Vol. 79 Tuesday, 

No. 106 June 3, 2014 

Part III 

Department of Energy 

10 CFR Part 431 

Energy Conservation Program: Energy Conservation Standards for Walk-In 

Coolers and Freezers; Final Rule 


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32050 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

DEPARTMENT OF ENERGY 

10 CFR Part 431 

[Docket Number 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: Final rule. 

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 

standards would be technologically 

feasible and economically justified, and 

would save a significant amount of 

energy. In this final rule, DOE is 

adopting more-stringent energy 

conservation standards for some classes 

of walk-in cooler and walk-in freezer 

components and has determined that 

these standards are technologically 

feasible and economically justified and 

would result in the significant 

conservation of energy. 

DATES: The effective date of this rule is 

August 4, 2014. Compliance with the 

amended standards established for 

walk-in coolers and walk-in freezers in 

this final rule is required on June 5, 

2017. 

ADDRESSES: The docket, which includes 

Federal Register notices, public meeting 

attendee lists and transcripts, 

comments, and other supporting 

documents/materials, is available for 

review at www.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://www.regulations.gov/ 

#!docketDetail;D=EERE-2010-BT-STD0003. The regulations.gov Web page will 

contain simple instructions on how to 

access all documents, including public 

comments, in the docket. 

For further information on how to 

review the docket, contact Ms. Brenda 

Edwards at (202) 586–2945 or by email: 

Brenda.Edwards@ee.doe.gov. 

FOR FURTHER INFORMATION CONTACT: John 

Cymbalsky, U.S. Department of Energy, 

Office of Energy Efficiency and 

Renewable Energy, Building 

Technologies Program, EE–5B, 1000 

Independence Avenue SW., 

Washington, DC, 20585–0121. 

Telephone: (202) 287–1692. Email: 

walk-in_coolers_and_walkin_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 Final Rule and Its Benefits 

A. Benefits and Costs to Customers 

B. Impact on Manufacturers 

C. National Benefits 

D. Conclusion 

II. Introduction 

A. Authority 

B. Background 

1. Current Standards 

2. History of Standards Rulemaking for 

Walk-In Coolers and Walk-In Freezers 

III. General Discussion 

A. Component Level Standards 

B. Test Procedures and Metrics 

1. Panels 

2. Doors 

3. Refrigeration 

C. Certification, Compliance, and 

Enforcement 

D. Technological Feasibility 

1. General 

2. Maximum Technologically Feasible 

Levels 

E. Energy Savings 

1. Determination of Savings 

2. Significance of Savings 

F. Economic Justification 

1. Specific Criteria 

a. Economic Impact on Manufacturers and 

Commercial Customers 

b. Savings in Operating Costs Compared to 

Increase in Price 

c. Energy Savings 

d. Lessening of Utility or Performance of 

Equipment 

e. Impact of Any Lessening of Competition 

f. Need of the Nation to Conserve Energy 

g. Other Factors 

2. Rebuttable Presumption 

IV. Methodology and Discussion of 

Comments 

A. General Rulemaking Issues 

1. Trial Standard Levels 

2. Rulemaking Timeline 

B. Market and Technology Assessment 

1. Equipment Included in This Rulemaking 

a. Panels and Doors 

b. Refrigeration Systems 

2. Equipment Classes 

a. Panels and Doors 

b. Refrigeration Systems 

3. Technology Assessment 

C. Screening Analysis 

1. Panels and Doors 

2. Refrigeration Systems 

D. Engineering Analysis 

1. Representative Equipment for Analysis 

a. Panels and Doors 

b. Refrigeration 

2. Refrigerants 

3. Cost Assessment Methodology 

a. Teardown Analysis 

b. Cost Model 

c. Manufacturing Production Cost 

d. Manufacturing Markup 

e. Shipping Costs 

4. Energy Consumption Model 

a. Panels and Doors 

b. Refrigeration Systems 

5. Baseline Specifications 

a. Panels and Doors 

b. Refrigeration 

6. Design Options 

a. Panels and Doors 

b. Refrigeration 

E. Markups Analysis 

F. Energy Use Analysis 

1. Sizing Methodology for the Refrigeration 

System 

2. Oversize Factors 

G. Life-Cycle Cost and Payback Period 

Analysis 

1. Equipment Cost 

2. Installation Costs 

3. Maintenance and Repair Costs 

4. Annual Energy Consumption 

5. Energy Prices 

6. Energy Price Projections 

7. Equipment Lifetime 

8. Discount Rates 

9. Compliance Date of Standards 

10. Base-Case Efficiency Distributions 

11. Inputs To Payback Period Analysis 

12. Rebuttable-Presumption Payback 

Period 

H. Shipments 

a. Share of Shipments and Stock by 

Equipment Class 

2. Impact of Standards on Shipments 

I. National Impact Analysis—National 

Energy Savings and Net Present Value 

1. Forecasted Efficiency in the Base Case 

and Standards Cases 

2. National Energy Savings 

3. Net Present Value of Customer Benefit 

J. Customer Subgroup Analysis 

K. Manufacturer Impact Analysis 

1. Overview 

2. Government Regulatory Impact Model 

a. Government Regulatory Impact Model 

Key Inputs 

b. Government Regulatory Impact Model 

Scenarios 

3. Discussion of Comments 

a. Refrigerants 

b. Installation Contractors 

c. Small Manufacturers 

d. Mark Up Scenarios 

e. Number of Small Businesses 

L. Emissions Analysis 

M. Monetizing Carbon Dioxide and Other 

Emissions Impacts 

1. Social Cost of Carbon 

a. Monetizing Carbon Dioxide Emissions 

b. Development of Social Cost of Carbon 

Values 

c. Current Approach and Key Assumptions 

2. Valuation of Other Emissions 

Reductions 

N. Utility Impact Analysis 


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Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 32051 

1All 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). 

