3 million in the year before the 

compliance date. From TSL 1 to TSL 2, 


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standards increase for most equipment 

classes. For dedicated condensing, 

medium temperature, indoor systems, a 

manufacturer would need to consider 

including electronically commutated 

condenser fan motors, improved 

condenser fan blades, and improved 

evaporator fan blades. For dedicated 

condensing, medium temperature, 

outdoor systems, the most cost effective 

options include using ambient 

subcooling, variable speed condenser 

fan motors, and floating head pressure 

with electronic expansion valves. For 

dedicated condensing, low temperature, 

outdoor systems, manufacturers will 

need to consider incorporating 

improved evaporator fan blades, larger 

condenser coils, and floating head 

pressure with electronic expansion 

valves. The range of changes does not 

require significant amounts of new 

production equipment, but could 

require substantial development and 

engineering time. DOE estimates the 

WICF refrigeration industry’s 

conversion costs to increase to $24 

million. 

At TSL 3, the standards and the 

impacts on the walk-in refrigeration 

industry are identical to those at TSL 1. 

At TSL 4, the standards and the 

impacts on the walk-in refrigeration 

industry are identical to those at TSL 2. 

TSL 5 and TSL 6 represent max-tech 

for WICF refrigeration systems. DOE 

estimates impacts on refrigeration INPV 

to range from ¥$43.3 million to ¥$0.8 

million, or a change in INPV of ¥22.9 

percent to ¥0.4 percent. At this level, 

refrigeration industry free cash flow is 

estimated to decrease by as much as 

$8.3 million, or 51.0 percent compared 

to the base-case value of $16.3 million 

in the year before the compliance year. 

DOE’s engineering analysis indicates 

that manufacturers would need to 

incorporate design changes beyond 

those for TSL 4 and TSL 3 to achieve 

this standard. Additional design 

changes for dedicated condensing, low 

temperature, indoor and outdoor 

refrigeration would include defrost 

controls. For multiplex units, the 

standard levels at TSL 5 and 6 are 

identical to those at TSL 1. Total 

conversion costs are expected to reach 

$28 million for the industry. 

b. Impacts on Direct Employment 

Methodology 

To quantitatively assess the impacts 

of energy conservation standards on 

employment, DOE used the GRIM to 

estimate the domestic labor 

expenditures and number of employees 

in the base case and at each TSL from 

2013 through 2046. DOE used statistical 

data from the U.S. Census Bureau’s 2011 

Annual Survey of Manufacturers (ASM), 

the results of the engineering analysis, 

and interviews with manufacturers to 

determine the inputs necessary to 

calculate industry-wide labor 

expenditures and domestic employment 

levels. Labor expenditures related to 

manufacturing of the product are a 

function of the labor intensity of the 

product, the sales volume, and an 

assumption that wages remain fixed in 

real terms over time. The total labor 

expenditures in each year are calculated 

by multiplying the MPCs by the labor 

percentage of MPCs. 

The total labor expenditures in the 

GRIM were then converted to domestic 

production employment levels by 

dividing production labor expenditures 

by the annual payment per production 

worker (production worker hours 

multiplied by the labor rate found in the 

U.S. Census Bureau’s 2011 ASM). The 

estimates of production workers in this 

section cover workers, including line 

supervisors who are directly involved in 

fabricating and assembling a product 

within the OEM facility. Workers 

performing services that are closely 

associated with production operations, 

such as materials handling tasks using 

forklifts, are also included as production 

labor. DOE’s estimates only account for 

production workers who manufacture 

the specific products covered by this 

rulemaking. To further establish a lower 

bound to negative impacts on 

employment, DOE reviewed design 

options, conversion costs, and market 

share information to determine the 

maximum number of manufacturers that 

would leave the industry at each TSL. 

In evaluating the impact of energy 

efficiency standards on employment, 

DOE performed separate analyses on all 

three walk-in component manufacturer 

industries: panels, doors and 

refrigeration systems. 

Using the GRIM, DOE estimates in the 

absence of new energy conservation 

standards, there would be 3,482 

domestic production workers for walkin panels, 1,187 domestic production 

workers for walk-in doors, and 346 

domestic production workers for walkin refrigeration systems in 2017. 

Table V–25, Table V–26, and Table V– 

27 show the range of the impacts of 

potential new energy conservation 

standards on U.S. production workers in 

the panel, door, and refrigeration system 

markets, respectively. Additional detail 

on the analysis of direct employment 

can be found in chapter 12 of the TSD. 

TABLE V–25—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR PANELS

TSL 1 2 3 4 5 6 

Potential Changes in Domestic Production 

Workers 2017 (from a base case employment 

of 3,462).

¥435 to 134 ..... 0 ........................ ¥871 to 490 ..... ¥435 to 134 ..... ¥871 to 490 ..... ¥1,741 to 3,243 

TABLE V–26—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR DOORS

TSL 1 2 3 4 5 6 

Potential Changes in Domestic Production 

Workers 2017 (from a base case employment 

of 1,187).

¥60 to 149 ....... 0 to 97 ............... ¥120 to 196 ..... ¥60 to 146 ....... ¥120 to 192 ..... ¥349 to 2,409 

TABLE V–27—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR

REFRIGERATION SYSTEMS

TSL 1 2 3 4 5 6 

Potential Changes in Domestic Production 

Workers 2017 (from a base case employment 

of 346).

0 to 31 ............... ¥88 to 74 ......... 0 to 31 ............... ¥88 to 74 ......... ¥116 to 99 ....... ¥116 to 99 


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55860 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

The employment impacts shown in 

Table V–25 through Table V–27 

represent the potential production 

employment changes that could result 

following the compliance date of new 

energy conservation standards. The 

upper end of the results in the table 

estimates the maximum increase in the 

number of production workers after the 

implementation of new energy 

conservation standards and it assumes 

that manufacturers would continue to 

produce the same scope of covered 

products within the United States. The 

lower end of the range represents the 

maximum decrease to the total number 

of U.S. production workers in the 

industry due to manufacturers leaving 

the industry. However, in the long-run, 

DOE would expect the manufacturers 

that do not leave the industry to add 

employees to cover lost capacity and to 

meet market demand. 

The employment impacts shown are 

independent of the employment impacts 

from the broader U.S. economy, which 

are documented in the Employment 

Impact Analysis, chapter 13 of the TSD. 

c. Impacts on Manufacturing Capacity 

Panels 

Manufacturers indicated that design 

options that necessitate thicker panels 

could lead to longer production times 

for panels. In general, every additional 

inch of foam increases panel cure times 

by roughly 20 minutes. DOE 

understands from manufacturer 

interviews, however, that the industry is 

not currently operating at full capacity. 

Given this fact, and the number of 

manufacturers able to produce panels 

above the baseline today, an increase in 

thickness at lower panel standards—that 

is, a standard that is based on 4-inch or 

5-inch panels—is not likely to lead to 

product shortages in the industry. 

However, a standard that necessitates 6- 

inch panels for any of the panel 

equipment classes would require 

manufacturers to add equipment to 

maintain throughput due to longer 

curing times or to purchase all new 

tooling to enable production if the 

manufacturer’s current equipment 

cannot accommodate 6-inch panels. 

These conversion costs are discussed 

further in chapter 12 of the TSD. 

Doors 

Display door manufacturers did not 

identify any design options which 

would lead to capacity constraints. 

However, manufacturers commented on 

differences between the two types of 

low-emittance coatings analyzed: hard 

low emittance coating (‘‘hard-coat’’), the 

baseline option, and soft low emittance 

coating (‘‘soft-coat’’), the corresponding 

design option. Hard-coat is applied to 

the glass pane at high temperatures 

during the formation of the pane and is 

extremely durable, while soft-coat is 

applied in a separate step after the glass 

pane is formed and is less durable than 

hard low emittance coating but has 

better performance characteristics. 

Manufacturers indicated that soft-coat is 

significantly more difficult to work with 

and may require new conveyor 

equipment. As manufacturers adjust to 

working with soft-coat, longer lead 

times may occur. 

The production of solid doors is very 

similar to the production of panels and 

faces the same capacity challenges as 

panels. As indicated in the panel 

discussion above, DOE does not 

anticipate capacity constraints at a 

standard that moves manufacturers to 5 

inches of thickness. 

Refrigeration 

DOE did not identify any significant 

capacity constraints for the design 

options being evaluated for this 

rulemaking. For most refrigeration 

manufacturers, the walk-in market 

makes up a relatively small percentage 

of their overall revenues. Additionally, 

most of the design options being 

evaluated are available as product 

options today. As a result, the industry 

should not experience capacity 

constraints directly resulting from an 

energy conservation standard. 

d. Impacts on Small Manufacturer SubGroup 

As discussed in section IV.I.1, using 

average cost assumptions to develop an 

industry cash-flow estimate may not be 

adequate for assessing differential 

impacts among manufacturer subgroups. Small manufacturers, niche 

equipment manufacturers, and 

manufacturers exhibiting a cost 

structure substantially different from the 

industry average could be affected 

disproportionately. DOE used the 

results of the industry characterization 

to group manufacturers exhibiting 

similar characteristics. Consequently, 

DOE analyzes small manufacturers as a 

sub-group. 

DOE evaluated the impact of new 

energy conservation standards on small 

manufacturers, specifically ones defined 

as ‘‘small businesses’’ by the SBA. The 

SBA defines a ‘‘small business’’ as 

having 750 employees or less for NAICS 

333415, ‘‘Air-Conditioning and Warm 

Air Heating Equipment and Commercial 

and Industrial Refrigeration Equipment 

Manufacturing.’’ Based on this 

definition, DOE identified 2 

refrigeration system manufacturers, 42 

panel manufacturers, and 5 door 

manufacturers in the WICF industry that 

are small businesses. DOE describes the 

differential impacts on these small 

businesses in today’s notice at section 

VI.B, Review Under the Regulatory 

Flexibility Act. 

Section VI.B concludes that larger 

manufacturers could have a competitive 

advantage in multiple component 

markets due to their size, engineering 

and testing resources, and ability to 

access capital. Additionally, in some 

market segments, larger manufacturers 

have significantly higher production 

volumes over which to spread costs. In 

particular, DOE’s analysis shows that 

this rule could drive consolidation in 

the walk-in cooler and freezer panel 

industry. While DOE cannot certify that 

today’s rule would not have a 

significant economic impact on a 

substantial number of small 

manufacturers, DOE has considered 

these potential impacts and sought to 

mitigate any such impacts in choosing 

the TSL proposed in today’s rule. For 

example, DOE specifically considered 

TSL 2, which would not raise the 

efficiency requirement on panel 

manufacturers above the base case level 

in order to minimize impacts on panel 

manufacturers. . In addition to the range 

of TSLs considered, alternatives to the 

proposed rule that were considered 

include the following policy 

alternatives: (1) No new regulatory 

action, (2) commercial consumer 

rebates, and (3) commercial consumer 

tax credits. Chapter 17 of the TSD 

associated with this proposed rule 

includes a report referred to in Section 

VI.A in the preamble as the regulatory 

impact analysis (RIA). The energy 

savings of these regulatory alternatives 

are one to two orders of magnitude 

smaller than those expected from the 

standard levels under consideration. 

The range of economic impacts of these 

regulatory alternatives is an order of 

magnitude smaller than the range of 

impacts expected from the standard 

levels under consideration. For a 

complete discussion of the impacts on 

small businesses, see section VI.B and 

chapter 12 of the TSD. 

e. Cumulative Regulatory Burden 

While any one regulation may not 

impose a significant burden on 

manufacturers, the combined effects of 

several impending regulations may have 

serious consequences for some 

manufacturers, groups of manufacturers, 

or an entire industry. Assessing the 

impact of a single regulation may 

overlook this cumulative regulatory 

burden. Multiple regulations affecting 

the same manufacturer can strain profits 


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and can lead companies to abandon 

product lines or markets with lower 

expected future returns than competing 

products. For these reasons, DOE 

conducts an analysis of cumulative 

regulatory burden as part of its 

rulemakings pertaining to appliance and 

equipment efficiency. 

For the cumulative regulatory burden 

analysis, DOE looks at other regulations 

that could affect walk in cooler and 

freezer manufacturers that will take 

effect approximately 3 years before or 

after the compliance date of new energy 

conservation standards for these 

products. In addition to the new energy 

conservation regulations on walk-ins, 

several other Federal regulations apply 

to these products and other equipment 

produced by the same manufacturers. 

While the cumulative regulatory burden 

focuses on the impacts on 

manufacturers of other Federal 

requirements, DOE also describes a 

number of other regulations in section 

VI.B because it recognizes that these 

regulations also impact the products 

covered by this rulemaking. 

Companies that produce a wide range 

of regulated products may be faced with 

more capital and product development 

expenditures than competitors with a 

narrower scope of products. Regulatory 

burdens can prompt companies to exit 

the market or reduce their product 

offerings, potentially reducing 

competition. Smaller companies in 

particular can be affected by regulatory 

costs since these companies have lower 

sales volumes over which they can 

amortize the costs of meeting new 

regulations. DOE discusses below the 

regulatory burdens manufacturers could 

experience, mainly, DOE regulations for 

other products or equipment produced 

by walk-in manufacturers and other 

Federal requirements including the 

United States Clean Air Act, the Energy 

Independence and Security Act of 2007. 

While this analysis focuses on the 

impacts on manufacturers of other 

Federal requirements, in this section 

DOE also describes a number of other 

regulations that could also impact the 

WICF equipment covered by this 

rulemaking: potential climate change 

and greenhouse gas legislation, State 

conservation standards, and food safety 

regulations. DOE discusses these and 

other requirements, and includes the 

full details of the cumulative regulatory 

burden, in chapter 12 of the NOPR TSD. 

DOE Regulations for Other Products 

Produced by Walk-In Cooler and Freezer 

Manufacturers 

In addition to the new energy 

conservation standards on walk in 

cooler and freezer equipment, several 

other Federal regulations apply to other 

products produced by the same 

manufacturers. DOE recognizes that 

each regulation can significantly affect a 

manufacturer’s financial operations. 

Multiple regulations affecting the same 

manufacturer can strain manufacturers’ 

profits and possibly cause an exit from 

the market. DOE is conducting an 

energy conservation standard 

rulemaking for commercial refrigeration 

equipment. In its Notice of Proposed 

Rulemaking for commercial refrigeration 

equipment, DOE initially estimated 

conversion costs for the CRE industry to 

total $87.5 million. Conversion costs are 

one-time expenses the industry will 

bear between the announcement date of 

the standard and the effective date of 

the standard. 

Federal Clean Air Act 

The Clean Air Act defines the EPA’s 

responsibilities for protecting and 

improving the nation’s air quality and 

the stratospheric ozone layer. The most 

significant of these additional 

regulations is the EPA-mandated phaseout of hydrochlorofluorocarbons 

(HCFCs). The Act requires that, on a 

quarterly basis, any person who 

produced, imported, or exported certain 

substances, including HCFC 

refrigerants, report the amount 

produced, imported and exported. 

Additionally—effective January 1, 

2015—selling, manufacturing, and using 

any such substance is banned unless 

such substance (1) has been used, 

recovered, and recycled; (2) is used and 

entirely consumed in the production of 

other chemicals; or (3) is used as a 

refrigerant in appliances manufactured 

prior to January 1, 2020. Finally, 

production phase-outs will continue 

until January 1, 2030 when such 

production will be illegal. These bans 

could trigger design changes to natural 

or low global warming potential 

refrigerants and could impact the 

insulation used in products covered by 

this rulemaking. 

State Conservation Standards 

Since 2004, the State of California has 

had established energy standards for 

walk-in coolers and freezers. 

California’s Code of Regulations (Title 

20, Section 1605) prescribe 

requirements for insulation levels, 

motor types, and use of automatic doorclosers used for WICF applications. 

These requirements have since been 

amended and mirror those standards 

that Congress prescribed as part of EISA 

2007. Other States, notably, 

Connecticut, Maryland, and Oregon, 

have recently established energy 

efficiency standards for walk-ins that 

are also identical to the ones contained 

in EPCA. These standards would not be 

preempted until any Federal standards 

that DOE may adopt take effect. See 42 

U.S.C. 6316(h)(2). Once DOE’s standards 

are finalized, all other State standards 

that are in effect would be pre-empted. 

As a result, these State standards do not 

pose any regulatory burden above that 

which has already been established in 

EPCA. 

Food Safety Standards 

Manufacturers expressed concern 

regarding Federal, State, and local food 

safety regulations. A walk-in must 

perform to the standards set by NSF, 

state, country, and city health 

regulations. There is general concern 

among manufacturers about conflicting 

regulation scenarios as new energy 

conservation standards may potentially 

prevent or make it more difficult for 

them to comply with food safety 

regulations. 

3. National Impact Analysis 

a. Amount and Significance of Energy 

Savings 

To estimate the national energy 

savings attributable to the TSLs under 

consideration, DOE compared the 

energy consumption of the refrigeration 

systems under the base case to their 

anticipated energy consumption under 

each TSL. Because all the TSLs except 

TSL 6 combine high efficiency 

refrigeration systems with envelope 

components having small efficiency 

gains over the baseline levels, DOE 

projected that the additional impact 

from higher efficiency levels for 

envelope components on the capacity of 

refrigeration systems sold for each 

system, and subsequently on the 

aggregate shipped capacity, would not 

significantly impact the energy savings 

estimate for each TSL. Consequently, 

DOE calculated the baseline energy 

consumption and the energy savings for 

higher efficiency refrigeration systems 

independent of the envelope component 

efficiency level at the TSLs considered. 

DOE did, however, estimate this 

reduction in capacity from improved 

envelope component efficiency on an 

aggregate basis at each TSL and 

accounted for the economic benefit in 

the calculation of the national net 

present value for each TSL as discussed 

in section V.3.b. 

By contrast, the energy savings 

benefits for the envelope components 

are influenced directly by the efficiency 

of the refrigeration system. Because of 

this, the energy savings for the envelope 

levels are calculated such that both the 

baseline and the higher efficiency 


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55862 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

envelope components are paired with 

the refrigeration system at the efficiency 

level corresponding to the specific TSL. 

Table V–28 through Table V–30 

present DOE’s forecasts of the national 

primary energy savings for each TSL of 

the refrigeration systems and selected 

envelope components, and the 

combination of refrigeration systems 

and envelope components. In addition 

Table V–30 shows the FFC energy 

savings for each TSL. These forecasts 

were calculated using the approach 

described in section IV.G. Chapter 10 of 

the NOPR TSD presents tables that also 

show the magnitude of the energy 

savings. 

TABLE V–28—WICF REFRIGERATION SYSTEMS: CUMULATIVE NATIONAL ENERGY SAVINGS IN QUADS

[Primary energy savings] 

Equipment class 

Trial standard levels 

1,3 2,4 5 6 

DC.M.I* ............................................................................................................ 0.024 0.041 0.041 0.041 

DC.M.O* ........................................................................................................... 1.825 2.446 2.524 2.524 

DC.L.I* ............................................................................................................. 0.009 0.016 0.017 0.017 

DC.L.O* ............................................................................................................ 0.768 1.162 1.256 1.256 

MC.M ............................................................................................................... 0.378 0.376 0.378 0.378 

MC.L ................................................................................................................ 0.099 0.084 0.099 0.099 

* For DC refrigeration systems, results include both capacity ranges. 