2For editorial reasons, upon codification in the 

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

O. Employment Impact Analysis 

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. Customer Subgroup Analysis 

c. Rebuttable Presumption Payback 

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. Energy Savings 

b. Net Present Value of Customer Costs and 

Benefits 

c. Indirect 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. Summary of National Economic Impact 

8. Other Factors 

C. Conclusions 

1. Benefits and Burdens of Trial Standard 

Levels Considered for Walk-in Coolers 

and Walk-in Freezers 

2. Summary of Benefits and Costs 

(Annualized) of the Standards 

VI. Procedural Issues and Regulatory Review 

A. Review Under Executive Orders 12866 

and 13563 

B. Review Under the Regulatory Flexibility 

Act 

1. Description and Estimated Number of 

Small Entities Regulated 

2. Description and Estimate of Compliance 

Requirements 

3. Duplication, Overlap, and Conflict With 

Other Rules and Regulations 

4. Significant Alternatives to the Rule 

C. Review Under the Paperwork Reduction 

Act 

D. Review Under the National 

Environmental Policy Act of 1969 

E. Review Under Executive Order 13132 

F. Review Under Executive Order 12988 

G. Review Under the Unfunded Mandates 

Reform Act of 1995 

H. Review Under the Treasury and General 

Government Appropriations Act, 1999 

I. Review Under Executive Order 12630 

J. Review Under the Treasury and General 

Government Appropriations Act, 2001 

K. Review Under Executive Order 13211 

L. Review Under the Information Quality 

Bulletin for Peer Review 

M. Congressional Notification 

VII. Approval of the Office of the Secretary 

I. Summary of the Final Rule and Its 

Benefits 

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.1 2 (42 U.S.C. 6311(1), (20), 

6313(f) and 6314(a)(9)) Pursuant to 

EPCA, any new or amended energy 

conservation standard that DOE 

prescribes for certain equipment, such 

as walk-in coolers and walk-in freezers 

(collectively, ‘‘walk-ins’’ or ‘‘WICFs’’), 

shall be designed to achieve the 

maximum improvement in energy 

efficiency that DOE determines is both 

technologically feasible and 

economically justified. (42 U.S.C. 

6295(o)(2)(A)) Furthermore, the new or 

amended standard must result in the 

significant conservation of energy. (42 

U.S.C. 6295(o)(3)(B)) In accordance with 

these and other statutory provisions 

discussed in this notice, DOE is 

adopting amended energy conservation 

standards for the main components of 

walk-in coolers and walk-in freezers 

(walk-ins), refrigeration systems, panels, 

and doors. These standards are 

expressed in terms of annual walk-in 

energy factor (AWEF) for the walk-in 

refrigeration systems, R-value for walkin panels, and maximum energy 

consumption (MEC) for walk-in doors. 

These standards are shown in Table I.1. 

These standards apply to all equipment 

listed in Table I.1 and manufactured in, 

or imported into, the United States once 

the compliance date listed above is 

reached. 

TABLE I.1—ENERGY CONSERVATION STANDARDS FOR WALK-IN COOLERS AND WALK-IN FREEZERS

Class descriptor Class Standard level 

Refrigeration Systems Minimum AWEF (Btu/W-h) * 

Dedicated Condensing, Medium Temperature, Indoor System, <9,000 Btu/h Capacity ......... DC.M.I, <9,000 ... 5.61 

Dedicated Condensing, Medium Temperature, Indoor System, ≥9,000 Btu/h Capacity ......... DC.M.I, ≥9,000 ... 5.61 

Dedicated Condensing, Medium Temperature, Outdoor System, <9,000 Btu/h Capacity ...... DC.M.O, <9,000 7.60 

Dedicated Condensing, Medium Temperature, Outdoor System, ≥9,000 Btu/h Capacity ...... DC.M.O, ≥9,000 7.60 

Dedicated Condensing, Low Temperature, Indoor System, <9,000 Btu/h Capacity ............... DC.L.I, <9,000 .... 5.93 × 10¥5 × Q + 2.33 

Dedicated Condensing, Low Temperature, Indoor System, ≥9,000 Btu/h Capacity ............... DC.L.I, ≥9,000 .... 3.10 

Dedicated Condensing, Low Temperature, Outdoor System, <9,000 Btu/h Capacity ............. DC.L.O, <9,000 .. 2.30 × 10¥4 × Q + 2.73 

Dedicated Condensing, Low Temperature, Outdoor System, ≥9,000 Btu/h Capacity ............. DC.L.O, ≥9,000 .. 4.79 

Multiplex Condensing, Medium Temperature ........................................................................... MC.M .................. 10.89 

Multiplex Condensing, Low Temperature ................................................................................. MC.L ................... 6.57 

Panels Minimum R-value (h-ft2-°F/Btu) 

Structural Panel, Medium Temperature .................................................................................... SP.M .................. 25 

Structural Panel, Low Temperature .......................................................................................... SP.L ................... 32 

Floor Panel, Low Temperature ................................................................................................. FP.L .................... 28 

Non-Display Doors Maximum energy consumption 

(kWh/day) ** 

Passage Door, Medium Temperature ...................................................................................... PD.M .................. 0.05 × And + 1.7 

Passage Door, Low Temperature ............................................................................................. PD.L ................... 0.14 × And + 4.8 

Freight Door, Medium Temperature ......................................................................................... FD.M .................. 0.04 × And + 1.9 

Freight Door, Low Temperature ............................................................................................... FD.L ................... 0.12 × And + 5.6 


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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 final rule 

TSD. 

4All monetary values in this section are 

expressed in 2013 dollars and are discounted to 

2014. 

TABLE I.1—ENERGY CONSERVATION STANDARDS FOR WALK-IN COOLERS AND WALK-IN FREEZERS—Continued 

Class descriptor Class Standard level 

Display Doors Maximum Energy 

Consumption (kWh/day) † 

Display Door, Medium Temperature ......................................................................................... DD.M .................. 0.04 × Add + 0.41 

Display Door, Low Temperature ............................................................................................... DD.L ................... 0.15 × Add + 0.29 

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

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

† Add represents the surface area of the display door. 

A. Benefits and Costs to Customers 

Table I.2 presents DOE’s evaluation of 

the economic impacts of these standards 

on customers of walk-in coolers and 

walk-in freezers, as measured by the 

average life-cycle cost (LCC) savings and 

the median payback period (PBP). The 

average LCC savings are positive for all 

equipment classes for which customers 

are impacted by the standards. 

TABLE I.2—IMPACTS OF THE FINAL RULE’S STANDARDS ON CUSTOMERS OF WALK-IN COOLERS AND WALK-IN FREEZERS

Equipment class Average LCC savings 

2013$ 

Median payback period 

Years 

Refrigeration System Class * 

DC.M.I * .................................................................................................................................... 5942 3.5 

DC.M.O * .................................................................................................................................. 6533 2.2 

DC.L.I * ..................................................................................................................................... 2078 1.6 

DC.L.O * ................................................................................................................................... 5942 3.5 

MC.M ....................................................................................................................................... 547 3.1 

MC.L ........................................................................................................................................ 362 3.1 

Panel Class 

SP.M ........................................................................................................................................

SP.L .........................................................................................................................................

FP.L .........................................................................................................................................

Non-Display Door Class 

PD.M ........................................................................................................................................

PD.L .........................................................................................................................................

FD.M ........................................................................................................................................

FD.L .........................................................................................................................................

Display Door Class 

DD.M ........................................................................................................................................ 143 7.3 

DD.L ......................................................................................................................................... 902 5.4 

Note: ‘‘—’’ indicates no impact because standards are set at the baseline level. 

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

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 (2013) 

through the end of the analysis period 

(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 INPV for 

manufacturers of walk-in coolers and 

walk-in freezers is $1,291 million in 

2012$. Under these standards, DOE 

expects the industry net present value to 

change by ¥4.10 percent to 6.21 

percent. Total industry conversion costs 

are expected to total $33.61 million. 

DOE does not expect any plant closings 

or significant loss of employment to 

result from these standards. 

C. National Benefits 4

DOE’s analyses indicate that these 

standards would save a significant 

amount of energy. The lifetime savings 

for walk-in coolers and walk-in freezers 

purchased in the 30-year period that 

begins in the year of compliance with 

amended standards (2017–2046) amount 

to 3.149 quadrillion British thermal 

units (quads). The annual savings in 

2030 (0.10 quads) is equivalent to 0.5 

percent of total U.S. commercial energy 

use in 2014. 

The cumulative net present value 

(NPV) of total consumer costs and 

savings of these standards for walk-in 

coolers and walk-in freezers ranges from 

$3.98 billion (at a 7-percent discount 

rate) to $9.90 billion (at a 3-percent 

discount rate). This NPV expresses the 

estimated total value of future operating 

cost savings minus the estimated 


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5A metric ton is equivalent to 1.1 short tons. 

Results for NOX and Hg are presented in short tons. 

6 DOE calculated emissions reductions relative to 

the Annual Energy Outlook 2013 (AEO 2013) 

Reference case, which generally represents current 

legislation and environmental regulations for which 

implementing regulations were available as of 

December 31, 2012. 

7Technical Update of the Social Cost of Carbon 

for Regulatory Impact Analysis Under Executive 

Order 12866. Interagency Working Group on Social 

Cost of Carbon, United States Government. May 

2013; revised November 2013. http://

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

inforeg/technical-update-social-cost-of-carbon-forregulator-impact-analysis.pdf. 

8 DOE is investigating the valuation of the other 

emissions reductions. 

9 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 2014, 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.4. From the present value, DOE 

then calculated the fixed annual payment over a 30- 

year period (2017 through 2046) 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. 

increased equipment costs for 

equipment purchased in 2016–2047. 

In addition, these standards are 

expected to have significant 

environmental benefits. The energy 

savings would result in cumulative 

emission reductions of approximately 

159.2 million metric tons (Mt) 5 of 

carbon dioxide (CO2), 833 thousand tons 

of methane, 229 thousand tons of sulfur 

dioxide (SO2), 254.4 thousand tons of 

nitrogen oxides (NOX), 3.5 thousand 

tons of nitrous oxide (N2O), and 0.27 

tons of mercury (Hg).6 Through 2030, 

the cumulative emissions reductions of 

CO2 amount to 61.6 Mt. 

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 a recent Federal 

interagency process.7 The derivation of 

the SCC values is discussed in section 

IV.M. Using discount rates appropriate 

for each set of SCC values, DOE 

estimates that the net present monetary 

value of the CO2 emissions reductions is 

between $1.2 billion and $16.3 billion. 

DOE also estimates that the net present 

monetary value of the NOX emissions 

reductions is $183.5 million at a 7- 

percent discount rate, and $366.1 

million at a 3-percent discount rate.8

Table I.3 summarizes the national 

economic costs and benefits expected to 

result from these standards for walk-in 

coolers and walk-in freezers. 

TABLE I.3—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF WALK-IN COOLERS AND WALK-IN FREEZERS

ENERGY CONSERVATION STANDARDS

Category * Present Value 

Billion 2013$ 

Discount Rate 

(percent) 

Benefits 

Operating Cost Savings ................................................................................................................................... 9.5 7 

19.7 3 

CO2 Reduction Monetized Value ($12.0/t case) ** .......................................................................................... 1.2 5 

CO2 Reduction Monetized Value ($40.5/t case) ** .......................................................................................... 5.3 3 

CO2 Reduction Monetized Value ($62.4/t case) ** .......................................................................................... 8.4 2.5 

CO2 Reduction Monetized Value ($119/t case) ** ........................................................................................... 16.3 3 

NOX Reduction Monetized Value (at $2,684/ton) ** ........................................................................................ 0.2 7 

0.4 3 

Total Benefits † ................................................................................................................................................ 15.0 7 

25.4 3 

Costs 

Incremental Installed Costs ............................................................................................................................. 5.5 7 

9.8 3 

Net Benefits 

Including CO2 and NOX Reduction Monetized Value † ................................................................................... 9.5 7 

15.6 3 

* This table presents the costs and benefits associated with walk-in coolers and walk-in freezers shipped in 2017–2046. These results include 

benefits to customers which accrue after 2046 from the equipment purchased in 2017–2046. The results account for the incremental variable and 

fixed costs incurred by manufacturers due to the amended standard, some of which may be incurred in preparation for this final rule. 

** The CO2 values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the updated SCC values. The 

first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporates 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% and 7% cases are derived using the series corresponding to average SCC with 3-percent discount rate. 