TABLE V–29—COMPONENT EQUIPMENT CLASS: CUMULATIVE NATIONAL ENERGY SAVINGS IN QUADS

[Primary energy savings] 

Equipment class 

Trial standard levels 

1 2 3 4 5 6 

SP.M ................................................................................ 0.259 0.000 0.324 0.221 0.273 0.553 

SP.L ................................................................................. 0.447 0.000 0.564 0.380 0.447 0.619 

FP.L .................................................................................. 0.048 0.000 0.069 0.040 0.055 0.069 

DD.M ................................................................................ 0.405 0.394 0.405 0.394 0.394 0.620 

DD.L ................................................................................. 0.021 0.020 0.029 0.020 0.020 0.095 

PD.M ................................................................................ 0.009 0.000 0.009 0.007 0.007 0.073 

PD.L ................................................................................. 0.113 0.000 0.141 0.106 0.128 0.140 

FD.M ................................................................................ 0.000 0.000 0.000 0.000 0.000 0.004 

FD.L ................................................................................. 0.010 0.000 0.013 0.007 0.012 0.013 

TABLE V–30—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: CUMULATIVE NATIONAL PRIMARY AND FULL-FUEL

CYCLE ENERGY SAVINGS IN QUADS

Application 

Trial standard levels 

1 2 3 4 5 6 

Medium Temperature ....................................................... 2.900 3.257 2.965 3.486 3.617 4.193 

Low Temperature ............................................................. 1.515 1.283 1.692 1.816 2.032 2.308 

Primary Energy Savings Total ......................................... 4.415 4.540 4.658 5.302 5.649 6.501 

Upstream Energy Savings ............................................... 0.072 0.074 0.076 0.086 0.092 0.106 

FFC Total .................................................................. 4.487 4.614 4.734 5.388 5.741 6.607 

Circular A–4 requires agencies to 

present analytical results, including 

separate schedules of the monetized 

benefits and costs that show the type 

and timing of benefits and costs. 

Circular A–4 also directs agencies to 

consider the variability of key elements 

underlying the estimates of benefits and 

costs. For this rulemaking, DOE 

undertook a sensitivity analysis using 

nine rather than 30 years of product 

shipments. The choice of a 9-year 

period is a proxy for the timeline in 

EPCA for the review of certain energy 

conservation standards and potential 

revision of and compliance with such 

revised standards. We would note that 

the review timeframe established in 

EPCA generally does not overlap with 

the product lifetime, product 

manufacturing cycles or other factors 

specific to walk-in coolers and freezers. 

Thus, this information is presented for 

informational purposes only and is not 

indicative of any change in DOE’s 

analytical methodology. The NES of 

estimated primary energy savings 

results based on a 9-year analytical 

period are presented in Table V–31 

through Table V–33. The impacts are 

counted over the lifetime of products 

purchased in 2017–2025. 


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TABLE V–31—WICF REFRIGERATION SYSTEMS: CUMULATIVE NATIONAL PRIMARY ENERGY SAVINGS IN QUADS FOR UNITS

SOLD IN 2017–2025 

Equipment class 

Trial standard levels 

1,3 2,4 5 6 

DC.M.I* ............................................................................................................ 0.007 0.012 0.012 0.012 

DC.M.O* ........................................................................................................... 0.547 0.733 0.756 0.756 

DC.L.I* ............................................................................................................. 0.003 0.005 0.005 0.005 

DC.L.O* ............................................................................................................ 0.230 0.348 0.376 0.376 

MC.M ............................................................................................................... 0.113 0.113 0.113 0.113 

MC.L ................................................................................................................ 0.030 0.025 0.030 0.030 

* For DC refrigeration systems, results include multiple capacity ranges. 

TABLE V–32—COMPONENT EQUIPMENT CLASS: CUMULATIVE NATIONAL PRIMARY ENERGY SAVINGS IN QUADS FOR UNITS

SOLD IN 2017–2025 

[Primary energy savings] 

Equipment class 

Trial standard levels 

1 2 3 4 5 6 

SP.M ........................................................ 0.063 0.000 0.079 0.054 0.066 0.134 

SP.L ......................................................... 0.108 0.000 0.137 0.092 0.108 0.150 

FP.L .......................................................... 0.012 0.000 0.017 0.010 0.013 0.017 

DD.M ........................................................ 0.123 0.119 0.123 0.119 0.119 0.188 

DD.L ......................................................... 0.006 0.006 0.009 0.006 0.006 0.029 

PD.M ........................................................ 0.003 0.000 0.003 0.002 0.002 0.021 

PD.L ......................................................... 0.033 0.000 0.041 0.031 0.037 0.041 

FD.M ........................................................ 0.000 0.000 0.000 0.000 0.000 0.001 

FD.L ......................................................... 0.002 0.000 0.003 0.002 0.003 0.003 

TABLE V–33—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: CUMULATIVE NATIONAL PRIMARY AND FULL-FUEL

CYCLE ENERGY SAVINGS IN QUADS FOR UNITS SOLD IN 2017–2025 

Application 

Trial standard levels 

1 2 3 4 5 6 

Medium Temperature ............................... 0.855 0.977 0.871 1.033 1.069 1.226 

Low Temperature ..................................... 0.425 0.384 0.470 0.519 0.579 0.651 

Primary Energy Savings Total ................. 1.280 1.361 1.341 1.552 1.648 1.877 

Upstream Energy Savings ....................... 0.021 0.022 0.022 0.025 0.027 0.031 

FFC Total .......................................... 1.301 1.383 1.363 1.577 1.675 1.908 

b. Net Present Value of Consumer Costs 

and Benefits 

DOE estimated the cumulative NPV to 

the nation of the total costs and savings 

for consumers that would result from 

particular composite standard levels for 

the refrigeration systems and 

components. In accordance with OMB 

guidelines on regulatory analysis (OMB 

Circular A–4, section E, September 17, 

2003), DOE calculated NPV using both 

a 7-percent and a 3-percent real 

discount rate. The 7-percent rate is an 

estimate of the average before-tax rate of 

return on private capital in the U.S. 

economy, and reflects the returns on 

real estate and small business capital, 

including corporate capital. DOE used 

this discount rate to approximate the 

opportunity cost of capital in the private 

sector, since recent OMB analysis has 

found the average rate of return on 

capital to be near this rate. In addition, 

DOE used the 3-percent rate to capture 

the potential effects of standards on 

private consumption. This rate 

represents the rate at which society 

discounts future consumption flows to 

their present value. It can be 

approximated by the real rate of return 

on long-term government debt (i.e., 

yield on Treasury notes minus annual 

rate of change in the Consumer Price 

Index), which has averaged about 3 

percent on a pre-tax basis for the last 30 

years. 

Table V–34 through Table V–39 show 

the consumer NPV results for each of 

the TSLs DOE considered for the 

combination of refrigeration systems 

and envelope components, using both a 

7-percent and a 3-percent discount rate. 

In each case, the impacts cover the 

lifetime of products purchased in 2017– 

2046. For a particular TSL combination, 

improving component efficiency should 

result in reduced refrigeration load on 

the paired refrigeration system and 

consequently, the refrigeration system 

can be downsized, resulting in 

additional consumer benefits. In 

estimating the ‘‘first cost benefits,’’ DOE 

made several assumptions and has 

shown the results only in the summary 

table. For a discussion of these 

assumptions, see chapter 10 of the TSD. 


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TABLE V–34—WICF REFRIGERATION SYSTEMS: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT DISCOUNT

RATE FOR UNITS SOLD IN 2017–2046 

Equipment classes 

Trial standard levels 

1,3 2,4 5 6 

DC.M.I * ............................................................................................................ 38 52 52 52 

DC.M.O * .......................................................................................................... 3,417 3,943 3,937 3,937 

DC.L.I * ............................................................................................................. 12 19 19 19

DC.L.O * ........................................................................................................... 1,488 1,995 1,913 1,913 

MC.M ............................................................................................................... 835 843 835 835 

MC.L ................................................................................................................ 161 189 161 161 

* For DC refrigeration systems, results include both capacity ranges. 

TABLE V–35—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN 2017–2046 

Equipment class 

Trial standard levels 

1 2 3 4 5 6 

SP.M ........................................................ 289 0 121 207 11 ¥17,715 

SP.L ......................................................... 662 0 269 520 21 ¥4,298 

FP.L .......................................................... 63 0 52 48 22 ¥578 

DD.M ........................................................ 571 545 571 545 543 ¥11,200 

DD.L ......................................................... 54 51 0 51 50 ¥395 

PD.M ........................................................ 4 0 4 1 1 ¥1,764 

PD.L ......................................................... 106 0 38 88 6 ¥513 

FD.M ........................................................ 0 0 0 0 0 ¥106 

FD.L ......................................................... 10 0 5 9 2 ¥59 

TABLE V–36—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: NET PRESENT VALUE IN MILLIONS (2012$) AT A

7-PERCENT DISCOUNT RATE FOR UNITS SOLD IN 2017–2046 

Application 

Trial standard levels 

1 2 3 4 5 6 

Medium temperature 

Combined NPV ........................................ 5,155 5,384 4,987 5,592 5,380 ¥25,961 

First cost benefits ..................................... 6 3 18 34 45 153 

Sub-Total .......................................... 5,161 5,386 5,004 5,627 5,425 ¥25,809 

Low temperature 

Combined NPV ........................................ 2,555 2,255 2,025 2,919 2,193 ¥3,751 

First cost benefits ..................................... 49 0 89 96 246 344 

Sub-Total .......................................... 2,604 2,255 2,114 3,015 2,438 ¥3,408 

Total—All ................................... 7,765 7,641 7,118 8,642 7,864 ¥29,217 

TABLE V–37—WICF REFRIGERATION SYSTEMS: NET PRESENT VALUE IN MILLIONS (2012$) AT A 3-PERCENT DISCOUNT

RATE FOR UNITS SOLD IN 2017–2046 

Equipment class 

Trial standard levels 

1,3 2,4 5 6 

DC.M.I * ............................................................................................................ 107 159 159 159 

DC.M.O * .......................................................................................................... 9,161 11,047 11,147 11,147 

DC.L.I * ............................................................................................................. 36 61 60 60

DC.L.O * ........................................................................................................... 3,951 5,483 5,455 5,455 

MC.M ............................................................................................................... 2,143 2,157 2,143 2,143 

MC.L ................................................................................................................ 450 483 450 450 

* For DC refrigeration systems, results include both capacity ranges. 


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TABLE V–38—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 3-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN 2017–2046 

Equipment class 

Trial standard levels 

1 2 3 4 5 6 

SP.M ........................................................ 990 0 779 770 484 ¥32,834 

SP.L ......................................................... 2,151 0 1,468 1,694 797 ¥7,144 

FP.L .......................................................... 219 0 216 167 134 ¥985 

DD.M ........................................................ 1,667 1,602 1,667 1,602 1,597 ¥20,987 

DD.L ......................................................... 135 128 41 128 126 ¥640 

PD.M ........................................................ 21 0 21 13 12 ¥3,329 

PD.L ......................................................... 364 0 270 319 189 ¥803 

FD.M ........................................................ 1 0 1 1 1 ¥200 

FD.L ......................................................... 36 0 31 32 23 ¥92 

TABLE V–39—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: NET PRESENT VALUE IN MILLIONS (2012$) AT A

3-PERCENT DISCOUNT RATE FOR UNITS SOLD IN 2017–2046 

Application 

Trial standard levels 

1 2 3 4 5 6 

Medium temperature 

Combined NPV ........................................ 14,091 14,965 13,880 15,748 15,543 ¥43,901 

First cost benefits ..................................... 12 5 34 66 87 294 

Sub-Total .......................................... 14,102 14,970 13,914 15,814 15,630 ¥43,607 

Low temperature 

Combined NPV ........................................ 7,191 6,155 6,464 8,297 7,234 ¥3,700 

First cost benefits ..................................... 94 0 172 185 473 663 

Sub-Total .......................................... 7,285 6,155 6,636 8,482 7,707 ¥3,037 

Total—All ................................... 21,387 21,125 20,550 24,296 23,337 ¥46,644 

The NPV results based on the 

aforementioned 9-year analytical period 

are presented in Table V–40 through 

Table V–45. The impacts are counted 

over the lifetime of products purchased 

in 2017–2025. As mentioned previously, 

this information is presented for 

informational purposes only and is not 

indicative of any change in DOE’s 

analytical methodology or decision 

criteria. 

TABLE V–40—WICF REFRIGERATION SYSTEMS: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT DISCOUNT

RATE FOR UNITS SOLD IN 2017–2025 

Equipment classes 

Trial standard levels 

1,3 2,4 5 6 

DC.M.I * ............................................................................................................ 21 30 30 30 

DC.M.O * .......................................................................................................... 1,864 2,175 2,178 2,178 

DC.L.I * ............................................................................................................. 7 11 11 11 

DC.L.O * ........................................................................................................... 810 1,095 1,060 1,060 

MC.M ............................................................................................................... 451 455 451 451 

MC.L ................................................................................................................ 89 102 89 89 

* For DC refrigeration systems, results include both capacity ranges. 

TABLE V–41—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN 2017–2025 

Equipment class 

Trial standard levels 

1 2 3 4 5 6 

SP.M ........................................................ 128 0 35 89 ¥17 ¥9,275 

SP.L ......................................................... 306 0 92 238 ¥27 ¥2,293 

FP.L .......................................................... 29 0 21 21 6 ¥307 

DD.M ........................................................ 326 312 326 312 311 ¥5,473 

DD.L ......................................................... 29 28 3 28 27 ¥186 


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55866 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

TABLE V–41—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN 2017–2025—Continued 

Equipment class 

Trial standard levels 

1 2 3 4 5 6 

PD.M ........................................................ 3 0 3 1 1 ¥870 

PD.L ......................................................... 62 0 30 53 13 ¥244 

FD.M ........................................................ 0 0 0 0 0 ¥53 

FD.L ......................................................... 5 0 2 4 0 ¥30 

TABLE V–42—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: NET PRESENT VALUE IN MILLIONS (2012$) AT A

7-PERCENT DISCOUNT RATE FOR UNITS SOLD IN 2017–2025 

Application 

Trial standard levels 

1 2 3 4 5 6 

Medium temperature 

Combined NPV ........................................ 2,883 3,061 2,791 3,156 3,153 ¥12,843 

First cost benefits ..................................... 3 1 9 17 23 77 

Sub-Total .......................................... 2,886 3,062 2,800 3,174 3,176 ¥12,766 

Low temperature 

Combined NPV ........................................ 1,322 1,125 1,045 1,479 1,416 ¥1,829 

First cost benefits ..................................... 23 0 42 33 124 174 

Sub-Total .......................................... 1,345 1,125 1,087 1,512 1,540 ¥1,655 

Total—All ................................... 4,230 4,188 3,887 4,686 4,716 ¥14,421 

TABLE V–43—WICF REFRIGERATION SYSTEMS: NET PRESENT VALUE IN MILLIONS (2012$) AT A 3-PERCENT DISCOUNT

RATE FOR UNITS SOLD IN 2017–2025 

Equipment class 

Trial standard levels 

1,3 2,4 5 6 

DC.M.I * ............................................................................................................ 42 63 63 63 

DC.M.O * .......................................................................................................... 3,564 4,330 4,377 4,377 

DC.L.I * ............................................................................................................. 14 24 24 24

DC.L.O * ........................................................................................................... 1,535 2,143 2,145 2,145 

MC.M ............................................................................................................... 828 832 828 828 

MC.L ................................................................................................................ 177 187 177 177 

* For DC refrigeration systems, results include both capacity ranges. 

TABLE V–44—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 3-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN 2017–2025 

Equipment class 

Trial standard levels 

1 2 3 4 5 6 

SP.M ........................................................ 296 0 197 224 101 ¥12,538 

SP.L ......................................................... 651 0 385 503 167 ¥2,879 

FP.L .......................................................... 64 0 61 48 34 ¥392 

DD.M ........................................................ 675 650 675 650 648 ¥7,204 

DD.L ......................................................... 52 50 21 50 49 ¥203 

PD.M ........................................................ 9 0 9 6 5 ¥1,161 

PD.L ......................................................... 147 0 118 129 87 ¥261 

FD.M ........................................................ 0 0 0 0 0 ¥71 

FD.L ......................................................... 11 0 8 10 6 ¥35 


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TABLE V–45—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: NET PRESENT VALUE IN MILLIONS (2012$) AT A

3-PERCENT DISCOUNT RATE FOR UNITS SOLD IN 2017–2025 

Application 

Trial standard levels 

1 2 3 4 5 6 

Medium temperature 

Combined NPV ........................................ 5,414 5,875 5,315 6,106 6,022 ¥15,707 

First cost benefits ..................................... 4 2 12 24 32 107 

Sub-Total .......................................... 5,418 5,877 5,328 6,130 6,054 ¥15,600 

Low temperature 

Combined NPV ........................................ 2,624 2,403 2,319 3,092 2,688 ¥1,425 

First cost benefits ..................................... 34 0 62 67 172 240 

Sub-Total .......................................... 2,658 2,403 2,382 3,159 2,859 ¥1,185 

Total—All ................................... 8,076 8,281 7,709 9,289 8,913 ¥16,785 

c. Employment Impacts 

Besides the direct impacts on 

manufacturing employment discussed 

in section V.B.2.b, DOE develops 

general estimates of the indirect 

employment impacts of proposed 

standards on the economy. As discussed 

above, DOE expects energy conservation 

standards for walk-ins to reduce energy 

bills for commercial consumers, and the 

resulting net savings to be redirected to 

other forms of economic activity. DOE 

also realizes that these shifts in 

spending and economic activity by 

WICF owners could affect the demand 

for labor. Thus, indirect employment 

impacts may result from expenditures 

shifting between goods (the substitution 

effect) and changes in income and 

overall expenditure levels (the income 

effect) that occur due to the imposition 

of standards. These impacts may affect 

a variety of businesses not directly 

involved in the decision to make, 

operate, or pay the utility bills for walkins. To estimate these indirect economic 

effects, DOE used an input/output 

model of the U.S. economy using U.S. 

Department of Commerce, Bureau of 

Economic Analysis (BEA) and Bureau of 

Labor Statistics (BLS) data (as described 

in section IV.J; see chapter 13 of the 

TSD for more details). 

In this input/output model, the 

dollars saved on utility bills from more 

efficient walk-in equipment are centered 

in economic sectors that create more 

jobs than are lost in the electric utility 

industry when spending is shifted from 

electricity to other products and 

services. Thus, the proposed walk-in 

energy conservation standards are likely 

to slightly increase the net demand for 

labor in the economy. However, the net 

increase in jobs might be offset by other, 

unanticipated effects on employment. 

Neither the BLS data nor the input/

output model used by DOE indicates the 

quality of jobs lost or gained. As shown 

in Table V–46, DOE estimates that net 

indirect employment impacts from a 

proposed WICF standard are small 

relative to the national economy. 

TABLE V–46—NET CHANGE IN JOBS FROM INDIRECT EMPLOYMENT EFFECTS UNDER WICF TSLS

Year Trial standard 

level 

Net national change in jobs 

(thousands) 

Envelope 

components 

Refrigeration 

systems Total 

2017 ................................................................................................. 1 0.2 0.5 0.7 

2 0.1 0.7 0.8 

3 0.2 0.5 0.7 

4 0.2 0.7 0.9 

5 0.2 0.8 1.0 

6 0.3 0.8 1.1 

2021 ................................................................................................. 1 0.8 2.5 3.4 

2 0.3 3.4 3.7 

3 1.0 2.5 3.5 

4 0.8 3.4 4.2 

5 0.9 3.6 4.4 

6 1.4 3.6 5.0 

4. Impact on Utility or Performance of 

Equipment 

In performing the engineering 

analysis, DOE generally considers 

design options that would not lessen the 

utility or performance of the individual 

classes of equipment. See 42 U.S.C. 