The benefits and costs of these 

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 operating the 

equipment (consisting primarily of 

operating cost savings from using less 

energy, minus increases in equipment 

purchase and installation costs, which 

is another way of representing consumer 

NPV, plus (2) the annualized monetary 

value of the benefits of emission 

reductions, including CO2 emission 

reductions.9

Although adding the value of 

consumer savings to the values of 

emission reductions provides a valuable 

perspective, two issues should be 

considered. First, the national operating 

cost savings are domestic U.S. consumer 

monetary savings that occur as a result 

of market transactions, while the value 


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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-in coolers and walk-in freezers 

shipped in 2017–2046. The SCC values, 

on the other hand, reflect the present 

value of all future climate-related 

impacts resulting from the emission of 

one metric ton of carbon dioxide in each 

year. These impacts continue well 

beyond 2100. 

Estimates of annualized benefits and 

costs of these standards are shown in 

Table I.4. 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 in this rule is $511 

million per year in increased equipment 

costs, while the benefits are $879 

million per year in reduced equipment 

operating costs, $287 million in CO2

reductions, and $16.93 million in 

reduced NOX emissions. In this case, the 

net benefit amounts to $671 million per 

year. Using a 3-percent discount rate for 

all benefits and costs and the average 

SCC series, the cost of the standards in 

this rule is $528 million per year in 

increased equipment costs, while the 

benefits are $1,064 million per year in 

reduced operating costs, $287 million in 

CO2 reductions, and $19.82 million in 

reduced NOX emissions. In this case, the 

net benefit amounts to $842 million per 

year. 

TABLE I.4—ANNUALIZED BENEFITS AND COSTS OF AMENDED STANDARDS FOR WALK-IN COOLERS AND WALK-IN

FREEZERS

Discount rate 

Million 2013$/year 

Primary 

estimate * 

Low net 

benefits 

estimate * 

High net 

benefits 

estimate * 

Benefits 

Operating Cost Savings ....................................................................... 7% .................... 879 ................... 854 ................... 917. 

3% .................... 1064 ................. 1027 ................. 1115. 

CO2 Reduction at ($12.08/t case) ** .................................................... 5% .................... 86 ..................... 86 ..................... 86. 

CO2 Reduction at ($40.5/t case) ** ...................................................... 3% .................... 287 ................... 287 ................... 287. 

CO2 Reduction at ($62.4/t case) ** ...................................................... 2.5% ................. 420 ................... 420 ................... 420. 

CO2 Reduction at ($119/t case) ** ....................................................... 3% .................... 884 ................... 884 ................... 884. 

NOX Reduction at ($2,684/ton) ** ........................................................ 7% .................... 16.93 ................ 16.93 ................ 16.93. 

3% .................... 19.82 ................ 19.82 ................ 19.82. 

Total Benefits † .................................................................................... 7% plus CO2

range.

981 to 1,780 ..... 957 to 1,755 ..... 1,020 to 1,818. 

7% .................... 1,183 ................ 1,158 ................ 1,221. 

3% plus CO2

range.

1,169 to 1,968 .. 1,133 to 1,931 .. 1,221 to 2,019. 

3% .................... 1,371 ................ 1,334 ................ 1,422. 

Costs 

Incremental Equipment Costs .............................................................. 7% .................... 511 ................... 501 ................... 522. 

¥3% ................. 528 ................... 515 ................... 541. 

Net Benefits 

Total † ................................................................................................... 7% plus CO2

range.

470 to 1,269 ..... 456 to 1,255 ..... 498 to 1,296. 

7% .................... 671 ................... 657 ................... 699. 

3% plus CO2

range.

641 to 1,440 ..... 617 to 1,416 ..... 680 to 1,478. 

3% .................... 842 ................... 818 ................... 881. 

* This table presents the annualized costs and benefits associated with walk-in coolers and walk-in freezers shipped in 2017–2046. These results include benefits to customers which accrue after 2046 from the equipment purchased in 2017–2046. The results account for the incremental variable and fixed costs incurred by manufacturers due to the amended standard, some of which may be incurred in preparation for the 

final rule. The primary, low, and high estimates utilize projections of energy prices from the AEO 2013 Reference case, Low Estimate, and High 

Estimate, respectively. In addition, incremental equipment costs reflect a medium decline rate for projected equipment price trends in the Primary 

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

price trends in the High Benefits Estimate. The methods used to derive projected price trends are explained in section IV.I. 

** The CO2 values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the updated SCC values. The 

first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE 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, which is the $39.7/t CO2 reduction case. 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. 

D. Conclusion 

Based on the analyses culminating in 

this final rule, DOE found the benefits 

to the nation from the standards (energy 

savings, consumer LCC savings, positive 

NPV of consumer benefit, and emission 

reductions) outweigh the burdens (loss 

of INPV and LCC increases for some 

users of this equipment). DOE has 

concluded that the standards in this 

final rule represent the maximum 


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10All 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). 

11For editorial reasons, upon codification in the 

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

improvement in energy efficiency that is 

technologically feasible and 

economically justified, and would result 

in significant conservation of energy. 

(42 U.S.C. 6295(o), 6316(e)) 

II. Introduction 

The following section briefly 

discusses the statutory authority 

underlying this final rule, as well as 

some of the relevant historical 

background related to the establishment 

of standards for walk-in coolers and 

walk-in freezers. 

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.10 11 (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 the Energy Independence 

and Security Act of 2007, Public Law 

110–140 (December 19, 2007) (‘‘EISA’’), 

and those established by DOE in a 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 

7. Other factors the Secretary of 

Energy (Secretary) considers relevant. 

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

6316(a)) 

DOE does not generally 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 this 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, 

Sec. 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 

codified this amendment into its 

regulations on October 23, 2013, at 78 

FR 62988. 