6295(o)(2)(B)(i)(IV). As presented in the 

screening analysis (chapter 4 of the 

TSD), DOE eliminates design options 

that reduce the utility of the equipment 

from consideration. For this notice, DOE 

tentatively concludes that none of the 

efficiency levels proposed for walk-in 

cooler and freezer equipment would be 

likely to reduce the utility or 

performance of the equipment. 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55868 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

5. Impact of Any Lessening of 

Competition 

DOE has also considered any 

lessening of competition that is likely to 

result from amended standards. The 

Attorney General determines the 

impact, if any, of any lessening of 

competition likely to result from a 

proposed standard, and transmits such 

determination to the Secretary, together 

with an analysis of the nature and 

extent of such impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (ii)) 

To assist the Attorney General in 

making such determination, DOE will 

provide DOJ with copies of this NOPR 

and the TSD for review. DOE will 

consider DOJ’s comments on the 

proposed rule in preparing the final 

rule, and DOE will publish and respond 

to DOJ’s comments in that document. 

DOE also notes that during MIA 

interviews, domestic manufacturers 

indicated that foreign manufacturers do 

not generally enter the walk-in market 

and have not done so for the past 

several years; however, some walk-in 

equipment may be manufactured in 

Mexico or Canada. Manufacturers also 

stated that consolidation has occurred 

among walk-in manufacturers in recent 

years, due largely to the competitive 

nature of the industry and the recently 

enacted standards established by 

Congress. DOE believes that these trends 

will continue in this market regardless 

of the proposed standard levels chosen, 

but could accelerate if higher standard 

levels are set. 

DOE does not believe that the 

proposed standards would result in 

domestic firms moving their production 

facilities outside the United States. The 

vast majority of walk-ins sold in the 

United States are manufactured in the 

United States, in large part because 

walk-in equipment is generally bulky, 

making it difficult and expensive to ship 

internationally. Manufacturers generally 

indicated during interviews that they 

would modify their existing facilities to 

comply with the amended energy 

conservation standards that DOE 

develops. 

6. Need of the Nation To Conserve 

Energy 

An improvement in the energy 

efficiency of the products subject to 

today’s rule is likely to improve the 

security of the nation’s energy system by 

reducing overall demand for energy. 

Reduced electricity demand may also 

improve the reliability of the electricity 

system. Reductions in national electric 

generating capacity estimated for each 

considered TSL are reported in chapter 

14 of the TSD. 

Energy savings from amended 

standards for WICF equipment classes 

covered in today’s NOPR could also 

produce environmental benefits in the 

form of reduced emissions of air 

pollutants and greenhouse gases 

associated with electricity production. 

Table V–47 provides DOE’s estimate of 

cumulative emissions reductions 

projected to result from the TSLs 

considered in this rulemaking. The table 

includes both power sector emissions 

and upstream emissions. The upstream 

emissions were calculated using the 

multipliers discussed in section IV.G. 

DOE reports annual CO2, NOX, and Hg 

emissions reductions for each TSL in 

chapter 15 of the NOPR TSD. As 

discussed in section IV.J, DOE did not 

include NOX emissions reduction from 

power plants in States subject to CAIR, 

because an energy conservation 

standard would not affect the overall 

level of NOX emissions in those States 

due to the emissions caps mandated by 

CSAPR. 

TABLE V–47—CUMULATIVE EMISSIONS REDUCTION FOR WICF TSLS FOR EQUIPMENT PURCHASED IN 2017–2046 

TSL 

1 2 3 4 5 6 

Power Sector and Site Emissions * 

CO2 (million metric tons) .............................................................. 234.32 240.95 246.75 281.35 299.79 345.05 

NOX (thousand tons) ................................................................... 178.96 183.22 188.62 214.60 228.76 263.66 

Hg (tons) ...................................................................................... 0.52 0.53 0.54 0.62 0.66 0.76 

N2O (thousand tons) .................................................................... 5.22 5.33 5.51 6.26 6.67 7.70 

CH4 (thousand tons) .................................................................... 29.18 29.98 30.74 35.03 37.33 42.98 

SO2 (thousand tons) .................................................................... 313.03 322.01 329.61 375.89 400.52 460.93 

Upstream Emissions 

CO2 (million metric tons) .............................................................. 13.87 14.27 14.61 16.66 17.75 20.43 

NOX (thousand tons) ................................................................... 190.90 196.36 201.02 229.24 244.26 281.10 

Hg (tons) ...................................................................................... 0.01 0.01 0.01 0.01 0.01 0.01 

N2O (thousand tons) .................................................................... 0.14 0.14 0.15 0.17 0.18 0.21 

CH4 (thousand tons) .................................................................... 1,159.66 1,192.72 1,221.16 1,392.52 1,483.77 1,707.59 

SO2 (thousand tons) .................................................................... 2.97 3.06 3.13 3.57 3.80 4.38 

Total Emissions 

CO2 (million metric tons) .............................................................. 248.19 255.22 261.36 298.01 317.54 365.48 

NOX (thousand tons) ................................................................... 369.85 379.58 389.64 443.84 473.02 544.76 

Hg (tons) ...................................................................................... 0.52 0.54 0.55 0.63 0.67 0.77 

N2O (thousand tons) .................................................................... 5.36 5.48 5.65 6.43 6.85 7.90 

CH4 (thousand tons) .................................................................... 1,188.84 1,222.70 1,251.90 1,427.56 1,521.10 1,750.57 

SO2 (thousand tons) .................................................................... 316.00 325.06 332.74 379.46 404.32 465.31 

As part of the analysis for this NOPR, 

DOE estimated monetary benefits likely 

to result from the reduced emissions of 

CO2 and NOX that DOE estimated for 

each of the TSLs considered. As 

discussed in section IV.M.1, DOE used 

values for the SCC developed by an 

interagency process. The interagency 

group selected four sets of SCC values 

for use in regulatory analyses. Three sets 

are based on the average SCC from three 

integrated assessment models, at 

discount rates of 2.5 percent, 3 percent, 

and 5 percent. The fourth set, which 

represents the 95th-percentile SCC 


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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 55869 

estimate across all three models at a 3- 

percent discount rate, is included to 

represent higher-than-expected impacts 

from temperature change further out in 

the tails of the SCC distribution. The 

four values for CO2 emissions 

reductions in 2015, expressed in 2012$, 

are $12.9/ton, $40.8/ton, $62.2/ton, and 

$117.0/ton. The values for later years 

are higher due to increasing damages as 

the magnitude of climate change 

increases. 

Table V–48 presents the global value 

of CO2 emissions reductions at each 

TSL. DOE calculated domestic values as 

a range from 7 percent to 23 percent of 

the global values, and these results are 

presented in chapter 16 of the NOPR 

TSD. 

TABLE V–48—CUMULATIVE EMISSIONS REDUCTION FOR WICF TSLS

[2017 through 2073] 

TSL 

SCC case *

5% discount 

rate, 

average * 

3% discount 

rate, 

average * 

2.5% discount 

rate, average * 

3% discount 

rate, 95th 

percentile * 

Primary Energy Emissions 

Million 2012$ 

1 ....................................................................................................................... 1,477.1 7,031.6 11,276.4 21,608.4 

2 ....................................................................................................................... 1,532.4 7,269.9 11,648.3 22,334.5 

3 ....................................................................................................................... 1,552.5 7,396.3 11,863.3 22,730.2 

4 ....................................................................................................................... 1,777.9 8,455.6 13,556.7 25,982.3 

5 ....................................................................................................................... 1,892.8 9,004.8 14,438.5 27,670.6 

6 ....................................................................................................................... 2,173.0 10,348.6 16,597.3 31,802.7 

Upstream Emissions 

1 ....................................................................................................................... 86.8 415.1 665.9 1,277.0 

2 ....................................................................................................................... 90.0 429.1 687.8 1,319.6 

3 ....................................................................................................................... 91.2 436.7 700.6 1,343.3 

4 ....................................................................................................................... 104.4 499.1 800.6 1,535.4 

5 ....................................................................................................................... 111.2 531.6 852.7 1,635.2 

6 ....................................................................................................................... 127.7 610.9 980.2 1,879.4 

Total Emissions 

1 ....................................................................................................................... 1,563.8 7,446.7 11,942.3 22,885.4 

2 ....................................................................................................................... 1,622.4 7,698.9 12,336.1 23,654.1 

3 ....................................................................................................................... 1,643.7 7,832.9 12,563.9 24,073.6 

4 ....................................................................................................................... 1,882.4 8,954.8 14,357.3 27,517.7 

5 ....................................................................................................................... 2,003.9 9,536.4 15,291.2 29,305.8 

6 ....................................................................................................................... 2,300.7 10,959.5 17,577.5 33,682.1 

* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.9, $40.8, $62.2 and $117.0 per metric ton (2012$). 

DOE is well aware that scientific and 

economic knowledge about the 

contribution of CO2 and other GHG 

emissions to changes in the future 

global climate and the potential 

resulting damages to the world economy 

continues to evolve rapidly. Thus, any 

value placed in this NOPR on reducing 

CO2 emissions is subject to change. 

DOE, together with other Federal 

agencies, will continue to review 

various methodologies for estimating 

the monetary value of reductions in CO2

and other GHG emissions. This ongoing 

review will consider the comments on 

this subject that are part of the public 

record for this NOPR and other 

rulemakings, as well as other 

methodological assumptions and issues. 

However, consistent with DOE’s legal 

obligations, and taking into account the 

uncertainty involved with this 

particular issue, DOE has included in 

this NOPR the most recent values and 

analyses resulting from the ongoing 

interagency review process. 

DOE also estimated a range for the 

cumulative monetary value of the 

economic benefits associated with NOX

and Hg emissions reductions 

anticipated to result from amended 

ballast standards. Table V–49 presents 

the present value of cumulative NOX

emissions reductions for each TSL 

calculated using the average dollar-perton values at 7-percent and 3-percent 

discount rates. 

TABLE V–49—CUMULATIVE PRESENT VALUE OF NOX EMISSIONS REDUCTION FOR WICF TSLS

[2017 through 2073] 

TSL 3% discount 

rate 

7% discount 

rate 

Power Sector Emissions 

Million 2012$ 

1 ........................................................................................................................................................................... 219.7 96.3 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55870 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

TABLE V–49—CUMULATIVE PRESENT VALUE OF NOX EMISSIONS REDUCTION FOR WICF TSLS—Continued 

[2017 through 2073] 

TSL 3% discount 

rate 

7% discount 

rate 

2 ........................................................................................................................................................................... 227.7 101.0 

3 ........................................................................................................................................................................... 231.0 100.9 

4 ........................................................................................................................................................................... 264.4 116.2 

5 ........................................................................................................................................................................... 281.5 123.6 

6 ........................................................................................................................................................................... 323.3 141.4 

Upstream Emissions 

1 ........................................................................................................................................................................... 240.1 105.4 

2 ........................................................................................................................................................................... 249.4 110.5 

3 ........................................................................................................................................................................... 252.3 110.5 

4 ........................................................................................................................................................................... 289.1 127.2 

5 ........................................................................................................................................................................... 307.7 135.3 

6 ........................................................................................................................................................................... 353.1 154.8 

Total Emissions 

1 ........................................................................................................................................................................... 459.8 201.6 

2 ........................................................................................................................................................................... 477.1 211.4 

3 ........................................................................................................................................................................... 483.3 211.4 

4 ........................................................................................................................................................................... 553.5 243.5 

5 ........................................................................................................................................................................... 589.2 258.9 

6 ........................................................................................................................................................................... 676.5 296.3 

Note: Present value of NOX emissions calculated with at $2,639 per ton. 

The NPV of the monetized benefits 

associated with emissions reductions 

can be viewed as a complement to the 

NPV of the consumer savings calculated 

for each TSL considered in this NOPR. 

Table V–50 presents the NPV values 

that result from adding the estimates of 

the potential economic benefits 

resulting from reduced CO2 and NOX

emissions in each of four valuation 

scenarios to the NPV of consumer 

savings calculated for each TSL 

considered in this rulemaking, at both a 

7-percent and a 3-percent discount rate. 

The CO2 values used in the columns of 

each table correspond to the four 

scenarios for the valuation of CO2

emission reductions discussed above. 

TABLE V–50—WICF TSLS: NET PRESENT VALUE OF CONSUMER SAVINGS COMBINED WITH NET PRESENT VALUE OF

MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS

TSL 

Consumer NPV at 3% discount rate added with: 

SCC Value of $12.9/ 

metric ton CO2* and low 

value for NOX** 

SCC Value of $40.8/ 

metric ton CO2* and 

medium value for NOX** 

SCC Value of $62.2/ 

metric ton CO2* and 

medium value for NOX** 

SCC Value of $117.0/ 

metric ton CO2* and 

high value for NOX** 

billion 2012$ 

1 ....................................................... 23.03 29.29 33.79 45.11 

2 ....................................................... 22.83 29.30 33.94 45.65 

3 ....................................................... 22.28 28.87 33.60 45.50 

4 ....................................................... 26.28 33.80 39.21 52.82 

5 ....................................................... 25.45 33.46 39.22 53.72 

6 ....................................................... ¥44.22 ¥35.01 ¥28.39 ¥11.73 

TSL 

Consumer NPV at 7% discount rate added with: 

SCC Value of $12.9/ 

metric ton CO2* and low 

value for NOX** 

SCC Value of $40.8/ 

metric ton CO2* and 

medium value for NOX** 

SCC Value of $62.2/ 

metric ton CO2* and 

medium value for NOX** 

SCC Value of $117.0/ 

metric ton CO2* and 

high value for NOX** 

billion 2012$ 

1 ....................................................... 9.36 15.41 19.91 31.02 

2 ....................................................... 9.30 15.55 20.19 31.68 

3 ....................................................... 8.80 15.16 19.89 31.58 

4 ....................................................... 10.57 17.84 23.24 36.60 

5 ....................................................... 9.91 17.66 23.41 37.64 

6 ....................................................... ¥26.86 ¥17.96 ¥11.34 5.01 

Note: Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per ton of NOX emissions. High Value 

corresponds to $4,809 per ton of NOX emissions. 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 55871 

* These label values represent the global SCC in 2015, in 2012$. The present values have been calculated with scenario-consistent discount 

rates. 

Although adding the value of 

consumer savings to the values of 

emission reductions provides a valuable 

perspective, the following should be 

considered: (1) The national consumer 

savings are domestic U.S. consumer 

monetary savings found in market 

transactions, while the values of 

emissions reductions are based on 

estimates of marginal social costs, 

which, in the case of CO2, are based on 

a global value; and (2) the assessments 

of consumer savings and emissionrelated benefits are performed with 

different computer models, leading to 

different timeframes for analysis. For 

walk-ins, the present value of national 

consumer savings is measured for the 

period in which units shipped (2017– 

2046) continue to operate. However, the 

time frames of the benefits associated 

with the emission reductions differ. For 

example, the value of CO2 emissions 

reductions reflects the present value of 

all future climate-related impacts due to 

emitting a ton of CO2 in that year, out 

to 2300. 

Chapter 15 of the NOPR TSD presents 

calculations of the combined NPV, 

including benefits from emissions 

reductions for each TSL. 

7. Other Factors 

Consistent with EPCA, DOE examined 

whether other factors might be relevant 

in determining whether the proposed 

standards are economically justified. 

See generally 42 U.S.C. 

6295(o)(2)(B)(i)(VII). DOE identified 

none other than those discussed above. 

DOE prepared a regulatory impact 

analysis (RIA) for this rulemaking, 

which is contained in the TSD. The RIA 

is subject to review by the Office of 

Information and Regulatory Affairs 

(OIRA) in the OMB. The RIA consists of 

(1) a statement of the problem addressed 

by this regulation and the mandate for 

Government action, (2) a description 

and analysis of policy alternatives to 

this regulation, (3) a quantitative review 

of the potential impacts of the 

alternatives, and (4) the national 

economic impacts of the proposed 

standard. 

The RIA assesses the effects of 

feasible policy alternatives to walk-in 

equipment standards and provides a 

comparison of the impacts of the 

alternatives. DOE evaluated the 

alternatives in terms of their ability to 

achieve significant energy savings at 

reasonable cost, and compared them to 

the effectiveness of the proposed rule. 

DOE analyzed these alternatives with 

reference to the particular market 

dynamics of the WICF industry. 

DOE identified the following major 

policy alternatives for achieving 

increased WICF efficiency: 

• No new regulatory action 

• Commercial consumer tax credits 

• Commercial consumer rebates 

• Voluntary energy efficiency targets 

• Bulk government purchases 

• Early replacement 

DOE qualitatively evaluated each 

alternative’s ability to achieve 

significant energy savings at reasonable 

cost and compared it to the effectiveness 

of the proposed rule. DOE assumed that 

each alternative policy would induce 

commercial consumers to voluntarily 

purchase at least some higher efficient 

at any of the trial standard levels (TSLs). 

In contrast to a standard at one of the 

TSLs, the adoption rate of the 

alternative non-regulatory policy cases 

may not be 100 percent, which would 

result in lower energy savings than a 

standard. The following paragraphs 

discuss each policy alternative. (See 

chapter 17 of the TSD, Regulatory 

Impact Analysis, for further details.) 

No new regulatory action. The case in 

which no regulatory action is taken for 

WICF equipment constitutes the base 

case (or no action) scenario. By 

definition, no new regulatory action 

yields zero energy savings and a net 

present value of zero dollars. 

Commercial consumer tax credits. 

Consumer tax credits are considered a 

viable non-regulatory market 

transformation program. From a 

consumer perspective, the most 

important difference between rebate and 

tax credit programs is that a rebate can 

be obtained quickly, whereas receipt of 

tax credits is delayed until income taxes 

are filed or a tax refund is provided by 

the Internal Revenue Service (IRS). 

From a societal perspective, tax credits 

(like rebates) do not change the installed 

cost of the equipment, but rather 

transfer a portion of the cost from the 

consumer to taxpayers as a whole. DOE, 

therefore, assumed that equipment costs 

in the consumer tax credits scenario 

were identical to the NIA base case. 

Commercial consumer rebates. 

Consumer rebates cover a portion of the 

difference in incremental product price 

between products meeting baseline 

efficiency levels and those meeting 

higher efficiency levels, resulting in a 

higher percentage of consumers 

purchasing more efficient models and 

decreased aggregated energy use 

compared to the base case. Although a 

rebate program would reduce the total 

installed cost to the consumer, it is 

financed by tax revenues. Therefore, 

from a societal perspective, the installed 

cost at any efficiency level does not 

change with the rebate program; rather, 

part of the cost is transferred from the 

consumer to taxpayers as a whole. 

Consequently, DOE assumed that 

equipment costs in the rebates scenario 

were identical to the NIA base case. 

Voluntary energy efficiency targets. 

While it is possible that voluntary 

programs for equipment would be 

effective, DOE lacks a quantitative basis 

to determine how effective such a 

program might be. As noted previously, 

broader economic and social 

considerations are in play than simple 

economic return to the equipment 

purchaser. DOE lacks the data necessary 

to quantitatively project the degree to 

which such voluntary programs for 

more expensive, higher efficiency 

equipment would modify the market. 