Since the promulgation of the 

amendment, 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 


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6313(f)(6) and that the applicable 

insulation requirements did not apply to 

the RollSeal doors HH Technologies 

identified. Nothing in this 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 equipment designed and 

marketed exclusively for medical, 

scientific, or research purposes. (42 

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

prescriptive standards for walk-ins 

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 

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

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

authorized DOE 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 Walk-In 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 


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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-ins, 

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 existing and 

potential new equipment classes for 

walk-in coolers and walk-in freezers, 

characterized the markets for this 

equipment, and reviewed techniques 

and approaches for improving its 

efficiency; 

• A screening analysis reviewed 

technology options to improve the 

efficiency of walk-in coolers and walkin 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 walk-in freezers; 

• An energy use analysis estimated 

the annual energy use of walk-in coolers 

and walk-in freezers; 

• A markups analysis converted 

estimated MSPs derived from the 

engineering analysis to customer 

purchase prices; 

• A life-cycle cost analysis calculated, 

for individual customers, the 

discounted savings in operating costs 

throughout the estimated average life of 

walk-in coolers and walk-in 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 would 

take customers to recover the higher 

purchase price of more energy efficient 

equipment through lower operating 

costs; 

• A shipments analysis estimated 

shipments of walk-in coolers and walkin freezers over the time period 

examined in the analysis; 

• A national impact analysis (NIA) 

assessed the national energy savings 

(NES), and the national NPV of total 

customer costs and savings, expected to 

result from specific, potential energy 

conservation standards for walk-in 

coolers and walk-in freezers; and 

• A manufacturer impact analysis 

(MIA) assessed the potential effects on 

manufacturers of amended 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 

resolution of the issues in this 

rulemaking as they pertain to walk-ins. 

This final rule 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.) 

On September 11, 2013, DOE 

published a notice of proposed 

rulemaking (NOPR) in this proceeding 

(September 2013 NOPR). 78 FR 55781. 

In the September 2013 NOPR, DOE 

addressed, in detail, the comments 

received in earlier stages of rulemaking, 

and proposed new energy conservation 

standards for walk-ins. In conjunction 

with the September 2013 NOPR, DOE 

also published on its Web site the 

complete technical support document 

(TSD) for the proposed rule, which 

incorporated the analyses DOE 

conducted and technical documentation 

for each analysis. Also published on 

DOE’s Web site were the engineering 

analysis spreadsheets, the LCC 

spreadsheet, and the national impact 

analysis standard spreadsheet; these can 

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

.gov/buildings/appliance_standards/

rulemaking.aspx/ruleid/30. 

The standards DOE proposed for 

walk-in coolers and walk-in freezers are 

shown in Table II.1. 

BILLING CODE 6450–01–P 


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In the September 2013 NOPR, in 

addition to seeking comments generally 

on its proposal, DOE identified a 

number of specific issues on which it 

was particularly interested in receiving 

comments and views of interested 

parties, which were detailed in section 

VII.E of that notice. 78 FR at 55882– 

55887 (September 11, 2013) After the 

publication of the September 2013 

NOPR, DOE received written comments 

on these and other issues. DOE also held 

a public meeting in Washington, DC, on 

October 9, 2013, to hear oral comments 

on, and solicit information relevant to, 

the proposed rule. The comments on the 

NOPR are addressed in this document. 

III. General Discussion 

A. Component Level Standards 

In the NOPR, DOE proposed 

component-level standards for walk-in 

coolers and freezers, in order to ensure 

accurate testing and compliance. 

Specifically, DOE proposed to regulate 

separately three main components of a 

walk-in: Panels, doors, and refrigeration 

systems. See 78 FR at 55822 (September 

11, 2013). DOE received comments from 

a number of different entities. A list of 

these entities is included in Table III.1 

below. 

TABLE III.1—INTERESTED PARTIES WHO COMMENTED ON THE WICF NOPR 

Commenter Acronym Affiliation Comment number 

(docket reference) 

Air Conditioning Contractors of America ............................... ACCA ..................................... Trade Association .................. 119 

Air-Conditioning, Heating, and Refrigeration Institute ........... AHRI ...................................... Trade Association .................. 083, 114 

Alex Milgroom ........................................................................ Milgroom ................................ Individual ............................... 090 

American Panel Corporation ................................................. APC, American Panel ........... Manufacturer ......................... 099 

Architectural Testing, Inc. ...................................................... AT .......................................... Manufacturer ......................... 111 

Arctic Industries, Inc. ............................................................. Arctic ...................................... Manufacturer ......................... 117 

Appliance Standards Awareness Project, American Council 

for an Energy Efficient Economy, and Natural Resources 

Defense Council.

ASAP, ACEEE, NRDC 

(ASAP et al.).

Efficiency Organization .......... 113 

Bally Refrigerated Boxes, Inc. ............................................... Bally ....................................... Manufacturer ......................... 102 

California Investor Owned Utilities ........................................ CA IOUs ................................ Utility Association .................. 089, 110 

Center for the Study of Science Cato Institute ..................... Cato, CSS ............................. Efficiency Organization .......... 106 

Crown Tonka, ThermalRite and International Cold Storage ICS et al. ............................... Manufacturer ......................... 100 

ebm-papst Inc. ....................................................................... ebm-papst .............................. Component/Material Supplier 092 

Hillphoenix ............................................................................. Hillphoenix ............................. Manufacturer ......................... 107 

Hussmann Corporation .......................................................... Hussmann ............................. Manufacturer ......................... 093 

Imperial-Brown ....................................................................... IB ........................................... Manufacturer ......................... 098 

KeepRite Refrigeration .......................................................... KeepRite ................................ Manufacturer ......................... 105 

Lennox International Inc./Heatcraft Refrigeration Products, 

LLC.

Lennox ................................... Manufacturer ......................... 109 

Louisville Cooler .................................................................... Louisville Cooler .................... Manufacturer ......................... 081 

Manitowoc Company ............................................................. Manitowoc ............................. Manufacturer ......................... 108 

National Coil Company .......................................................... NCC ....................................... Component/Material Supplier 096 

National Restaurant Association ........................................... NRA ....................................... Consumer Advocate .............. 112 

New York State Office of the Attorney General .................... AGNY .................................... State Official/Agency ............. 116 

Nor-Lake, Inc. ........................................................................ Nor-Lake ................................ Manufacturer ......................... 115 

North American Association of Food Equipment Manufacturers.NAFEM .................................. Consumer Advocate .............. 118 

Northwest Energy Efficiency Alliance and Northwest Power 

and Conservation Council.

NEEA, NPCC (NEEA et al.) .. Efficiency Organization .......... 101 

Natural Resources Defense Council, Environmental Defense Fund, Union of Concenrned Scientists, Institute for 

Policy Integrity.

NRDC, EDC, UCS, IPI 

(NRDC et al.).

Efficiency Organization .......... 094 

Robert Kopp .......................................................................... Kopp ...................................... Individual ............................... 080 

Society of American Florists .................................................. SAF ........................................ Consumer Advocate .............. 103 

Suzanne Jaworowski ............................................................. Jaworowski ............................ Individual ............................... 074 

The Mercatus Center at George Mason University .............. Mercatus, Mercatus Center ... Efficiency Organization .......... 091 

THERMO–KOOL/Mid-South Industries, Inc. ......................... Thermo-Kool .......................... Manufacturer ......................... 097 

U.S. Chamber of Commerce ................................................. US Chamber of Commerce ... Regional Agency/Association 095 

U.S. Cooler—Division of Craig Industries Inc ....................... US Cooler .............................. Manufacturer ......................... 075, 104 

Heatcraft Refrigeration Products, LLC .................................. Heatcraft ................................ Manufacturer ......................... * 

Honeywell .............................................................................. Honeywell .............................. Manufacturer ......................... * 

SmithBucklin Corporation ...................................................... SmithBucklin .......................... Manufacturer ......................... * 

Heating, Air-Conditioning & Refrigeration Distributors International.HARDI ................................... Manufacturer ......................... * 

Heat Transfer Products Group .............................................. HT, Heat Transfer ................. Manufacturer ......................... * 

The Danfoss Group ............................................................... Danfoss ................................. Component/Material Supplier * 

* These commenters were present at the public meeting but did not submit written comments. 

DOE received several comments 

supporting its component-based 

approach to setting standards for walkins. Nor-Lake, Kysor, and Louisville 

Cooler agreed with this approach. (NorLake, No. 115 at p. 1, Kysor, Public 

Meeting Transcript, No. 88 at p. 40, and 

Louisville Cooler, No. 81 at p. 1) Bally, 

IB, and ICS commented that componentlevel standards were practical. (Bally, 

No. 102 at p. 1, IB, No. 98 at p. 1, and 

Hillphoenix, No. 107 at p. 2) ACCA 

notes that component-level standards 

simplify the compliance burden for 

assemblers. (ACCA, No. 119 at p. 2) US 

Cooler also agreed with the component 

approach, noting that the refrigeration 

industry is well established, and adding 


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that a component-level approach will 

give US Cooler more flexibility to meet 

the proposed requirements. (US Cooler, 

No. 88 at p. 51) ASAP and the CA IOUs 

agreed with the component performance 

approach for panels and doors. (ASAP, 

Public Meeting Transcript, No. 88 at p. 

16 and CA IOUs, Public Meeting 

Transcript, No. 88 at p. 30) 

DOE received additional comments 

concerning how WICF component 

standards could be set. Thermo-Kool 

commented that while component level 

standards were feasible, components 

added to doors such as windows and 

heater wires, among others, should be 

regulated separately—it added that 

doors should be regulated along with 

wall and ceiling panels. (ThermoKool, 

No. 97 at p. 1) Hillphoenix commented 

that standards for panels, walls, 

ceilings, and floors should also include 

the door panel. (Hillphoenix, No. 107 at 

p. 2) Bally noted that setting separate 

standards for windows would eliminate 

the need for door manufacturers to test 

the same door twice—i.e. with and 

without windows. (Bally, No. 102 at p. 

5) APC commented that electrical 

components, such as vision windows, 

heater wires, relief vents, and 

temperature alarms, should have 

separate standards and not be included 

in the analysis of non-display doors. 

(APC, No. 99 at p. 2) The CA IOUs 

commented that separate standards for 

the envelope and refrigeration systems 

would be highly effective because they 

would reduce the possibility of 

underperforming envelopes or underperforming refrigeration systems. The 

CA IOUs remarked that it would have 

been difficult to enforce a standard that 

allowed performance trade-offs between 

the envelope and refrigeration system. 

(CA IOUs, No. 110 at p. 1) The CA IOUs 

further commented that separate 

lighting performance standards for 

walk-ins would create more clarity for 

performance requirements of display 

doors. (CA IOUs, No. 110 at p. 4) 

In light of the comments received, 

DOE is finalizing an approach that sets 

out separate component-level standards 

for panels, doors, and refrigeration 

systems of WICFs. DOE recognizes that 

refrigeration systems may be sold as two 

other separate components—a unit 

cooler and a condensing unit—and is 

addressing this through a separate 

approach and certification process for 

this equipment. For more details on this 

approach, see section III.B.2. 

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 for 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). Recently, DOE published 

additional amendments that would, 

among other things, permit the use of 

alternative efficiency determination 

methods when evaluating the energy 

usage of refrigeration system unit 

coolers and condenser units. See 79 FR 

27387 (May 13, 2014). These 

amendments have been taken into 

account when formulating the standards 

promulgated in this notice. 

The proposed amendments provide 

an approach that would base 

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 test procedure final 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 

21580, 21604 (April 15, 2011). DOE 

explained that panel manufacturers 

would test their panels to obtain a 

thermal transmittance metric—known 

as U-factor, measured in British thermal 

units (Btus) per hour-per square foot 

degrees (Fahrenheit) (Btu/h-ft2¥°F)— 

and identified three types of panels: 

display panels, floor panels, and nonfloor 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. 

In response to the energy conservation 

standards NOPR, DOE received 

comments stating that the ASTM C1363, 

DIN EN 13164, and DIN EN 13165 were 

significantly burdensome for 

manufacturers to conduct. DOE 

addressed these comments in a separate 

notice published on May 13, 2014, 

which proposed certain simplifications 

to the current procedure. See 79 FR 

27387. Specifically, under this 

approach, manufacturers would no 

longer need to use the performancebased test procedures for WICF floor 

and non-floor panels, which include 

ASTM C1363, DIN EN 13164, and DINE 

EN 13165 (10 CFR Part 431, Subpart R, 

Appendix A, sections 4.2, 4.3, 5.1, and 

5.2). DOE recognizes that these 

performance-based procedures for WICF 

floor and non-floor panels are in 

addition to the prescriptive 

requirements established in EPCA for 

panel insulation R-values and, therefore, 

may increase the test burden to 

manufacturers. As DOE is no longer 

requiring the performance-based 

procedures which were ultimately used 

to calculate a U-value of a walk-in 

panel, the Department reverted to 

thermal resistance, or R-value, as 

measured by ASTM C518, as the metric 

for establishing performance standards 

for walk-in cooler and freezer panels. 