Bulk Government purchases and early 

replacement incentive programs. DOE 

also considered, but did not analyze, the 

potential of bulk Government purchases 

and early replacement incentive 

programs as alternatives to the proposed 

standards. Bulk purchases would have 

very limited impact on improving the 

overall market efficiency of WICF 

equipment because they are a negligible 

part of the total. In the case of 

replacement incentives, several policy 

options exist to promote early 

replacement, including a direct national 

program of consumer incentives, 

incentives paid to utilities to promote 

an early replacement program, market 

promotions through equipment 

manufacturers, and replacement of 

government-owned equipment. In 

considering early replacements, DOE 

estimates that the energy savings 

realized through a one-time early 

replacement of existing stock equipment 

does not result in energy savings 

commensurate to the cost to administer 

the program. Consequently, DOE did not 

analyze this option in detail. 

C. Proposed Standard 

‘‘When considering proposed 

standards, the new or amended energy 

conservation standard that DOE adopts 

for any type (or class) of walk-in coolers 

and freezers shall be designed to 

achieve the maximum improvement in 

energy efficiency that the Secretary of 

Energy determines is technologically 

feasible and economically justified. (42 

U.S.C. 6313(f)(4)(A)) In determining 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55872 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

whether a standard is economically 

justified, the Secretary must determine 

whether the benefits of the standard 

exceed its burdens to the greatest extent 

practicable, considering the seven 

statutory factors discussed previously. 

(42 U.S.C. 6295(o)(2)(B)(i) and 6316(a)) 

The new or amended standard must also 

‘‘result in significant conservation of 

energy.’’ (42 U.S.C. 6295(o)(3)(B) and 

6316(a)) 

DOE considered the impacts of 

standards at each TSL, beginning with 

the maximum technologically feasible 

level, to determine whether that level 

met the evaluation criteria. If the max 

tech level was not justified, DOE then 

considered the next most efficient level 

and undertook the same evaluation until 

it reached the highest efficiency level 

that is both technologically feasible and 

economically justified and saves a 

significant amount of energy. 

DOE discusses the benefits and/or 

burdens of each TSL in the remainder 

of this section. DOE bases its discussion 

of each TSL on quantitative analytical 

results such as national energy savings, 

net present value (discounted at 3 and 

7 percent), emissions reductions, 

industry net present value, life-cycle 

cost, and consumers’ installed price 

increases. Beyond the quantitative 

results, DOE also considers other 

burdens and benefits that affect 

economic justification, including how 

technological feasibility, manufacturer 

costs, and impacts on competition may 

affect the economic results presented. 

DOE has included a table below that 

presents a summary of the results of 

DOE’s quantitative analysis for each 

TSL. In addition to the quantitative 

results presented in the tables, DOE also 

considers other burdens and benefits 

that affect economic justification. 

Section V.B presents the estimated 

impacts of each TSL on commercial 

customers and manufacturers, and 

subgroups thereof, as well as the Nation. 

TABLE V–51—SUMMARY OF RESULTS FOR WICF REFRIGERATION SYSTEMS AND ENVELOPE COMPONENTS, TSLS 1–6 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

National Full-Fuel Cycle Energy Savings (quads) 

Total-All .................................................... 4.49 4.61 4.73 5.39 5.74 6.61 

NPV of Consumer Benefits (2012$ billion) 

3% discount rate ...................................... 21.4 21.1 20.6 24.3 23.3 ¥46.6 

7% discount rate ...................................... 7.8 7.6 7.1 8.6 7.9 ¥29.2 

Industry Impacts 

Change in Industry NPV (2012$ million) ¥60 to ¥1 ¥44 to 11 ¥108 to ¥23 ¥77 to 0 ¥134 to ¥19 ¥657 to 924 

Change in Industry NPV (%) ................... ¥7 to 0 ¥5 to 1 ¥13 to ¥3 ¥9 to 0 ¥16 to ¥2 ¥77 to 109 

Cumulative Emissions Reduction 

CO2 (MMt) ................................................ 248.2 255.2 261.4 298.0 317.5 365.5 

NOX (kt) ................................................... 369.9 379.6 389.6 443.8 473.0 544.8 

Hg (t) ........................................................ 0.5 0.5 0.6 0.6 0.7 0.8 

SO2 (kt) .................................................... 316.0 325.1 332.7 379.5 404.3 465.3 

N2O (kt) .................................................... 5.4 5.5 5.7 6.4 6.9 7.90 

N2O (kt CO2 eq)@ .................................... 1,600.0 1,634.5 1,687.2 1,917.5 2,044.5 2,357.9 

CH4 (kt) .................................................... 1,188.84 1,222.70 1,251.90 1,427.56 1,521.10 1,750.57 

CH4 (kt CO2 eq)@ .................................... 29,720.25 30,566.82 31,296.66 35,688.0 38,026.65 43,763.14 

Value of Cumulative Emissions Reduction * 

CO2 (2012$ billion) * ................................ 1.56 to 22.89 1.62 to 23.65 1.64 to 24.07 1.88 to 27.52 2.00 to 29.31 2.41 to 33.68 

NOX—3% discount rate (2012$ million) .. 460 477 483 553 589 676 

NOX—7% discount rate (2012$ million) .. 202 211 211 243 259 296 

LCC Savings (2012$)** 

Refrigeration Systems 

DC.M.I *** ................................................. 280 611 280 611 611 611 

DC.M.O *** ............................................... 1,048 1,577 1,117 1,509 1,608 1,608 

DC.L.I *** .................................................. 505 1,117 505 1,117 1,080 1,080 

DC.L.O *** ................................................ 1,328 2,001 1,328 2,001 1,994 1,994 

MC.M ........................................................ 1,715 1,724 1,715 1,724 1,715 1,715 

MC.L ......................................................... 1,849 2,061 1,849 2,061 1,849 1,849 

Envelope Components 

SP.M ........................................................ 16 0 ¥9 8 ¥22 ¥2,139 

SP.L ......................................................... 122 0 ¥66 72 ¥140 ¥1,890 

FP.L .......................................................... 66 0 ¥4 30 ¥65 ¥1,653 

DD.M ........................................................ 239 228 239 228 222 ¥2,650 

DD.L ......................................................... 217 200 ¥12 200 198 ¥1,717 

PD.M ........................................................ 2 0 2 0 0 ¥884 

PD.L ......................................................... 74 0 ¥16 52 ¥52 ¥665 

FD.M ........................................................ 3 0 3 1 0 ¥1,157 


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TABLE V–51—SUMMARY OF RESULTS FOR WICF REFRIGERATION SYSTEMS AND ENVELOPE COMPONENTS, TSLS 1–6— 

Continued 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

FD.L ......................................................... 152 0 28 136 ¥32 ¥1,337 

PBP (years) †

Refrigeration Systems 

DC.M.I *** ................................................. 3.2 4.4 3.2 4.4 4.4 4.4 

DC.M.O *** ............................................... 1.3 2.5 1.8 2.0 3.0 3.0 

DC.L.I *** .................................................. 2.8 2.7 2.8 2.7 3.1 3.1 

DC.L.O *** ................................................ 1.2 2.3 1.2 2.3 2.8 2.8 

MC.M ........................................................ 0.6 0.5 0.6 0.5 0.6 0.6 

MC.L ......................................................... 2.5 0.4 2.5 0.4 2.5 2.5 

Envelope Components 

SP.M ........................................................ 3.8 N/A 6.8 4.5 9.0 146.4 

SP.L ......................................................... 2.9 N/A 7.4 3.6 10.0 43.0 

FP.L .......................................................... 3.5 N/A 6.0 4.5 8.0 48.7 

DD.M ........................................................ 2.1 2.2 2.1 2.2 2.2 37.6 

DD.L ......................................................... N/A N/A 6.0 N/A N/A 18.5 

PD.M ........................................................ 4.5 N/A 4.5 5.5 6.0 78.7 

PD.L ......................................................... 4.3 N/A 6.2 4.7 7.0 18.3 

FD.M ........................................................ 4.5 N/A 4.5 5.4 5.9 81.5 

FD.L ......................................................... 3.8 N/A 5.8 2.9 6.5 21.7 

Distribution of Consumer LCC Impacts 

All Medium and Low Temperature Refrigeration Systems 

Net Cost (%) ..................................... 0 0 0 0 1 1 

No Impact (%) ................................... 0 0 0 0 0 0 

Net Benefit (%) ................................. 100 100 100 100 99 99 

All Medium and Low Temperature Panels 

Net Cost (%) ..................................... 11 0 76 28 93 100 

No Impact (%) ................................... 0 100 0 0 0 0 

Net Benefit (%) ................................. 89 0 24 72 7 0 

All Medium and Low Temperature Display Doors 

Net Cost (%) ..................................... 0 0 4 0 0 100 

No Impact (%) ................................... 0 0 0 0 0 0 

Net Benefit (%) ................................. 100 100 96 100 100 0 

All Medium and Low Temperature Passage Doors 

Net Cost (%) ..................................... 23 0 39 45 67 100 

No Impact (%) ................................... 0 100 0 0 0 0 

Net Benefit (%) ................................. 77 0 61 55 33 0 

All Medium and Low Temperature Freight Doors 

Net Cost (%) ..................................... 16 0 39 28 65 100 

No Impact (%) ................................... 0 100 0 0 0 0 

Net Benefit (%) ................................. 84 0 61 72 35 0 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. 

** For LCCs, DOE did not consider variability of input parameters and used fixed input values. For the panels the unit of analysis is 100 ft2, for 

other items it is a single unit of a refrigeration system or a door. 

*** For DC refrigeration systems, results include both capacity ranges. 

†For PBPs, DOE did not consider variability of input parameters and used fixed input values. 

@ CO2eq is the quantity of CO2 that would have the same global warming potential (GWP). 

DOE also notes that the economics 

literature provides a wide-ranging 

discussion of how consumers trade off 

upfront costs and energy savings in the 

absence of government intervention. 

Much of this literature attempts to 

explain why consumers appear to 

undervalue energy efficiency 

improvements. This undervaluation 

suggests that regulation that promotes 

energy efficiency can produce 

significant net private gains (as well as 

producing social gains by, for example, 

reducing pollution). There is evidence 

that consumers undervalue future 

energy savings as a result of (1) a lack 

of information, (2) a lack of sufficient 

salience of the long-term or aggregate 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55874 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

35Alan Sanstad, Notes on the Economics of 

Household Energy Consumption and Technology 

Choice. Lawrence Berkeley National Laboratory. 

2010. http://www1.eere.energy.gov/buildings/

appliance_standards/pdfs/consumer_ee_theory.pdf 

benefits, (3) a lack of sufficient savings 

to warrant accelerating or altering 

investments in energy saving 

equipment, (4) excessive focus on the 

short term, in the form of inconsistent 

weighing of future energy cost savings 

relative to available returns on other 

investments; (5) computational or other 

difficulties associated with the 

evaluation of relevant tradeoffs; and (6) 

a divergence in incentives (e.g., renter 

versus building owner; builder versus 

home buyer). Other literature indicates 

that with less than perfect foresight and 

a high degree of uncertainty about the 

future, it may be rational for consumers 

to trade off these types of investments 

at a higher than expected rate between 

current consumption and uncertain 

future energy cost savings. Some studies 

suggest that this seeming 

undervaluation may be explained in 

certain circumstances by differences 

between tested and actual energy 

savings, or by uncertainty and 

irreversibility of energy investments. 

There may also be ‘‘hidden’’ welfare 

losses to customers if newer energy 

efficient equipment is an imperfect 

substitute for the less efficient 

equipment it replaces. In the abstract, it 

may be difficult to say how a welfare 

gain from correcting potential underinvestment in energy conservation 

compares in magnitude to the potential 

welfare losses associated with no longer 

purchasing equipment or switching to 

an imperfect substitute, both of which 

still exist in this framework. 

While DOE is not prepared at present 

to provide a fully quantifiable 

framework for estimating the benefits 

and costs of changes in consumer 

purchase decisions due to an energy 

conservation standard, DOE has posted 

a paper that discusses the issue of 

consumer welfare impacts of appliance 

energy efficiency standards, and 

potential enhancements to the 

methodology by which these impacts 

are defined and estimated in the 

regulatory process.35 DOE is committed 

to developing a framework that can 

support empirical quantitative tools for 

improved assessment of the consumer 

welfare impacts of appliance standards. 

DOE welcomes comments on how to 

more fully assess the potential impact of 

energy conservation standards on 

consumer choice and how to quantify 

this impact in its regulatory analysis in 

future rulemakings. In particular, DOE 

requests comment on whether there are 

features or attributes of the more energy 

efficient walk-in coolers and walk-in 

freezers that manufacturers would 

produce to meet the standards in this 

proposed rule that might affect the 

welfare, positively or negatively, of 

consumers who purchase WICFs. 

First, DOE considered TSL 6, the max 

tech level for WICF refrigeration 

systems and the covered envelope 

components combined together. TSL 6 

would save an estimated 6.61 quads of 

energy through 2073, an amount DOE 

considers significant. For the Nation as 

a whole, DOE projects that TSL 6 would 

have a negative NPV for consumers, i.e., 

result in increased costs of $29.2 billion, 

using a discount rate of 7 percent. The 

emissions reductions at TSL 6 are 365.5 

MMt of CO2, up to 545 kt of NOX, 465 

kt of SO2, and up to 0.8 tons of Hg. 

These reductions are valued from $2.41 

to $33.68 billion for CO2. For NOX the 

emissions reductions are valued at $296 

million at a discount rate of 7 percent. 

At TSL 6, DOE projects that 

consumers of WICF envelope 

components will experience an increase 

in LCC, ranging from $665 (low 

temperature passage door) to $2,650 

(medium temperature display door) 

compared to the baseline. For 

refrigeration systems, however, DOE 

estimates that consumers would 

experience a decrease in LCC ranging 

from $611 to $1,994. 

At TSL 6, manufacturers expect 

diminished profitability due to large 

increases in product costs, capital 

investments in equipment and tooling, 

and expenditures related to engineering 

and testing. The projected change in 

INPV ranges from a decrease of $657 

million to an increase of $924 million 

based on DOE’s manufacturer mark-up 

scenarios. The upper bound of $924 

million is considered an optimistic 

scenario by manufacturers because it 

assumes manufacturers can fully pass 

on substantial increases in product 

costs. DOE recognizes the risk of large 

negative impacts on industry if 

manufacturers’ expectations concerning 

reduced profit margins are realized. TSL 

6 could reduce the walk-in refrigeration, 

panel, and door INPV by up to 77 

percent, if the most negative impacts are 

realized. 

After carefully considering the 

analysis and weighing the benefits and 

burdens of TSL 6, DOE finds that the 

benefits to the Nation of TSL 6 (i.e., 

energy savings and emissions 

reductions (including environmental 

and monetary benefits)) are small 

compared to the burdens (i.e., a 

decrease of $29.2 billion in NPV and a 

decrease of 77 percent in INPV). 

Because the burdens of TSL 6 far 

outweigh the benefits, TSL 6 is not 

economically justified. Therefore, DOE 

is not proposing to adopt TSL 6. 

DOE then considered TSL 5, which 

combines refrigeration systems and 

envelope components at the highest 

efficiency level for each that would 

generate positive NPV to the Nation. 

TSL 5 would likely save an estimated 

5.74 quads of energy through 2073, an 

amount DOE considers significant. For 

the Nation as a whole, DOE projects that 

TSL 5 would result in a net increase of 

$7.9 billion in NPV, using a discount 

rate of 7 percent. The estimated 

emissions reductions at TSL 5 are 317.5 

MMt of CO2, up to 473 kt of NOX, 404 

kt of SO2, and up to 0.7 tons of Hg. 

These reductions are valued from $2.00 

to $29.31 billion for CO2. For NOX the 

emissions reductions are valued at $259 

million at a discount rate of 7 percent. 

At TSL 5, DOE projects that the 

customers of WICF equipment will 

experience an increase in LCC for 

panels and low temperature passage and 

freight doors and either unchanged or 

decreased LCC for display doors and 

medium temperature passage and 

freight doors. For the refrigeration 

systems, DOE estimates that the 

consumers would experience a decrease 

in LCC ranging from $611 to $1,994. 

At TSL 5, the projected change in 

INPV ranges from a decrease of $134 

million to a decrease of $19 million. At 

TSL 5, DOE recognizes the risk of 

negative impacts if manufacturers’ 

expectations concerning reduced profit 

margins are realized. If the negative end 

of the range of impacts is reached as 

DOE expects, TSL 5 could result in a net 

loss of 16 percent in INPV to the walkin cooler and freezer industry. 

Additionally, DOE is concerned about 

TSL 5 causing disproportionate burdens 

on small business panel manufacturers, 

as explained in the Regulatory 

Flexibility analysis in section VI.B.4. 

After carefully considering the 

analysis and weighing the benefits and 

burdens of TSL 5, DOE finds that the 

benefits to the Nation at TSL 5 (i.e., 

energy savings and emissions 

reductions (including environmental 

and monetary benefits)) are too low 

compared to the burdens (i.e., a 

decrease of 16 percent in INPV for the 

walk-in cooler and freezer industry with 

disproportionate impacts on the panel 

industry). Because the burdens of TSL 5 

outweigh the benefits, TSL 5 is not 

economically justified. Therefore, DOE 

is not proposing TSL 5. 

Next, DOE considered TSL 4, which 

combines the refrigeration systems at 

the maximum NPV level with the 

envelope components also at the 

maximum NPV level. TSL 4 would 


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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 55875 

likely save an estimated 5.39 quads of 

energy through 2073, an amount DOE 

considers significant. For the Nation as 

a whole, DOE projects that TSL 4 would 

result in a net increase of $8.6 billion in 

NPV, using a discount rate of 7 percent. 

The estimated emissions reductions at 

TSL 4 are 298 MMt of CO2, up to 444 

kt of NOX, 379.5 kt of SO2, and up to 

0.6 tons of Hg. These reductions are 

valued from $1.88 to $27.52 billion for 

CO2. For NOX the emissions savings are 

valued at $243 million at a discount rate 

of 7 percent. 

At TSL 4, DOE projects that 

consumers of WICF equipment will 

experience a decrease of LCC for all 

equipment classes. At TSL 4, the 

projected change in INPV ranges from a 

decrease of $77 million to an increase of 

$0.01 million. At TSL 4, DOE recognizes 

the risk of negative impacts if 

manufacturers’ expectations concerning 

reduced profit margins are realized. If 

the negative end of the range of impacts 

is reached as DOE expects, TSL 4 could 

result in a net loss of 9 percent of INPV 

to walk-in manufacturers. 

After carefully considering the 

analysis and weighing the benefits and 

burdens of TSL 4, DOE tentatively 

believes that setting levels for both the 

refrigeration system and envelope 

components at TSL 4 represents the 

maximum improvement in energy 

efficiency that DOE’s analysis projects 

to be technologically feasible and 

economically justified. TSL 4 is 

technologically feasible because the 

technologies required to achieve these 

levels are already in existence. TSL 4 is 

economically justified because the 

benefits to the Nation (i.e., increased 

energy savings of 5.39 quads, emissions 

reductions including environmental and 

monetary benefits of, for example, 298 

MMt of carbon dioxide emissions 

reduction with an associated value of up 

to $27.52 billion at a discount rate of 3 

percent, and an increase of $8.6 billion 

in NPV) outweigh the costs (i.e., a 

decrease of 9 percent in INPV). 

Therefore, DOE has tentatively 

decided to propose the adoption of 

energy conservation standards at TSL 4 

for WICF refrigeration systems and the 

considered envelope components. DOE 

may re-examine this level depending on 

the nature of the information it receives 

during the comment period and make 

adjustments to its final levels in 

response to that information. 