Based on the comments submitted by 

interested parties, DOE finds that using 

ASTM C518 will provide a sufficient 

robust method to measure panel energy 

efficiency while minimizing 

manufacturer testing burdens. 

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, 


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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. See 

generally 76 FR 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 

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. 

DOE received several comments about 

the proposed metric. NEEA, et al. agreed 

with the door metric being a 

combination of the refrigeration load 

created by the heat loss through the 

door plus heater draw components 

associated with the door. (NEEA, et al., 

No. 101 at p. 5) Nor-Lake commented 

that doors also have a U-value metric 

like panels and that other energy 

consuming devices should be 

considered as an additional load on the 

refrigeration system. (Nor-Lake, No. 115 

at p. 2) Bally commented that the metric 

for doors should be a function of the 

temperature of the WICF box, the linear 

periphery dimensions of the door, the 

thickness of the door and the 

temperature or humidity conditions that 

exist on the outside of the door. (Bally, 

No. 102 at p. 3) Hillphoenix commented 

that the energy consumption posed by 

the perimeter heat on a door is not 

associated with surface area, but instead 

the length of the heater wire. 

(Hillphoenix, No. 107 at p. 2) At the 

public meeting, Kysor commented that 

the door metric should include the Rvalue as tested by ASTM C518 and the 

electrical draw for heater wire, if used. 

(Kysor, Public Meeting Transcript, No. 

88 at p. 96) AHRI suggested that the 

energy metric for door efficiency be 

expressed as a function of door 

perimeter length, as opposed to surface 

area, since the largest heat gain was at 

the periphery and edges. AHRI pointed 

out that while the perimeter of a 

‘‘medium’’ door was 11% greater than a 

‘‘small’’ door, the surface area was 29% 

greater causing smaller doors to be over 

penalized. (AHRI, No. 114 at p. 5) 

In response to Nor-Lake’s comment, 

DOE agrees that non-display doors are 

very similar to panels in that they are 

both primarily made up of insulation. 

However, the DOE test procedure adds 

the additional heat load caused by 

components like lighting and heater 

wire to the daily power consumption of 

these doors. DOE opted for this method 

because the electrical components, like 

heater wire, are integrated into the 

doors. DOE thought this method was 

more appropriate because the door 

manufacturers determine which 

electricity consuming components are 

integrated into the door. In response to 

Bally’s comment, DOE agrees that the 

space conditions of a walk-in have an 

impact on a door’s energy consumption. 

However, the thermal conductance of a 

cooler or freezer door, a portion of the 

maximum energy consumption metric, 

is measured at specific rating conditions 

to allow for equipment comparisons. 

These conditions are listed in 10 CFR 

431.304 and 10 CFR Subpart R, 

appendix A. Additionally, DOE expects 

the thermal transmittance as measured 

by NFRC 100–2010–E0A1 to capture the 

energy loss though the periphery of the 

door because this test method measures 

the heat transfer through an entire door. 

DOE appreciates Kysor’s comment, but 

finds that NFRC 100–2010–E0A1, and 

industry accepted test procedure, more 

accurately represents the thermal 

transmittance of the door. DOE agrees 

with AHRI that the energy consumption 

of the heater wire is directly related to 

the amount or length of heater wire 

used. However, EISA set a precedent by 

limiting the amount of heater wire per 

door opening area. Therefore, DOE is 

setting the standards in terms of door 

surface area instead of perimeter. 

DOE also received comments on the 

door test procedure. Bally remarked at 

the public meeting that the percent time 

off for device controls should be a 

floating value because it would be more 

practical than a set percent time off. 

(Bally, Public Meeting Transcript, No. 

88 at p. 148) DOE appreciates Bally’s 

comment and acknowledges that some 

controls may reduce more energy than 

other. However, the current test 

procedure does not measure the 

effectiveness of the controls. 

Additionally, DOE is concerned that 

incorporating additional testing to 

measure a controls percent time off 

value would great undue burden on 

manufacturers. For these reasons the 

Department is not considering floating 

percent time off values. 

3. Refrigeration 

The DOE test procedure incorporates 

an industry test procedure that applies 

to walk-in refrigeration systems: AHRI 

1250 (I–P)-2009, ‘‘2009 Standard for 

Performance Rating of Walk-In Coolers 

and Freezers’’ (‘‘AHRI 1250–2009’’). (10 

CFR 431.304) This procedure applies to 

three different scenarios—(1) unit 

coolers and condensing units sold 

together as a matched system, (2) unit 

coolers and condensing units sold 

separately, and (3) 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 is using an 

energy conservation standard for 

refrigeration systems that would be 

presented in terms of AWEF. 

Several stakeholders commented on 

the applicability of the test procedure to 

refrigeration components (i.e., the unit 

cooler and the condensing unit) sold 

separately. NEEA, et al. expressed 

support for the proposed standard’s 

approach of using AHRI 1250 for testing 

and rating all condensing units. (NEEA, 

et al., No. 101 at p. 3) CA IOUs, on the 

other hand, asserted that the AHRI 1250 

test was inadequate because it requires 

a unit cooler for testing a dedicated 

condensing unit, which is a less reliable 

rating method due to the lack of a viable 

enforcement mechanism. (CA IOUs, 


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Public Meeting Transcript, No. 88 at p. 