VI. Procedural Issues and Regulatory 

Review 

A. Review Under Executive Orders 

12866 and 13563 

Section 1(b)(1) of Executive Order 

12866, ‘‘Regulatory Planning and 

Review,’’ 58 FR 51735 (Oct. 4, 1993), 

requires each agency to identify the 

problem that it intends to address, 

including, where applicable, the failures 

of private markets or public institutions 

that warrant new agency action, as well 

as to assess the significance of that 

problem. The problems that today’s 

standards address are as follows: 

(1) There is a lack of consumer 

information and/or information 

processing capability about energy 

efficiency opportunities in the walk-in 

cooler and freezer market. 

(2) There is asymmetric information 

(one party to a transaction has more and 

better information than the other) and/ 

or high transactions costs (costs of 

gathering information and effecting 

exchanges of goods and services). 

(3) There are external benefits 

resulting from improved energy 

efficiency of walk-in coolers and 

freezers that are not captured by the 

users of such equipment. These benefits 

include externalities related to 

environmental protection that are not 

reflected in energy prices, such as 

reduced emissions of greenhouse gases. 

In addition, DOE has determined that 

today’s regulatory action is an 

‘‘economically significant regulatory 

action’’ under section 3(f)(1) of 

Executive Order 12866. Accordingly, 

section 6(a)(3) of the Executive Order 

requires that DOE prepare a regulatory 

impact analysis (RIA) on today’s rule 

and that the Office of Information and 

Regulatory Affairs (OIRA) in the Office 

of Management and Budget (OMB) 

review this rule. DOE presented to OIRA 

for review the proposed rule and other 

documents prepared for this 

rulemaking, including the RIA, and has 

included these documents in the 

rulemaking record. The assessments 

prepared pursuant to Executive Order 

12866 can be found in the technical 

support document for this rulemaking. 

DOE has also reviewed this proposed 

regulation pursuant to Executive Order 

13563, issued on January 18, 2011 (76 

FR 3281, Jan. 21, 2011). EO 13563 is 

supplemental to and explicitly reaffirms 

the principles, structures, and 

definitions governing regulatory review 

established in Executive Order 12866. 

To the extent permitted by law, agencies 

are required by Executive Order 13563 

to: (1) Propose or adopt a regulation 

only upon a reasoned determination 

that its benefits justify its costs 

(recognizing that some benefits and 

costs are difficult to quantify); (2) tailor 

regulations to impose the least burden 

on society, consistent with obtaining 

regulatory objectives, taking into 

account, among other things, and to the 

extent practicable, the costs of 

cumulative regulations; (3) select, in 

choosing among alternative regulatory 

approaches, those approaches that 

maximize net benefits (including 

potential economic, environmental, 

public health and safety, and other 

advantages; distributive impacts; and 

equity); (4) to the extent feasible, specify 

performance objectives, rather than 

specifying the behavior or manner of 

compliance that regulated entities must 

adopt; and (5) identify and assess 

available alternatives to direct 

regulation, including providing 

economic incentives to encourage the 

desired behavior, such as user fees or 

marketable permits, or providing 

information upon which choices can be 

made by the public. 

DOE emphasizes as well that 

Executive Order 13563 requires agencies 

to use the best available techniques to 

quantify anticipated present and future 

benefits and costs as accurately as 

possible. In its guidance, the Office of 

Information and Regulatory Affairs has 

emphasized that such techniques may 

include identifying changing future 

compliance costs that might result from 

technological innovation or anticipated 

behavioral changes. For the reasons 

stated in the preamble, DOE believes 

that today’s NOPR is consistent with 

these principles, including the 

requirement that, to the extent 

permitted by law, benefits justify costs 

and that net benefits are maximized. 

B. Review Under the Regulatory 

Flexibility Act 

The Regulatory Flexibility Act (5 

U.S.C. 601 et seq.) requires preparation 

of an initial regulatory flexibility 

analysis (IRFA) for any rule that by law 

must be proposed for public comment, 

unless the agency certifies that the rule, 

if promulgated, will not have a 

significant economic impact on a 

substantial number of small entities. As 

required by Executive Order 13272, 

‘‘Proper Consideration of Small Entities 

in Agency Rulemaking,’’ 67 FR 53461 

(August. 16, 2002), DOE published 

procedures and policies on February 19, 

2003 to ensure that the potential 

impacts of its rules on small entities are 

properly considered during the 

rulemaking process. 68 FR 7990. DOE 

has made its procedures and policies 

available on the Office of the General 

Counsel’s Web site (http://energy.gov/

gc/office-general-counsel). 


tkelley on DSK3SPTVN1PROD with PROPOSALS2
55876 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

For manufacturers of walk-in coolers 

and freezers, the Small Business 

Administration (SBA) has set a size 

threshold, which defines those entities 

classified as ‘‘small businesses’’ for the 

purposes of the statute. DOE used the 

SBA’s small business size standards to 

determine whether any small entities 

would be subject to the requirements of 

the rule. 65 FR 30836, 30848 (May 15, 

2000), as amended at 65 FR 53533, 

53544 (Sept. 5, 2000) and codified at 13 

CFR part 121.The size standards are 

listed by North American Industry 

Classification System (NAICS) code and 

industry description and are available at 

http://www.sba.gov/idc/groups/public/

documents/sba_homepage/serv_sstd_

tablepdf.pdf. Walk-in cooler and freezer 

manufacturing is classified under 

NAICS 333415, ‘‘Air-Conditioning and 

Warm Air Heating Equipment and 

Commercial and Industrial Refrigeration 

Equipment Manufacturing.’’ The SBA 

sets a threshold of 750 employees or 

fewer for an entity to be considered as 

a small business for this category. 

DOE determined that it could not 

certify that the proposed rule, if 

promulgated, would not have a 

significant effect on a substantial 

number of small entities that 

manufacture WICF panels and doors. 

Therefore, DOE has prepared an IRFA 

(sections VI.B.1 through VI.B.6 below) 

for this rulemaking. The IRFA describes 

potential impacts on small businesses 

associated with walk-in cooler and 

freezer energy conservation standards. 

1. Reasons for the Proposed Rule 

Title III of the Energy Policy and 

Conservation Act of 1975, as amended, 

(EPCA or the Act) sets forth a variety of 

provisions designed to improve energy 

efficiency. Part B of Title III (42 U.S.C. 

6291–6309) provides for the Energy 

Conservation Program for Consumer 

Products Other Than Automobiles. The 

National Energy Conservation Policy 

Act (NECPA), Public Law 95–619, 

amended EPCA to add Part C of Title III, 

which established an energy 

conservation program for certain 

industrial equipment. (42 U.S.C. 6311– 

6317) (For purposes of codification in 

Title 42 of the U.S. Code, these parts 

were subsequently redesignated as Parts 

A and A–1, respectively, for editorial 

reasons.) Section 312 of the Energy 

Independence and Security Act of 2007 

(EISA 2007) further amended EPCA by 

adding certain equipment to this energy 

conservation program, including walkin coolers and walk-in freezers 

(collectively ‘‘walk-in equipment’’ or 

‘‘walk-ins’’), which are the subject of 

this rulemaking. (42 U.S.C. 6311(1), 

(20), 6313(f) and 6314(a)(9)) The 

proposed rule would establish energy 

conservation standards for walk-in 

coolers and walk-in freezers. 

2. Objectives of, and Legal Basis for, the 

Proposed Rule 

EPCA provides that DOE must 

publish performance-based standards 

for walk-in coolers and walk-in freezers 

that achieve the maximum improvement 

in energy that is technologically feasible 

and economically justified. (42 U.S.C. 

6313(f)(4)(A)) However, in general, DOE 

may not adopt any standard that would 

not result in the significant conservation 

of energy. (42 U.S.C. 6295(o)(3)) 

(Regarding provisions contained only in 

the consumer products section of the 

U.S. Code, DOE is proposing to apply 

those provisions to walk-in coolers and 

walk-in freezers in the same manner.) 

Moreover, DOE may not prescribe a 

standard: (1) For certain products, 

including walk-in coolers and freezers, 

if no test procedure has been established 

for the product; or (2) if DOE determines 

by rule that the proposed standard is not 

technologically feasible or economically 

justified. (42 U.S.C. 6295(o)(3)(A)–(B)) 

In deciding whether a proposed 

standard is economically justified, DOE 

must determine whether the benefits of 

the standard exceed its burdens after 

receiving comments on the proposed 

standard. (42 U.S.C. 6295(o)(2)(B)(i)) To 

determine whether economic 

justification exists, DOE reviews 

comments received and conducts 

analysis to determine whether DOE 

must make this determination, and by 

considering, to the greatest extent 

practicable, the seven factors set forth in 

42 U.S.C.6295(o)(2)(B) (see section II of 

this preamble). 

EPCA also states that the Secretary 

may not prescribe a standard if 

interested persons have established by a 

preponderance of the evidence that the 

standard is likely to result in the 

unavailability in the United States of 

any covered product type (or class) of 

performance characteristics (including 

reliability), features, sizes, capacities, 

and volumes that are substantially the 

same as those generally available in the 

United States. (42 U.S.C. 6295(o)(4)) 

Further information concerning the 

background of this rulemaking is 

provided in chapter 1 of the TSD. 

3. Description and Estimated Number of 

Small Entities Regulated 

DOE used available public 

information and information from 

confidential interviews to identify 

potential small manufacturers. DOE’s 

research involved industry trade 

association membership directories 

(including AHRI and NAFEM), the NSF 

Section 7 certification database, 

individual company Web sites, and 

marketing research tools (e.g., Dun and 

Bradstreet reports) to create a list of 

companies that manufacture or sell 

walk-in cooler or freezer panels, doors, 

and refrigeration systems covered by 

this rulemaking. DOE also asked 

stakeholders and industry 

representatives if they were aware of 

any other small manufacturers during 

manufacturer interviews and at previous 

DOE public meetings. DOE reviewed the 

publicly available data and contacted 

select companies on its list, as 

necessary, to determine whether they 

met the SBA’s definition of a small 

business manufacturer of WICF 

equipment. DOE screened out 

companies that did not offer products 

covered by this rulemaking, did not 

meet the definition of a ‘‘small 

business,’’ or are foreign owned and 

operated. 

Based on this information, DOE 

identified 52 panel manufacturers and 

found 42 of the identified panel 

manufacturers to be small businesses. 

As part of the MIA interviews, the 

Department interviewed nine panel 

manufacturers, including three small 

business operations. During MIA 

interviews, multiple manufacturers 

claimed that there are ‘‘hundreds of 

two-man garage-based operations’’ that 

produce WICF panels in small 

quantities. They asserted that these 

small manufacturers do not typically 

comply with EISA 2007 standards and 

do not obtain UL or NSF certifications 

for their equipment. DOE was not able 

to identify these small businesses and 

did not consider them in its analysis. 

Based on the purported number of small 

panel manufacturers and the potential 

scope of the impact (as described in 

section VI.B.4 below), DOE could not 

certify that the proposed standards 

would not have a significant impact on 

a substantial number of small 

businesses with respect to the panel 

industry. 

DOE identified 59 walk-in door 

manufacturers. Fifty-five of those 

produce solid doors and four produce 

display doors. Of the fifty-five solid 

door manufacturers, fifty-two produce 

panels as their primary business and are 

considered in the category of panel 

manufacturers above. The remaining 

three solid door manufacturers are all 

considered to be small businesses. Of 

the four display door manufacturers, 

two are considered small businesses. 

Therefore, of the seven manufacturers 

that exclusively produce WICF doors 

(three producing solid doors and four 

producing display doors), DOE 

determined that five are small 


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businesses. As part of the MIA 

interviews, the Department interviewed 

six door manufacturers, including four 

small business operations. Based on the 

large proportion of small door 

manufacturers in the door market and 

the potential scope of the impact (as 

described in section VI.B.4 below), DOE 

could not certify that the proposed 

standards would not have a significant 

impact on a large number of small 

businesses with respect to the door 

industry. 

DOE identified nine refrigeration 

system manufacturers in the WICF 

industry. Based on publicly available 

information, two of the manufacturers 

are small businesses. One small 

business focuses on large warehouse 

refrigeration systems, which are outside 

the scope of this rulemaking. However, 

at its smallest capacity, this company’s 

units can be sold to the walk-in market. 

The other small business specializes in 

building evaporators and unit coolers 

for a range of refrigeration applications, 

including the walk-in market. As part of 

the MIA interviews, the Department 

interviewed five refrigeration 

manufacturers, including the two small 

business operations. Both small 

businesses expressed concern that the 

rulemaking would negatively impact 

their businesses and one small business 

indicated it would exit the walk-in 

industry as a result of any standard that 

would directly impact walk-in 

refrigeration system energy efficiency. 

However, due to the small number of 

small businesses that manufacture WICF 

refrigeration systems and the fact that 

only one of two focuses on WICF 

refrigeration as a key market segment 

and constitutes a very small share of the 

overall walk-in market, DOE certifies 

that the proposed standards would not 

have a significant impact on a 

substantial number of small businesses 

with respect to the refrigeration 

equipment industry. 

4. Description and Estimate of 

Compliance Requirements 

Given the significant role of small 

businesses in the walk-in panel and 

walk-in door industries, DOE provides a 

detailed analysis of the impacts of the 

proposed standard on these industries 

below. 

Panels 

In the walk-in industry, panel 

manufacturers typically use the same 

production lines to manufacture all 

three equipment classes (SP.M, SP.L, 

and FP.L). The equipment class with the 

most stringent standard drives 

conversion costs. The design options 

considered include reducing heat loss 

through the panel frame (typically by 

using high density polyurethane 

framing materials or by moving to a 

frameless design), increasing the 

thickness of panels, and incorporating 

vacuum-insulated technology. 

Small manufacturers tend to be at a 

disadvantage when adapting to a new 

standard requiring fixed cost 

investments. Small manufacturers may 

have greater difficulty obtaining credit 

or may obtain less favorable terms than 

larger competitors when capital 

expenditures are necessary to meet the 

standard. Additionally, product testing 

costs stemming from the energy 

conservation standard tend to be fixed 

and do not scale with sales volume. As 

a result, these product conversion costs 

would be the same in absolute terms for 

small and large panel manufacturers. 

The small businesses would have to 

recoup these over smaller sales 

volumes, leading to higher per unit 

costs and potentially putting them at a 

pricing disadvantage. The projected 

conversion cost impacts on panel 

manufacturers are shown in Table VI–1 

and Table VI–2 below. 

TABLE VI–1—IMPACTS OF CONVERSION COSTS ON A SMALL PANEL MANUFACTURER

Capital conversion cost 

as a percentage of 

annual capital 

expenditures 

Product conversion cost 

as a percentage of 

annual R&D expense 

Total conversion cost as 

a percentage of annual 

revenue 

Total conversion cost as 

a percentage of annual 

operating income 

TSL 1 ............................................... 565 122 9 242 

TSL 2 ............................................... 0 0 0 0 

TSL 3 ............................................... 1695 230 26 669 

TSL 4 ............................................... 565 122 9 242 

TSL 5 ............................................... 1695 230 26 669 

TSL 6 ............................................... 5461 995 87 2262 

TABLE VI–2—IMPACTS OF CONVERSION COSTS ON A LARGE PANEL MANUFACTURER

Capital conversion cost 

as a percentage of 

annual capital 

expenditures 

Product conversion cost 

as a percentage of 

annual R&D expense 

Total conversion cost as 

a percentage of annual 

revenue 

Total conversion cost as 

a percentage of annual 

operating income 

TSL 1 ............................................... 22 5 0 9 

TSL 2 ............................................... 0 0 0 0 

TSL 3 ............................................... 66 9 1 26 

TSL 4 ............................................... 22 5 0 9 

TSL 5 ............................................... 66 9 1 26 

TSL 6 ............................................... 213 39 3 88 

At the proposed standard (TSL 4), the 

engineering analysis suggests that 

manufacturers would shift to high 

density rails for all products to achieve 

the minimum U-factors. The capital 

conversion costs would be 565% of the 

typical annual capital expenditures for 

a small manufacturer while only 22% of 

the typical annual capital expenditures 

for a large manufacturer. The product 

conversion costs would be 122% of the 

typical small manufacturer’s annual 

R&D budget and only 5% of the typical 

large manufacturer’s annual R&D 

budget. 

In addition to these conversion cost 

impacts, small manufacturers typically 

have a significant price disadvantage for 

raw materials, such as foaming agents. 

Any standard that requires small 


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manufacturers to use more insulation or 

add a different foam formulation for 

high density rails will accentuate the 

difference in material costs for large 

manufacturers versus small 

manufacturers. 

Based on the large number of small 

panel manufacturers and the potential 

scope of the impact (as described in 

section VI.B.2 below), DOE could not 

certify that the proposed standards 

would not have a significant impact on 

a substantial number of small 

businesses with respect to the panel 

industry. 

Doors 

For the walk-in door industry, DOE 

identified seven small manufacturers 

that produce doors as their primary 

product, as described in section VI.B.4. 

Three companies produce solid doors 

and four companies produce display 

doors. 

In the solid door market, all three 

manufacturers of customized passage 

doors and freight doors are small. The 

potential impacts on these three 

manufacturers are illustrated in Table 

VI–3. 

TABLE VI–3—IMPACTS OF CONVERSION COSTS ON A SMALL SOLID DOOR MANUFACTURER

Capital conversion cost 

as a percentage of 

annual capital 

expenditures 

Product conversion cost 

as a percentage of 

annual R&D expense 

Total conversion cost as 

a percentage of annual 

revenue 

Total conversion cost as 

a percentage of annual 

operating income 

TSL 1 ............................................... 52 47 2 25 

TSL 2 ............................................... 0 0 0 0 

TSL 3 ............................................... 626 47 5 63 

TSL 4 ............................................... 157 47 2 25 

TSL 5 ............................................... 626 47 5 63 

TSL 6 ............................................... 4086 142 27 369 

At the proposed standard (TSL 4), the 

engineering analysis suggests that 

manufacturers would shift to high 

density frames to achieve the minimum 

energy consumption for all solid doors. 

Additionally, for low-temperature 

passage doors, manufacturers would 

need to incorporate enhanced windows 

to reduce heat transmission; 

manufacturers of low-temperature 

freight doors would need to add 

controls to minimize anti-sweat heater 

energy usage. The capital conversion 

costs would be 157% of the typical 

annual capital expenditures for a small 

manufacturer and the product 

conversion costs would be 47% of the 

typical manufacturer’s annual R&D 

budget. 

In the display door market, two of the 

four manufacturers are small. If 

conversion costs for display door 

manufacturers were large, the small 

manufacturers could be at a 

disadvantage due to the fixed 

investments necessary for capital 

conversion and product conversion 

costs. However, as illustrated in Table 

VI–4, conversion costs for display door 

manufacturers are negligible for most 

TSLs. This is because the considered 

design options primarily consist of 

component swaps and component 

additions. To make these design 

changes, no costly equipment or tooling 

is necessary. As a result, the conversion 

costs do not cause small businesses to 

be at a significant disadvantage relative 

to larger businesses when adapting to 

the proposed standard. 

TABLE VI–4—IMPACTS OF CONVERSION COSTS ON A SMALL DISPLAY DOOR MANUFACTURER

Capital conversion cost 

as a percentage of 

annual capital 

expenditures 

Product conversion cost 

as a percentage of 

annual R&D expense 

Total conversion cost as 

a percentage of annual 

revenue 

Total conversion cost as 

a percentage of annual 

operating income 

TSL 1 ............................................... 0 2 0 0 

TSL 2 ............................................... 0 2 0 0 

TSL 3 ............................................... 0 2 0 0 

TSL 4 ............................................... 0 2 0 0 

TSL 5 ............................................... 0 2 0 0 

TSL 6 ............................................... 501 19 3 20 

TABLE VI–5—IMPACTS OF CONVERSION COSTS ON A LARGE DISPLAY DOOR MANUFACTURER

Capital conversion cost 

as a percentage of 

annual capital 

expenditures 

Product conversion cost 

as a percentage of 

annual R&D expense 

Total conversion cost as 

a percentage of annual 

revenue 

Total conversion cost as 

a percentage of annual 

operating income 

TSL 1 ............................................... 0 0 0 0 

TSL 2 ............................................... 0 0 0 0 

TSL 3 ............................................... 0 0 0 0 

TSL 4 ............................................... 0 0 0 0 

TSL 5 ............................................... 0 0 0 0 

TSL 6 ............................................... 88 3 0 4 

At the proposed standard (TSL 4), the 

engineering analysis suggests that 

manufacturers would need to purchase 

more efficient components, such as LED 

lights, and incorporate anti-sweat heater 

controllers. There are no anticipated 


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capital conversion costs, and product 

conversion costs appear to be 

manageable for both small and large 

businesses door manufacturers. 

Based on the number of small door 

manufacturers and the potential scope 

of the impact on solid door 

manufacturers, DOE could not certify 

that the proposed standards would not 

have a significant impact on a 

significant number of small businesses 

with respect to the walk-in door 

industry. 

5. Duplication, Overlap, and Conflict 

With Other Rules and Regulations 

DOE is not aware of any rules or 

regulations that duplicate, overlap, or 

conflict with the rule being considered 

today. 

6. Significant Alternatives to the 

Proposed Rule 

The primary alternatives to the 

proposed rule considered by DOE are 

the other TSLs besides the one being 

considered today, proposed TSL 4. DOE 

explicitly considered the role of small 

businesses in its selection of TSL 4 

rather than TSL 5. Though TSL 5 results 

in greater energy savings for the 

country, the standard would place 

excessive burdens on manufacturers, 

including small manufacturers, of walkin refrigeration, panels, and doors. In 

particular, DOE considered the increase 

in conversion costs and potential 

negative impacts on small businesses 

that occurred between TSL 4 and TSL 

5 for the solid door and panel 

industries, which have a significant 

number of small businesses. As another 

alternative to the proposed standard, 

DOE also considered lower TSLs; in 

particular, TSL 1, which does not set 

standards for panels and non-display 

doors. Chapter 12 of the TSD contains 

additional information about the impact 

of this rulemaking on manufacturers. 

In addition to the other TSLs 

considered, alternatives to the proposed 

rule include the following policy 

alternatives: (1) No new regulatory 

action, (2) commercial consumer 

rebates, and (3) commercial consumer 

tax credits. Chapter 17 of the TSD 

associated with this proposed rule 

includes a report referred to in Section 

VI.A in the preamble as the regulatory 

impact analysis (RIA). The energy 

savings of these regulatory alternatives 

are one to two orders of magnitude 

smaller than those expected from the 

standard levels under consideration. 

The range of economic impacts of these 

regulatory alternatives is an order of 

magnitude smaller than the range of 

impacts expected from the standard 

levels under consideration. 

C. Review Under the Paperwork 

Reduction Act 

Manufacturers of walk-in coolers and 

freezers must certify to DOE that their 

products comply with any applicable 

energy conservation standards. In 

certifying compliance, manufacturers 

must test their products according to the 

DOE test procedures for walk-in coolers 

and freezers, including any amendments 

adopted for those test procedures. DOE 

has established regulations for the 

certification and recordkeeping 

requirements for all covered consumer 

products and commercial equipment, 

including walk-in coolers and freezers. 

76 FR 12422 (March 7, 2011). The 

collection-of-information requirement 

for the certification and recordkeeping 

is subject to review and approval by 

OMB under the Paperwork Reduction 

Act (PRA). This requirement has been 

approved by OMB under OMB control 

number 1910–1400. Public reporting 

burden for the certification is estimated 

to average 20 hours per response, 

including the time for reviewing 

instructions, searching existing data 

sources, gathering and maintaining the 

data needed, and completing and 

reviewing the collection of information. 

Notwithstanding any other provision 

of the law, no person is required to 

respond to, nor shall any person be 

subject to a penalty for failure to comply 

with, a collection of information subject 

to the requirements of the PRA, unless 

that collection of information displays a 

currently valid OMB Control Number. 

D. Review Under the National 

Environmental Policy Act of 1969 

DOE has prepared a draft 

environmental assessment (EA) of the 

impacts of the proposed rule pursuant 

to the National Environmental Policy 

Act of 1969 (42 U.S.C. 4321 et seq.), the 

regulations of the Council on 

Environmental Quality (40 CFR parts 

1500–1508), and DOE’s regulations for 

compliance with the National 

Environmental Policy Act of 1969 (10 

CFR part 1021). This assessment 

includes an examination of the potential 

effects of emission reductions likely to 

result from the rule in the context of 

global climate change, as well as other 

types of environmental impacts. The 

draft EA has been incorporated into the 

NOPR TSD as chapter 15. Before issuing 

a final rule for walk-in coolers and 

freezers, DOE will consider public 

comments and, as appropriate, 

determine whether to issue a finding of 

no significant impact (FONSI) as part of 

a final EA or to prepare an 

environmental impact statement (EIS) 

for this rulemaking. 

E. Review Under Executive Order 13132 

Executive Order 13132, ‘‘Federalism’’ 

64 FR 43255 (Aug. 10, 1999), imposes 

certain requirements on Federal 

agencies formulating and implementing 

policies or regulations that preempt 

State law or that have Federalism 

implications. The Executive Order 

requires agencies to examine the 

constitutional and statutory authority 

supporting any action that would limit 

the policymaking discretion of the 

States and to carefully assess the 

necessity for such actions. The 

Executive Order also requires agencies 

to have an accountable process to 

ensure meaningful and timely input by 

State and local officials in the 

development of regulatory policies that 

have Federalism implications. On 

March 14, 2000, DOE published a 

statement of policy describing the 

intergovernmental consultation process 

it will follow in the development of 

such regulations. 65 FR 13735. EPCA 

governs and prescribes Federal 

preemption of State regulations as to 

energy conservation for the products 

that are the subject of today’s proposed 

rule. See 42 U.S.C. 6316(h)(1)(A)(2), 42 

U.S.C. 6316(h)(2)(B), and 42 U.S.C. 

6316(h)(3). No further action is required 

by Executive Order 13132. 

F. Review Under Executive Order 12988 

With respect to the review of existing 

regulations and the promulgation of 

new regulations, section 3(a) of 

Executive Order 12988, ‘‘Civil Justice 

Reform,’’ imposes on Federal agencies 

the general duty to adhere to the 

following requirements: (1) Eliminate 

drafting errors and ambiguity; (2) write 

regulations to minimize litigation; and 

(3) provide a clear legal standard for 

affected conduct rather than a general 

standard and promote simplification 

and burden reduction. 61 FR 4729 (Feb. 

7, 1996). Section 3(b) of Executive Order 

12988 specifically requires that 

Executive agencies make every 

reasonable effort to ensure that the 

regulation: (1) Clearly specifies the 

preemptive effect, if any; (2) clearly 

specifies any effect on existing Federal 

law or regulation; (3) provides a clear 

legal standard for affected conduct 

while promoting simplification and 

burden reduction; (4) specifies the 

retroactive effect, if any; (5) adequately 

defines key terms; and (6) addresses 

other important issues affecting clarity 

and general draftsmanship under any 

guidelines issued by the Attorney 

General. Section 3(c) of Executive Order 

12988 requires Executive agencies to 

review regulations in light of applicable 

standards in section 3(a) and section 


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3(b) to determine whether they are met 

or it is unreasonable to meet one or 

more of them. DOE has completed the 

required review and determined that, to 

the extent permitted by law, this 

proposed rule meets the relevant 

standards of Executive Order 12988. 

G. Review Under the Unfunded 

Mandates Reform Act of 1995 

Title II of the Unfunded Mandates 

Reform Act of 1995 (UMRA) requires 

each Federal agency to assess the effects 

of Federal regulatory actions on State, 

local, and Tribal governments and the 

private sector. Public Law 104–4, sec. 

201 (codified at 2 U.S.C. 1531). For a 

proposed regulatory action likely to 

result in a rule that may cause the 

expenditure by State, local, and Tribal 

governments, in the aggregate, or by the 

private sector of $100 million or more 

in any one year (adjusted annually for 

inflation), section 202 of UMRA requires 

a Federal agency to publish a written 

statement that estimates the resulting 

costs, benefits, and other effects on the 

national economy. (2 U.S.C. 1532(a), (b)) 

The UMRA also requires a Federal 

agency to develop an effective process 

to permit timely input by elected 

officers of State, local, and Tribal 

governments on a proposed ‘‘significant 

intergovernmental mandate,’’ and 

requires an agency plan for giving notice 

and opportunity for timely input to 

potentially affected small governments 

before establishing any requirements 

that might significantly or uniquely 

affect small governments. On March 18, 

1997, DOE published a statement of 

policy on its process for 

intergovernmental consultation under 

UMRA. 62 FR 12820. DOE’s policy 

statement is also available at http://

energy.gov/gc/office-general-counsel. 

Although today’s proposed rule does 

not contain a Federal intergovernmental 

mandate, it may require expenditures of 

$100 million or more on the private 

sector. Specifically, the proposed rule 

will likely result in a final rule that 

could require expenditures of $100 

million or more. Such expenditures may 

include: (1) Investment in research and 

development and in capital 

expenditures by walk-in cooler and 

freezer manufacturers in the years 

between the final rule and the 

compliance date for the new standards, 

and (2) incremental additional 

expenditures by customers to purchase 

higher-efficiency walk-in coolers and 

freezers, starting at the compliance date 

for the applicable standard. 

Section 202 of UMRA authorizes a 

Federal agency to respond to the content 

requirements of UMRA in any other 

statement or analysis that accompanies 

the proposed rule. 2 U.S.C. 1532(c). The 

content requirements of section 202(b) 

of UMRA relevant to a private sector 

mandate substantially overlap the 

economic analysis requirements that 

apply under section 325(o) of EPCA and 

Executive Order 12866. The 

SUPPLEMENTARY INFORMATION section of 

the NOPR and the ‘‘Regulatory Impact 

Analysis’’ section of the TSD for this 

proposed rule respond to those 

requirements. 

Under section 205 of UMRA, the 

Department is obligated to identify and 

consider a reasonable number of 

regulatory alternatives before 

promulgating a rule for which a written 

statement under section 202 is required. 

2 U.S.C. 1535(a). DOE is required to 

select from those alternatives the most 

cost-effective and least burdensome 

alternative that achieves the objectives 

of the proposed rule unless DOE 

publishes an explanation for doing 

otherwise, or the selection of such an 

alternative is inconsistent with law. As 

required by 42 U.S.C. 6313(f)(4)(A), 

today’s proposed rule would establish 

energy conservation standards for walkin coolers and walk-in freezers that are 

designed to achieve the maximum 

improvement in energy efficiency that 

DOE has determined to be both 

technologically feasible and 

economically justified. A full discussion 

of the alternatives considered by DOE is 

presented in the ‘‘Regulatory Impact 

Analysis’’ section of the TSD for today’s 

proposed rule. 

H. Review Under the Treasury and 

General Government Appropriations 

Act, 1999 

Section 654 of the Treasury and 

General Government Appropriations 

Act, 1999 (Pub. L. 105–277) requires 

Federal agencies to issue a Family 

Policymaking Assessment for any rule 

that may affect family well-being. This 

rule would not have any impact on the 

autonomy or integrity of the family as 

an institution. Accordingly, DOE has 

concluded that it is not necessary to 

prepare a Family Policymaking 

Assessment. 

I. Review Under Executive Order 12630 

DOE has determined, under Executive 

Order 12630, ‘‘Governmental Actions 

and Interference with Constitutionally 

Protected Property Rights’’ 53 FR 8859 

(Mar. 18, 1988), that this regulation 

would not result in any takings that 

might require compensation under the 

Fifth Amendment to the U.S. 

Constitution. 

J. Review Under the Treasury and 

General Government Appropriations 

Act, 2001 

Section 515 of the Treasury and 

General Government Appropriations 

Act, 2001 (44 U.S.C. 3516, note) 

provides for Federal agencies to review 

most disseminations of information to 

the public under guidelines established 

by each agency pursuant to general 

guidelines issued by OMB. OMB’s 

guidelines were published at 67 FR 

8452 (Feb. 22, 2002), and DOE’s 

guidelines were published at 67 FR 

62446 (Oct. 7, 2002). DOE has reviewed 

today’s NOPR under the OMB and DOE 

guidelines and has concluded that it is 

consistent with applicable policies in 

those guidelines. 

K. Review Under Executive Order 13211 

Executive Order 13211, ‘‘Actions 

Concerning Regulations That 

Significantly Affect Energy Supply, 

Distribution, or Use’’ 66 FR 28355 (May 

22, 2001) requires Federal agencies to 

prepare and submit to OIRA at OMB a 

Statement of Energy Effects for any 

proposed significant energy action. A 

‘‘significant energy action’’ is defined as 

any action by an agency that 

promulgates or is expected to lead to 

promulgation of a final rule, and that: 

(1) Is a significant regulatory action 

under Executive Order 12866, or any 

successor order; and (2) is likely to have 

a significant adverse effect on the 

supply, distribution, or use of energy; or 

(3) is designated by the Administrator of 

OIRA as a significant energy action. For 

any proposed significant energy action, 

the agency must give a detailed 

statement of any adverse effects on 

energy supply, distribution, or use 

should the proposal be implemented, 

and of reasonable alternatives to the 

action and their expected benefits on 

energy supply, distribution, and use. 

DOE has tentatively concluded that 

today’s regulatory action, which sets 

forth energy conservation standards for 

walk-in coolers and freezers, is not a 

significant energy action because the 

proposed standards are not likely to 

have a significant adverse effect on the 

supply, distribution, or use of energy, 

nor has it been designated as such by 

the Administrator at OIRA. Accordingly, 

DOE has not prepared a Statement of 

Energy Effects on the proposed rule. 

L. Review Under the Information 

Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in 

consultation with the Office of Science 

and Technology Policy (OSTP), issued 

its Final Information Quality Bulletin 

for Peer Review (the Bulletin). 70 FR 


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2664 (Jan. 14, 2005). The Bulletin 

establishes that certain scientific 

information shall be peer reviewed by 

qualified specialists before it is 

disseminated by the Federal 

Government, including influential 

scientific information related to agency 

regulatory actions. The purpose of the 

bulletin is to enhance the quality and 

credibility of the Government’s 

scientific information. Under the 

Bulletin, the energy conservation 

standards rulemaking analyses are 

‘‘influential scientific information,’’ 

which the Bulletin defines as scientific 

information the agency reasonably can 

determine will have, or does have, a 

clear and substantial impact on 

important public policies or private 

sector decisions. 70 FR 2667. 

In response to OMB’s Bulletin, DOE 

conducted formal in-progress peer 

reviews of the energy conservation 

standards development process and 

analyses and has prepared a Peer 

Review Report pertaining to the energy 

conservation standards rulemaking 

analyses. Generation of this report 

involved a rigorous, formal, and 

documented evaluation using objective 

criteria and qualified and independent 

reviewers to make a judgment as to the 

technical/scientific/business merit, the 

actual or anticipated results, and the 

productivity and management 

effectiveness of programs or projects. 

The ‘‘Energy Conservation Standards 

Rulemaking Peer Review Report’’ dated 

February 2007 has been disseminated 

and is available at the following Web 

site: www1.eere.energy.gov/buildings/

appliance_standards/peer_review.html. 

VII. Public Participation 

A. Attendance at the Public Meeting 

The time, date, and location of the 

public meeting are listed in the DATES

and ADDRESSES sections at the beginning 

of this notice. If you plan to attend the 

public meeting, please notify Ms. 

Brenda Edwards at (202) 586–2945 or 

Brenda.Edwards@ee.doe.gov. Please 

note that foreign nationals visiting DOE 

Headquarters are subject to advance 

security screening procedures. Any 

foreign national wishing to participate 

in the meeting should advise DOE as 

soon as possible by contacting Ms. 

Edwards to initiate the necessary 

procedures. Please also note that those 

wishing to bring laptops into the 

Forrestal Building will be required to 

obtain a property pass. Visitors should 

avoid bringing laptops, or allow an extra 

45 minutes. Persons can attend the 

public meeting via webinar. 

Webinar registration information, 

participant instructions, and 

information about the capabilities 

available to webinar participants will be 

published on DOE’s Web site at: http:// 

www1.eere.energy.gov/buildings/

appliance_standards/rulemaking.aspx/

ruleid/30. Participants are responsible 

for ensuring their systems are 

compatible with the webinar software. 

B. Procedure for Submitting Prepared 

General Statements for Distribution 

Any person who has plans to present 

a prepared general statement may 

request that copies of his or her 

statement be made available at the 

public meeting. Such persons may 

submit requests, along with an advance 

electronic copy of their statement in 

PDF (preferred), Microsoft Word or 

Excel, WordPerfect, or text (ASCII) file 

format, to the appropriate address 

shown in the ADDRESSES section at the 

beginning of this notice. The request 

and advance copy of statements must be 

received at least one week before the 

public meeting and may be emailed, 

hand-delivered, or sent by mail. DOE 

prefers to receive requests and advance 

copies via email. Please include a 

telephone number to enable DOE staff to 

make follow-up contact, if needed. 

C. Conduct of the Public Meeting 

DOE will designate a DOE official to 

preside at the public meeting and may 

also use a professional facilitator to aid 

discussion. The meeting will not be a 

judicial or evidentiary-type public 

hearing, but DOE will conduct it in 

accordance with section 336 of EPCA 

(42 U.S.C. 6306). A court reporter will 

be present to record the proceedings and 

prepare a transcript. DOE reserves the 

right to schedule the order of 

presentations and to establish the 

procedures governing the conduct of the 

public meeting. After the public 

meeting, interested parties may submit 

further comments on the proceedings as 

well as on any aspect of the rulemaking 

until the end of the comment period. 

The public meeting will be conducted 

in an informal, conference style. DOE 

will present summaries of comments 

received before the public meeting, 

allow time for prepared general 

statements by participants, and 

encourage all interested parties to share 

their views on issues affecting this 

rulemaking. Each participant will be 

allowed to make a general statement 

(within time limits determined by DOE), 

before the discussion of specific topics. 

DOE will allow, as time permits, other 

participants to comment briefly on any 

general statements. 

At the end of all prepared statements 

on a topic, DOE will permit participants 

to clarify their statements briefly and 

comment on statements made by others. 

Participants should be prepared to 

answer questions by DOE and by other 

participants concerning these issues. 

DOE representatives may also ask 

questions of participants concerning 

other matters relevant to this 

rulemaking. The official conducting the 

public meeting will accept additional 

comments or questions from those 

attending, as time permits. The 

presiding official will announce any 

further procedural rules or modification 

of the above procedures that may be 

needed for the proper conduct of the 

public meeting. 

A transcript of the public meeting will 

be included in the docket, which can be 

viewed as described in the Docket 

section at the beginning of this notice. 

In addition, any person may buy a copy 

of the transcript from the transcribing 

reporter. 

D. Submission of Comments 

DOE will accept comments, data, and 

information regarding this proposed 

rule before or after the public meeting, 

but no later than the date provided in 

the DATES section at the beginning of 

this proposed rule. Interested parties 

may submit comments, data, and other 

information using any of the methods 

described in the ADDRESSES section at 

the beginning of this notice. 

Submitting comments via 

regulations.gov. The regulations.gov 

Web page will require you to provide 

your name and contact information. 

Your contact information will be 

viewable to DOE Building Technologies 

staff only. Your contact information will 

not be publicly viewable except for your 

first and last names, organization name 

(if any), and submitter representative 

name (if any). If your comment is not 

processed properly because of technical 

difficulties, DOE will use this 

information to contact you. If DOE 

cannot read your comment due to 

technical difficulties and cannot contact 

you for clarification, DOE may not be 

able to consider your comment. 

However, your contact information 

will be publicly viewable if you include 

it in the comment itself or in any 

documents attached to your comment. 

Any information that you do not want 

to be publicly viewable should not be 

included in your comment, nor in any 

document attached to your comment. 

Otherwise, persons viewing comments 

will see only first and last names, 

organization names, correspondence 

containing comments, and any 

documents submitted with the 

comments. 

Do not submit to regulations.gov 

information for which disclosure is 


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restricted by statute, such as trade 

secrets and commercial or financial 

information (hereinafter referred to as 

Confidential Business Information 

(CBI)). Comments submitted through 

regulations.gov cannot be claimed as 

CBI. Comments received through the 

Web site will waive any CBI claims for 

the information submitted. For 

information on submitting CBI, see the 

Confidential Business Information 

section. 

DOE processes submissions made 

through regulations.gov before posting. 

Normally, comments will be posted 

within a few days of being submitted. 

However, if large volumes of comments 

are being processed simultaneously, 

your comment may not be viewable for 

up to several weeks. Please keep the 

comment tracking number that 

regulations.gov provides after you have 

successfully uploaded your comment. 

Submitting comments via email, hand 

delivery/courier, or mail. Comments and 

documents submitted via email, hand 

delivery, or mail also will be posted to 

regulations.gov. If you do not want your 

personal contact information to be 

publicly viewable, do not include it in 

your comment or any accompanying 

documents. Instead, provide your 

contact information in a cover letter. 

Include your first and last names, email 

address, telephone number, and 

optional mailing address. The cover 

letter will not be publicly viewable as 

long as it does not include any 

comments. 

Include contact information each time 

you submit comments, data, documents, 

and other information to DOE. If you 

submit via mail or hand delivery or 

courier, please provide all items on a 

CD, if feasible. It is not necessary to 

submit printed copies. No facsimiles 

(faxes) will be accepted. 

Comments, data, and other 

information submitted to DOE 

electronically should be provided in 

PDF (preferred), Microsoft Word or 

Excel, WordPerfect, or text (ASCII) file 

format. Provide documents that are not 

secured, that are written in English, and 

that are free of any defects or viruses. 

Documents should not contain special 

characters or any form of encryption 

and, if possible, they should carry the 

electronic signature of the author. 

Campaign form letters. Please submit 

campaign form letters by the originating 

organization in batches of between 50 to 

500 form letters per PDF or as one form 

letter with a list of supporters’ names 

compiled into one or more PDFs. This 

reduces comment processing and 

posting time. 

Confidential Business Information. 

According to 10 CFR 1004.11, any 

person submitting information that he 

or she believes to be confidential and 

exempt by law from public disclosure 

should submit via email, postal mail, or 

hand delivery or courier two wellmarked copies: One copy of the 

document marked confidential 

including all the information believed to 

be confidential, and one copy of the 

document marked non-confidential with 

the information believed to be 

confidential deleted. Submit these 

documents via email or on a CD, if 

feasible. DOE will make its own 

determination about the confidential 

status of the information and treat it 

according to its determination. 

Factors of interest to DOE when 

evaluating requests to treat submitted 

information as confidential include: (1) 

A description of the items; (2) whether 

and why such items are customarily 

treated as confidential within the 

industry; (3) whether the information is 

generally known by or available from 

other sources; (4) whether the 

information has previously been made 

available to others without obligation 

concerning its confidentiality; (5) an 

explanation of the competitive injury to 

the submitting person that would result 

from public disclosure; (6) when such 

information might lose its confidential 

character due to the passage of time; and 

(7) why disclosure of the information 

would be contrary to the public interest. 

It is DOE’s policy that all comments 

may be included in the public docket, 

without change and as received, 

including any personal information 

provided in the comments (except 

information deemed to be exempt from 

public disclosure). 

E. Issues on Which DOE Seeks Comment 

Although DOE welcomes comments 

on any aspect of this proposal, DOE is 

particularly interested in receiving 

comments and views of interested 

parties concerning the following issues: 

1. Component Level Standards 

In this NOPR, DOE proposes to set 

separate standards for the panels, 

display doors, non-display doors, and 

refrigeration system of a walk-in, but is 

not proposing to establish an overall 

performance standard for the envelope 

or for the walk-in as a whole. DOE 

requests that interested parties submit 

comments about this approach. See 

section III.A for further details. 

2. Market Performance Data 

As part of the market assessment, 

DOE collects information that provides 

an overall picture of the market for the 

walk-in coolers and freezers. DOE’s 

analysis of market data uses catalogue 

and performance data to determine the 

number of products on the market at 

varying efficiency levels. However, 

WICF equipment has not previously 

been rated for efficiency by 

manufacturers, nor has an efficiency 

metric been established for the 

equipment. DOE requests that interested 

parties submit market performance data 

to help inform DOE’s analysis. See 

section IV.A for further details. 

3. Definitions 

In this NOPR, DOE proposes to amend 

the existing definition of display door 

and to add definitions of passage door 

and freight door, as follows. 

DOE proposes to amend the existing 

definition of display door to include all 

doors that are composed of 50 percent 

or more glass or another transparent 

material. This amendment is intended 

to classify passage doors that are mostly 

composed of glass as display doors 

because the utility and construction of 

glass passage doors more closely 

resemble that of a display door. DOE 

proposes the following amended 

definition of display door: ‘‘Display 

door means a door that—(1) is designed 

for product display; or (2) has 50 

percent or more of its surface area 

composed of glass or another 

transparent material.’’ The amended 

definition would affect both the test 

procedure (by potentially subjecting a 

broader range of equipment to testing) 

and the energy conservation standards. 

DOE requests comment on the proposed 

definition of display door. 

DOE is also proposing a definition for 

passage doors in order to differentiate 

passage doors from freight doors. 

Passage doors are mostly intended for 

the passage of people and small 

machines such as hand carts. DOE 

proposes the following definition of 

passage door: ‘‘Passage door means a 

door that is used as a means of access 

for people and is less than 4 feet wide 

and 8 feet tall.’’ DOE requests comment 

on the proposed definition of passage 

door. 

Freight doors tend to be larger than 

passage doors and are typically used to 

allow machines, such as forklifts, into 

walk-ins. DOE is proposing a definition 

of ‘‘freight door’’ to distinguish it from 

a passage door. DOE proposes the 

following definition of freight door: 

‘‘Freight door means a door that is not 

a passage door and is equal to or larger 

than 4 feet wide and 8 feet tall.’’ DOE 

requests comment on the proposed 

definition of freight door. 

See section IV.A.1 for further 

information on the definitions. 


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4. Equipment Included in the 

Rulemaking 

DOE proposes not to include certain 

types of equipment in the rulemaking 

analysis. DOE identified three types of 

panels used in the walk-in industry: 

display panels, floor panels, and nonfloor panels. Based on its research, DOE 

determined that Display panels, 

typically found in beer caves (walk-ins 

used for the display and storage of beer 

or other alcoholic beverages often found 

in a supermarket) make up a small 

percentage of all panels currently 

present in the market. Therefore, 

because of the extremely limited energy 

savings potential currently projected to 

result from amending the requirements 

that these panels must meet, DOE is not 

proposing standards for walk-in display 

panels in this NOPR. Also, DOE is 

declining to set a performance-based 

standard for walk-in cooler floor panels. 

All other types of panels, freezer floor 

and non-floor, will be subject to a 

performance standard. DOE requests 

comment on this approach and requests 

market data to better understand the 

market share of display panels and 

walk-in cooler floor panels. 

DOE also proposes not to include 

blast freezer refrigeration systems, 

which are designed to quickly freeze 

food and then store it at a holding 

temperature, in this rulemaking 

analysis. DOE received comments 

regarding the performance difference 

and the higher energy consumption of 

blast freezers as compared to storage 

freezers. DOE questions whether blast 

freezer refrigeration systems would be 

less efficient than storage freezers and 

seeks information regarding whether 

blast freezers would face difficulty in 

complying with DOE’s proposed 

standards. Furthermore, if blast freezers 

cannot comply with those proposed 

standards, DOE requests test procedure 

data confirming the same. See section 

IV.A.2 for details. 

5. Type of Refrigerant Analyzed 

DOE based its analysis on 

refrigeration equipment using R404A, a 

hydrofluorocarbon (HFC) refrigerant, as 

it is widely used in the walk-ins 

industry. DOE received comments 

supporting the use of HFC refrigerants, 

but also suggested considering 

refrigerants with lower global warming 

potential (GWP) due to the shift in the 

marketplace toward these products. 

DOE acknowledges that there are 

government-wide efforts to reduce 

emissions of HFCs, and such actions are 

being pursued both through 

international diplomacy as well as 

domestic actions. DOE, in concert with 

other relevant agencies, will continue to 

work with industry and other 

stakeholders to identify safer and more 

sustainable alternatives to HFCs while 

evaluating energy efficiency standards 

for this equipment. DOE requests 

comment on the extent of current use or 

future availability of lower GWP 

refrigerants and asks manufacturers and 

chemical producers to submit data 

related to the ability of equipment 

(existing or redesigned) using HFC 

alternative refrigerants to meet the 

proposed standard. See section IV.A.2.b 

for further details. DOE also requests 

data and evidence to support estimates 

of the cost of any incremental 

technology or equipment redesign that 

may be needed in order to compensate 

for any energy efficiency losses 

associated with the use of alternative 

refrigerants to meet the standards 

proposed in this notice. 

6. Refrigeration Classes 

DOE has proposed separate classes for 

dedicated condensing refrigeration 

systems and unit coolers connected to 

multiplex condensing systems. 

However, DOE does not propose to 

create separate classes for dedicated 

packaged systems (where the unit cooler 

and condensing unit are integrated into 

a single piece of equipment) and 

dedicated split systems (where the unit 

cooler and condensing unit are separate 

pieces of equipment connected by 

refrigerant piping). Due to the small 

market share of packaged systems, DOE 

proposes to base the standard for 

dedicated condensing systems on an 

analysis of split systems. DOE requests 

comment on its proposal not to consider 

dedicated packaged systems and 

dedicated split systems as separate 

classes, and specifically asks whether 

this proposal would unfairly 

disadvantage any manufacturers. 

In addition, DOE proposes one 

standard level for high-capacity 

equipment and another for low-capacity 

equipment within the dedicated 

condensing category (because the 

compressor is covered only for DC 

systems). High- and low-capacity 

equipment would thus also be 

considered different equipment classes, 

with the classes divided at a threshold 

of 9,000 Btu/h. DOE requests comment 

on this proposal, particularly the 

capacity threshold between high- and 

low-capacity equipment. 

See section IV.A.3.b for details about 

the refrigeration system equipment 

classes. 

7. Cycle Efficiency 

DOE considered design options 

manufacturers could use to improve 

cycle efficiency; for example, 

economizer cooling. In the screening 

analysis, DOE screened out economizer 

cooling based on utility to the 

consumer, one of the four screening 

criteria. Specifically, economizer 

cooling is not effective in areas of the 

country where the temperature does not 

drop below a walk-in’s temperature. 

DOE did not identify any other options 

to improve cycle efficiency beyond what 

was already considered. However, DOE 

realizes that there may be other methods 

and designs manufacturers could use to 

improve cycle efficiency and requests 

specific recommendations on such 

methods and designs, as well as how 

they could be incorporated into the 

analysis of standard levels. See section 

IV.B.2.b for details. 

8. Envelope Representative Sizes 

DOE used three different panel sizes 

to represent the variation in panels 

within each equipment class. DOE 

determined the sizes based on market 

research and calculated the impact of 

size on the test metric, U-factor. DOE 

requests comment on the representative 

sizes used in the analysis and whether 

other sizes should be considered. 

Similar to panels, DOE used three 

different sizes to represent the 

differences in doors within each class 

for walk-in display and non-display 

doors. The sizes of the doors were 

determined by market research, and can 

be found in section IV.C.1.a for display 

and non-display doors. DOE requests 

comment on the representative 

equipment sizes analyzed in the 

proposed analysis. See section IV.C.1.a 

for further details. 

9. Performance Data for Envelope 

Components 

DOE’s engineering model separately 

analyzes panels, display doors, and nondisplay doors. The models estimate the 

performance of the baseline equipment 

and levels of performance above the 

baseline associated with specific design 

options that are added cumulatively to 

the baseline equipment. Results for 

performance of all components can be 

found in appendix 5A of the TSD. DOE 

requests comment on the performance 

data and requests any data 

manufacturers can provide about the 

performance of panels, display doors, or 

non-display doors and their design 

options. See section IV.A for further 

details. 

10. Refrigeration Metric 

The refrigeration energy model 

calculates the annual energy 

consumption and the Annual Walk-In 

Energy Factor (AWEF) of walk-in 


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coolers and freezers at various 

performance levels using a design 

option approach. AWEF is the ratio of 

the total heat, not included in the heat 

generated by the operation of the 

refrigeration system, removed, in Btu, 

from a walk-in box during a one-year 

period of usage to the total energy input 

of refrigeration systems, in watt-hours, 

during the same period. DOE proposes 

using AWEF as the metric to set 

standards for the refrigeration system 

and requests comment on this proposal. 

See section IV.C.2.a for further details. 

11. Manufacturing Markups 

DOE calculated the manufacturer’s 

selling price of the walk-in cooler and 

freezer equipment by multiplying the 

manufacturer’s production cost by a 

markup and adding the equipment’s 

shipping cost. The markup affects the 

manufacturer’s selling price, which is a 

critical input to the downstream 

economic analyses. DOE calculated an 

average markup for panels to be 32 

percent, for display doors to be 50 

percent, for non-display doors to be 62 

percent, and for refrigeration to be 35 

percent. DOE requests comment on the 

proposed markups. See section IV.C.3.d 

for further details. 

12. Envelope Component Shipping 

Prices 

DOE has found through its research 

that most panel, display door, and nondisplay door manufacturers use less 

than truck load freight to ship their 

respective components. DOE also found 

that typically none of the manufacturers 

mark up the shipments for profit, and 

instead include the cost of shipping as 

part of the price quote. DOE has 

conducted its analysis accordingly and 

requests comment on the shipping 

prices found in chapter 5 of the NOPR 

TSD. See section IV.C.3.e for further 

details. 

13. Panel and Door Baseline 

Assumptions 

In the NOPR analysis, DOE used 

wood framing members as the baseline 

framing material in panels. DOE’s 

analysis assumes the typical wood 

frame completely borders the insulation 

and is 1.5 inches wide. DOE requests 

comment on its baseline specifications 

for walk-in panels, specifically the 

assumptions about framing material and 

framing dimensions. 

DOE assumed that the baseline nondisplay doors are constructed in a 

similar manner to baseline panels. 

Baseline non-display doors consist of 

wood framing materials 1.5 inches wide 

that completely border foamed-in-place 

polyurethane insulation. For nondisplay doors, DOE also proposes to 

include a 2.25 ft2 window that conforms 

to the standards set by EPCA on all nondisplay passage doors regardless of the 

passage door’s size. DOE analyzed two 

different size windows for non-display 

freight doors. DOE assumed that a small 

freight door has a 2.25 ft2 window and 

that both medium and large freight 

doors have 4 ft2 windows. DOE requests 

comment on the baseline specifications 

for non-display doors, specifically on 

the size of the windows included in the 

baseline door. 

DOE made several assumptions about 

baseline display doors in its analysis. 

First it assumed that baseline display 

cooler doors are composed of two panes 

of glass with argon gas fill and hard coat 

low-e coating. Second, DOE assumed 

that the baseline cooler display door 

requires 2.9 W/ft2 of anti-sweat heater 

wire and does not have a heater wire 

controller. Baseline display freezer 

doors in DOE’s analysis are composed of 

three panes of glass, argon gas, and soft 

coat low-e coating. Third, DOE assumed 

that baseline freezer doors use 15.23 W/ 

ft2 of anti-sweat heater wire power and 

require an anti-sweat heater wire 

controller. Finally, DOE assumed that 

each baseline door is associated with 

one fluorescent light with an electronic 

ballast, and that a door shorter than 6.5 

feet has a 5-foot fluorescent bulb and a 

door equal to or taller than 6.5 feet has 

a 6-foot fluorescent bulb. DOE requests 

comment on the baseline assumptions 

for display cooler and freezer doors. In 

particular, DOE requests data 

illustrating the energy or power 

consumption of anti-sweat heaters 

found on cooler and freezer display 

doors. 

See section IV.C.4.a for further details 

on the baseline assumptions. 

14. Condensing Unit and Unit Cooler 

Components 

In its analysis of baseline equipment, 

DOE included all necessary components 

of the refrigeration system that came 

from the manufacturer. However, DOE 

has tentatively decided against 

including components in its engineering 

analysis that are not specifically part of 

the unit cooler or condensing unit; for 

example, refrigerant piping connecting a 

unit cooler to a multiplex condensing 

system. DOE assumes that these are not 

included in the manufacturer’s selling 

price of the equipment, and would be 

supplied by the contractor upon 

installation. DOE requests comment on 

this assumption. See section IV.C.4.b for 

further details. 

15. Refrigeration Temperature 

Difference Assumption 

In determining appropriate 

temperature set points, DOE considered 

information from various sources in 

formulating its assumptions: Comments, 

research, and confidential and nonconfidential discussions with 

manufacturers and other parties. DOE 

notes that the ambient temperature 

specified in the test procedure is 90 or 

95 degrees for indoor and outdoor 

condensing units, respectively. Given 

that the system must maintain a 

reasonable temperature difference (TD) 

between the SCT and the ambient 

temperature, the SCT during the test 

procedure would be higher than the 90– 

95 degree assumption recommended. 

Even though the set point during actual 

use may be lower, equipment is rated— 

and evaluated for meeting the 

standard—at the test procedure rating 

points. DOE requests comment on this 

assumption, particularly whether the 

TDs for baseline and higher efficiency 

equipment are appropriate. See section 

IV.C.4.b for further details. 

16. Panel Design Options 

In the proposed engineering analysis 

for walk-in panels, DOE included design 

options that increase the baseline 

insulation thickness, change the 

baseline insulation material from foamin-place polyurethane to a hybrid of 

polyurethane and VIP, change the 

baseline framing material from wood to 

high-density polyurethane, and 

eliminate a non-floor-panel’s framing 

material. DOE proposes that floor panels 

must retain some type of framing 

material, and that high-density 

polyurethane framing materials found in 

a panel have the same dimensions as the 

wood framing materials. DOE requests 

comment on the design options for 

panels, including the specifications for 

high-density polyurethane framing 

materials, manufacturer conversion 

costs for increasing the baseline panel 

thickness, and any estimated changes in 

repair, maintenance, or installation 

costs. DOE also requests comment on 

the technological feasibility of the panel 

options analyzed and whether the 

design options selected would cause 

any lessening of the utility or the 

performance of the walk-ins. See section 

IV.C.5.a for further details. 

17. Display and Non-Display Door 

Design Options 

The design options that DOE proposes 

for display doors include improved 

glass packs, anti-sweat heater controls 

for cooler doors, LED lighting, and 

lighting sensors. DOE does not propose 


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anti-sweat heater controls for freezer 

display doors because baseline freezer 

doors are required to have a controller 

due to the amount of power consumed 

by the anti-sweat heater wire. DOE 

requests comment on the proposed 

design options, specifically any heat 

transfer data for the improved glass 

packs detailed in chapter 5 of the TSD. 

The design options that DOE proposes 

for non-display doors include increased 

insulation thickness, changing the 

insulation material from baseline to a 

hybrid of polyurethane and VIP, 

changing the baseline framing material 

from wood to high-density 

polyurethane, improving the window’s 

glass pack, and adding an anti-sweat 

heater wire controller to the door. DOE 

requests comment on the proposed 

design options for non-display doors, 

and specifically requests comment on 

the manufacturer conversion 

investments required to update product 

designs and manufacturing lines in 

order to product compliant products; 

information regarding any changes in 

repair, maintenance, or installation 

costs of the window improvements 

detailed in chapter 5 of the TSD. DOE 

also requests comment on the 

technological feasibility of the panel 

options analyzed and whether the 

design options selected would cause 

any lessening of the utility or the 

performance of the walk-ins. 

See section IV.C.5.a and chapter 5 of 

the TSD for further details on the 

display and non-display door design 

options. 

18. Refrigeration System Design Options 

DOE is proposing to include the use 

of improved condenser coils as a design 

option, wherein the condenser coil 

increases by a certain percentage from 

its original size. After performing 

analytical calculations, DOE tentatively 

believes that increasing the coil size of 

the condenser would not require an 

increase in the coil size of the 

evaporator. However, DOE requests 

comment on this assumption, 

particularly from manufacturers that 

currently utilize larger condenser coils. 

DOE is proposing to use highefficiency condenser fan motors as a 

design option, and it is critical to 

accurately estimate the input power due 

to the energy savings associated with 

this option. DOE calculated the input 

power from the efficiency ratings 

provided. However, DOE received 

comments that this approach may not 

provide an accurate method to measure 

input power and requests feedback on 

how it should determine input power. 

DOE also considered a design option 

which modulates or adjusts the speed of 

the evaporator fans when the 

compressor is off. DOE is aware of the 

potential effects of evaporator fan 

control on food safety but has 

tentatively concluded that the controls 

it analyzed are limited (to 50 percent fan 

cycling or 50 percent fan speed when 

the compressor is off) such that food 

temperatures could be adequately 

maintained in either control case. DOE 

requests comment from interested 

parties as to whether food temperatures 

would be adequately maintained in the 

specific control cases it has analyzed, 

and, if not, what would be an 

appropriate control strategy. DOE 

particularly requests any data interested 

parties can provide to show the 

relationship between fan controls and 

food temperatures. DOE also seeks 

information on whether other 

components may be necessary to ensure 

food temperatures would be adequately 

maintained, such as extra thermostats 

located in certain areas of the walk-in. 

DOE has adjusted its analysis of the 

floating head pressure design option 

after taking commenters’ 

recommendations into account. DOE 

included components and analytical 

changes with respect to fan power, 

temperature differences, and SCT in 

response to stakeholder comments. DOE 

requests comment on its revised 

assumptions and implementation of this 

option, particularly regarding the cost to 

implement various floating head 

pressure control schemes and the energy 

savings that would be achieved. DOE 

requests comment on the technological 

feasibility of the panel options analyzed 

and whether the design options selected 

would cause any lessening of the utility 

or the performance of the walk-ins. DOE 

also requests information on any 

changes in repair, maintenance, or 

installation costs associated with the 

technologies needed to meet the 

proposed standards. 

See section IV.C.5.b and chapter 5 of 

the TSD for further details on the 

refrigeration system design options. 

19. Relative Equipment Sizing 

In the Energy Use Analysis, DOE 

calculates the expected energy 

consumption of the covered equipment, 

as installed. To do so, DOE makes 

certain assumptions about the relative 

sizing of refrigeration systems with 

envelopes, which determines how often 

the compressor runs during a day, 

which in turn affects the energy use of 

the equipment. For the NOPR analysis, 

DOE assumed that the runtime of the 

refrigeration system is 13.3 hours per 

day for coolers and 15 hours per day for 

freezers at full design point capacity and 

requests comment on this assumption. 

See section IV.E.1 for further details. 

20. Equipment Price Trends 

DOE assumes in its price forecasts for 

this NOPR that the real prices of walkin cooler and freezer equipment 

decrease slightly over time. DOE 

performed price trends sensitivity 

calculations to examine the dependence 

of the analysis results on different 

analytical assumptions. DOE invites 

comment on methods to improve its 

equipment price forecasting, as well as 

any data supporting alternate methods. 

For more details, see section IV.F.1. 

21. Refrigerant Charge Maintenance 

Costs 

DOE received comments on 

maintenance costs associated with 

refrigerant leakage and refrigerant 

charge and assumed a certain 

maintenance cost for the refrigeration 

system. DOE requests that interested 

parties submit data on refrigerant charge 

maintenance costs. See section IV.F.6 

for further details. 

22. Compliance Date of Standards 

DOE’s proposed standards will apply 

to products that are manufactured 

beginning on the date 3 years after the 

final rule is published unless DOE 

determines, by rule, that a 3-year period 

is inadequate, in which case DOE may 

extend the compliance date for that 

standard by an additional 2 years. (42 

U.S.C. 6314(f)(4)(B)) DOE proposes to 

provide 3 years for compliance with this 

standard, but seeks comment on 

whether it should consider a longer 

compliance date as authorized, and, if 

so, by how much. See section IV.F.9 for 

details. 

23. Base-Case Efficiency Distributions 

To accurately estimate the share of 

consumers who would likely be 

impacted by a standard at a particular 

efficiency level, DOE’s LCC analysis 

considers the projected distribution of 

product efficiencies that consumers 

purchase under the base case (i.e., the 

case without new energy efficiency 

standards). DOE examined the range of 

standard and optional equipment 

features offered by refrigeration 

manufacturers and estimated that for 

refrigeration systems, 75 percent of the 

equipment sold under the base case 

would be at DOE’s assumed baseline 

level—that is, the equipment would 

comply with the existing standards in 

EPCA, but have no additional features 

that improve efficiency. The remaining 

25 percent of equipment would have 

features that would increase its 

efficiency to a level commensurate with 


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55886 Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules 

the first design option in each 

equipment class. For envelope 

components, all base case shipments are 

assumed to have only a single EPCAcompliant efficiency level except for 

cooler display doors. For cooler display 

doors, shipments in the base case would 

be a mix of 80 percent EPCA-compliant 

equipment and 20 percent higher 

efficiency equipment. For both 

refrigeration systems and envelope 

components, DOE assumed that the 

base-case energy efficiency distribution 

would remain constant throughout the 

forecast period. DOE requests comment 

on its assumptions about base-case 

efficiency distributions. See sections 

IV.F.10 and IV.G.2 for details. 

24. Trial Standard Level Equations 

In this NOPR, DOE proposes standard 

levels for different classes of 

refrigeration systems. DOE expressed 

the AWEF for large capacity dedicated 

condensing systems as a single value 

and expressed the AWEF for the small 

capacity dedicated condensing systems 

as a linear equation normalized to the 

system gross capacity. DOE calculated a 

single minimum AWEF for each class of 

multiplex condensing systems. The 

methodology DOE used to develop the 

AWEF values and equations is detailed 

in appendix 10D of the TSD. DOE 

requests comment on the AWEF 

equations and the methodology for 

determining them. In particular, DOE 

asks interested parties to submit data on 

how the efficiency of typical 

refrigeration systems varies by capacity. 

Based on comments and additional data 

DOE receives on the NOPR, DOE may 

consider other methods of calculating 

the minimum AWEF associated with the 

TSLs for each equipment class. See 

section V.A.2 for details. 

25. Proposed Standard 

In this NOPR, DOE proposes TSL 4 as 

the energy conservation standard for 

equipment covered under this 

rulemaking. DOE proposes this standard 

because it tentatively believes that it 

represents the maximum improvement 

in energy efficiency that is 

technologically feasible and 

economically justified, and that the 

benefits outweigh the burdens. For a full 

description of the benefits and burdens 

of TSL 4, see section V.C. 

We seek comment, information and 

data on whether other combinations of 

standards for refrigeration units, panels, 

or doors can improve energy efficiency 

that is technologically feasible and 

economically justified, taking into 

consideration effects on the 

manufacturers and the end users of 

walk-in coolers and freezers. 

26. Product Attributes 

DOE requests comment on whether 

there are features or attributes of the 

more energy efficient walk-in coolers 

and freezers that manufacturers would 

produce to meet the standards in this 

proposed rule that might lessen the 

utility or performance of these products 

in current uses (i.e., restaurants, food 

service providers, grocery stores and 

convenience stores). An example of 

such an effect might be that grocers or 

restaurant operators would change 

where, how, how much and for how 

long food items would be stored or 

whether thicker panels would 

detrimentally reduce the refrigerated 

area of a walk-in making higher 

efficiency panels less desirable. DOE 

requests comment specifically on how 

any such effects should be weighed in 

the choice of standards for these walkin coolers and freezers for the final rule. 

27. Impact of Amended Standards on 

Future Shipments 

DOE welcomes stakeholder input and 

estimates on the effect of amended 

standards on future walk-in cooler and 

freezer shipments. We are seeking 

information on what factors drive the 

demand for walk-in coolers and freezers 

and whether those factors are likely to 

remain unchanged in the relevant 

analytic time period of 30 years. For 

example, a commenter submitted that 

70 percent of all restaurants and 90 

percent of all small restaurants fail due 

to insufficient up-front capital. In light 

of this information, are there better ways 

and data to project future shipments of 

walk-in coolers and freezers than the 

current method which is based on the 

number of buildings projected to house 

walk-in coolers and freezers? DOE also 

welcomes input and data on the 

demand elasticity estimates used in the 

analysis. 

28. Learning Impacts on Price Forecast 

for Future Shipments 

Currently, DOE projects future prices 

by subtracting the cost reductions 

associated with learning effects from the 

cost associated with the amended 

standards. DOE analyzes learning effects 

using PPI, a quality adjusted index of 

wholesale prices, as a proxy for price of 

commercial refrigerators. DOE is seeking 

input, and price data that could be used 

in place of PPI. Also DOE is seeking 

input on the magnitude of the price data 

and the cause of those price changes. 

29. Analytic Timeline 

For this rulemaking, DOE analyzed 

the effects of this proposal assuming 

that the walk-in coolers and freezers 

would be available to purchase starting 

2017 until 2047 and includes the useful 

life of the last unit sold, extending the 

analysis to 2073. DOE also undertook a 

sensitivity analysis using nine rather 

than 30 years of product shipments. The 

choice of a 30-year period is consistent 

with the DOE analysis for other 

products and commercial equipment. 

The choice of a 9-year period is a proxy 

for the timeline in EPCA for the review 

of certain energy conservation standards 

and potential revision of and 

compliance with such revised 

standards. We are seeking input, 

information and data on whether there 

are ways to refine the analytic timeline 

further. 

In particular, given that walk-in 

coolers and freezers are largely used by 

the food service industry, convenience 

stores and small grocers, we are seeking 

information on whether the turnover 

rates in the food service industry, 

convenience stores and small grocers 

affects the useful life of walk-in coolers 

and freezers. 

30. Markets for Used Walk-In Coolers 

and Freezers 

DOE is seeking information on 

whether there is a significant market for 

used walk-in coolers and freezers. Given 

the high turnover rate of food service 

industry (e.g., a commenter noted 70 to 

90 percent failure rates for restaurants), 

we are seeking to understand whether it 

is reasonable to assume that the useful 

life of the refrigeration system would be 

12 years and other components 15 years 

due to active used equipment markets. 

31. Small Businesses 

During the Framework and 

preliminary analysis public meetings, 

DOE received many comments 

regarding the potential impacts of 

amended energy conservation standards 

on small business manufacturers of 

walk-in coolers and freezers. DOE notes 

that the small businesses could be 

disproportionately affected by this 

standard because of the cost of testing, 

potential increase in materials and 

potential difficulty in obtaining 

financing. DOE seeks comment and, in 

particular, data, in its efforts to quantify 

the impacts of this rulemaking on small 

business manufacturers. 

32. Rebound Effect 

DOE assumed a rebound factor of one, 

or no effect, because walk-ins must cool 

their contents at all times and it is not 

possible for consumers to operate them 

more frequently. A rebound effect 

occurs when users operate higher 

efficiency equipment more frequently 

and/or for longer durations, thus 

offsetting estimated energy savings. DOE 


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seeks comment on this assumption and 

whether other factors should be 

considered in the rebound effect, such 

as a decision to buy a larger system due 

to increased lifetime costs savings, or 

money saved in electricity bills with 

more efficient walk-in coolers and 

freezers being used for other electricity 

consuming activities. 

33. Update to Social Cost of Carbon 

Values 

DOE solicits comment on the 

application of the new SCC values used 

to determine the social benefits of CO2 

emissions reductions over the 

rulemaking analysis period. The 

rulemaking analysis period covers from 

2017 to 2046 plus an additional 15 years 

to account for the lifetime of the 

equipment purchased between 2017 and 

2046. In particular, the agency solicits 

comment on the agency’s derivation of 

SCC values after 2050 where the agency 

applied the average annual growth rate 

of the SCC estimates in 2040–2050 

associated with each of the four sets of 

values. 

34. Cumulative Regulatory Burdens 

The agency seeks input on the 

cumulative regulatory burden that may 

be imposed on industry either from 

recently implemented rulemakings for 

this product class or other rulemakings 

that affect the same industry. 

VIII. Approval of the Office of the 

Secretary 

The Secretary of Energy has approved 

publication of today’s proposed rule. 

List of Subjects in 10 CFR Part 431 

Administrative practice and 

procedure, Confidential business 

information, Energy conservation, 

Imports, Intergovernmental relations, 

Reporting and recordkeeping 

requirements. 

Issued in Washington, DC, on August 29, 

2013. 

Mike Carr, 

Acting Assistant Secretary, Energy Efficiency 

and Renewable Energy. 

For the reasons set forth in the 

preamble, DOE proposes to amend part 

431 of chapter II of title 10, of the Code 

of Federal Regulations, as set forth 

below: 

PART 431—ENERGY EFFICIENCY 

PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL 

EQUIPMENT 

■ 1. The authority citation for part 431 

continues to read as follows: 

Authority: 42 U.S.C. 6291–6317. 

■ 2. Section 431.302 is amended by 

revising the definition for ‘‘Display 

door’’ and adding, in alphabetical order, 

definitions for ‘‘Freight door’’ and 

‘‘Passage door’’ to read as follows: 

§ 431.302 Definitions concerning walk-in 

coolers and freezers. 

* * * * * 

Display door means a door that: 

(1) Is designed for product display; or 

(2) Has 75 percent or more of its 

surface area composed of glass or 

another transparent material. 

* * * * * 

Freight door means a door that is not 

a display door and is equal to or larger 

than 4 feet wide and 8 feet tall. 

* * * * * 

Passage door means a door that is not 

a freight or display door. 

* * * * * 

■ 3. In § 431.304, revise paragraph (a) to 

read as follows: 

§ 431.304 Uniform test method for the 

measurement of energy consumption of 

walk-in coolers and walk-in freezers. 

(a) Scope. This section provides test 

procedures for measuring, pursuant to 

EPCA, the energy consumption of walkin coolers and walk-in freezers. 

* * * * * 

■ 4. In § 431.306, revise paragraph 

(a)(3), and add paragraphs (c), (d), (e), 

and (f) to read as follows: 

§ 431.306 Energy conservation standards 

and their effective dates. 

(a) * * * 

(3) Contain wall, ceiling, and door 

insulation of at least R–25 for coolers 

and R–32 for freezers, except that this 

paragraph shall not apply to: 

(i) Glazed portions of doors not to 

structural members and 

(ii) A walk-in cooler or walk-in freezer 

component if the component 

manufacturer has demonstrated to the 

satisfaction of the Secretary in a manner 

consistent with applicable requirements 

that the component reduces energy 

consumption at least as much as if such 

insulation requirements of subparagraph 

(a)(3) were to apply. 

(b) * * * 

(c) Walk-in cooler and freezer panels. 


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(d) Walk-in cooler and freezer display 

doors. 

Class descriptor Class 

Equations for 

maximum 

energy consumption 

(kWh/day)* 

Display Door, Medium Temperature ............................................................................................... DD.M 0.049 × Add + 0.39 

Display Door, Low Temperature ...................................................................................................... DD.L 0.33 × Add + 0.38 

*Add represents the surface area of the display door. 

(e) Walk-in cooler and freezer nondisplay doors. 

Class descriptor Class 

Equations for 

maximum 

energy consumption 

(kWh/day)* 

Passage Door, Medium Temperature ........................................................................... PD.M 0.0032 × And + 0.22 

Passage Door, Low Temperature ................................................................................. PD.L 0.14 × And + 4.0 

Freight Door, Medium Temperature .............................................................................. FD.M 0.0073 × And + 0.082 

Freight Door, Low Temperature .................................................................................... FD.L 0.11 × And + 5.4 

* And represents the surface area of the non-display door. 

(f) Walk-in cooler and freezer 

refrigeration systems. 

Class descriptor Class 

Equations for 

minimum AWEF 

(Btu/W–h)* 

Dedicated Condensing, Medium Temperature, Indoor System, < 9,000 Btu/h Capacity ............... DC.M.I, < 9,000 2.63 × 10¥4 × Q + 

4.53 

Dedicated Condensing, Medium Temperature, Indoor System, ≥ 9,000 Btu/h Capacity ............... DC.M.I, ≥ 9,000 6.90 

Dedicated Condensing, Medium Temperature, Outdoor System, < 9,000 Btu/h Capacity ............ DC.M.O, < 9,000 1.34 × 10¥3 × Q + 

0.12 

Dedicated Condensing, Medium Temperature, Outdoor System, ≥ 9,000 Btu/h Capacity ............ DC.M.O, ≥ 9,000 12.21 

Dedicated Condensing, Low Temperature, Indoor System, < 9,000 Btu/h Capacity ..................... DC.L.I, < 9,000 1.93 × 10¥4 × Q + 

1.89 

Dedicated Condensing, Low Temperature, Indoor System, ≥ 9,000 Btu/h Capacity ..................... DC.L.I, ≥ 9,000 3.63 

Dedicated Condensing, Low Temperature, Outdoor System, < 9,000 Btu/h Capacity .................. DC.L.O, < 9,000 5.70 × 10¥4 × Q + 

1.02 

Dedicated Condensing, Low Temperature, Outdoor System, ≥ 9,000 Btu/h Capacity .................. DC.L.O, ≥ 9,000 6.15 

Multiplex Condensing, Medium Temperature .................................................................................. MC.M 10.74 

Multiplex Condensing, Low Temperature ........................................................................................ MC.L 5.53 

* Q represents the system gross capacity as calculated by the procedures set forth in AHRI 1250. 

[FR Doc. 2013–21530 Filed 9–10–13; 8:45 am] 

BILLING CODE 6450–01–P 


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