384) CA IOUs recommended modifying 

the AHRI 1250 test method so that all 

unit coolers connected to remote 

condensing units are treated the same, 

whether they are connected to a 

dedicated, shared, or multiplex remote 

condensing unit. (CA IOUs, No. 110 at 

p. 2) CA IOUs further recommended 

developing a separate AHRI Standard 

for the performance rating of WICF 

refrigeration condensing units, along 

with TSLs (i.e. Trial Standard Levels) 

and energy conservation standards 

specific to refrigeration condensing 

units. (CA IOUs, No. 110 at p. 3) 

Manitowoc asserted that manufacturers 

that build only condensing units—but 

not evaporator coils—could not test the 

efficiency of the entire refrigeration 

system. (Manitowoc, No. 108 at p. 2) 

Other stakeholders commented 

specifically on the metrics established 

by the test procedure. KeepRite and 

Bally suggested that the energy 

efficiency ratio (EER) of the condensing 

unit and evaporator be used as the 

refrigeration system metric and basis of 

performance specifications in place of 

AWEF. (KeepRite, No. 105 at p. 1; Bally, 

No. 102 at p. 3) AHRI commented that 

the use of duty-cycle adjusted EER for 

condensing units and unit coolers, 

separately, was a more accurate metric 

than AWEF and should be the basis for 

performance specifications, because 

evaporator assemblies, condensing 

units, and refrigerants were often 

specified by contractors, procured from 

multiple manufacturers, and assembled 

as custom systems. (AHRI, No. 114 at p. 

2) Louisville Cooler commented that 

using a watts-per-hour was a more 

practical and replicable method of 

measuring energy use, and AWEF is 

impacted by variables such as ambient 

temperature and seasonal changes. 

(Louisville Cooler, No. 81 at p. 1) NEEA, 

et al., on the other hand, stated that 

AWEF was a logical metric to rate 

cooling system component efficiency in 

a way that enabled marketplace 

differentiation and simplified 

compliance and enforcement. (NEEA, et 

al., No. 101 at p. 2) 

DOE understands that the test 

procedure, as originally conceived, 

required both a unit cooler and a 

condensing unit to be tested in order to 

derive an AWEF rating for the system. 

In light of the issues about enforcement 

and manufacturer burden raised by the 

CA IOUs and Manitowoc, DOE has 

developed a separate approach 

addressing certification issues for 

manufacturers who produce and sell 

condensing units and/or unit coolers as 

separate products. Under that approach, 

a manufacturer who sells a unit without 

a matched condensing unit must rate 

and certify a refrigeration system 

containing that unit cooler by testing 

according to the methodology in AHRI 

1250 for unit coolers intended to be 

used with a parallel rack system (see 

AHRI 1250, section 7.9). The 

manufacturer would use the calculation 

method in this section to determine the 

system AWEF and certify this AWEF to 

DOE. Additionally, all unit coolers 

tested and rated as part of a system 

under this method must comply with 

the standards in the multiplex 

equipment classes. DOE notes that this 

approach is consistent with the 

approach recommended by the CA IOUs 

because the same approach is used for 

separately-sold unit coolers regardless 

of what kind of condensing unit they are 

paired with. A manufacturer who sells 

a condensing unit separately must rate 

and certify a refrigeration system 

containing that condensing unit by 

conducting the condensing unit portion 

of the test method (using the standard 

ratings in section 5.1 of AHRI 1250– 

2009) but applying nominal values for 

saturated suction temperature, 

evaporator fan power, and defrost 

energy, in order to calculate an AWEF 

for the refrigeration system basic model 

containing that condensing unit. These 

nominal values would be standardized, 

which means that other similarly 

situated manufacturers would use these 

values when calculating the efficiency 

of a refrigeration system using their 

particular condensing unit. For 

complete details on how refrigeration 

system components must be rated and 

certified under this approach, see 79 FR 

27387 at 27397 (detailing revised 

approach to be incorporated under 10 

CFR 431.304(c)(10)). In response to the 

comments about the appropriate metrics 

to use, DOE notes that it is continuing 

to use AWEF as the metric for WICF 

refrigeration systems and components, 

and continues to base its standards on 

AWEF. DOE believes AWEF is sufficient 

to capture WICF system and component 

performance and has not established a 

different metric, such as EER or watts/ 

hour, for rating refrigeration equipment. 

In response to Louisville Cooler’s 

comment on the effect of seasonal 

changes and temperatures, DOE notes 

that the test procedure established a set 

of uniform rating conditions that cover 

multiple ambient temperatures as a 

proxy for seasonal changes a system 

exposed to the outdoors may encounter. 

DOE’s standards are based on rating 

systems under the uniform rating 

conditions contained in the test 

procedure, thus maximizing the 

repeatability of the test. 

Lennox noted that the test procedure 

did not contain provisions for multiple 

unit cooler matches on a single 

condensing unit. (Lennox, No. 109 at p. 

3) DOE acknowledges this fact but notes 

that manufacturer installation 

instructions typically include setup of 

multiple unit coolers because this setup 

is commonly used; for instance, by 

installers who wish to distribute airflow 

more evenly around a large walk-in. 

During the test, the system should be set 

up per the manufacturer’s installation 

instructions. DOE successfully 

conducted testing of a system with two 

unit coolers as part of its rulemaking 

analysis. However, if DOE finds that 

such instructions are sufficiently 

unclear to others testing their 

equipment, DOE may introduce a test 

procedure addendum or amendment 

with more specific instructions for setup 

and testing. 

Further, some commenters identified 

types of systems or technologies that 

would not be covered by the test 

procedure. Hussmann commented that 

the AHRI 1250 procedure did not 

contain test methods for secondary 

refrigeration systems, such as those 

utilizing glycol, brine, or CO2. 

(Hussmann, No. 93 at p. 2) Danfoss 

commented that by regulating units in 

steady-state conditions, the proposed 

rule automatically excluded adaptive 

controls, which had tremendous energy 

savings potential. (Danfoss, Public 

Meeting Transcript, No. 88 at p. 115) 

ACEEE agreed with Danfoss that the 

AHRI 1250 procedure lacked the ability 

to account for controls, and other design 

options not affecting steady-state energy 

consumption. (ACEEE, Public Meeting 

Transcript, No. 88 at p. 149) AHRI 

added that the AHRI 1250 test 

procedure was likely to be updated in 

the next three to six months. (AHRI, No. 

114 at p. 3) 

DOE agrees with Hussmann that the 

AHRI 1250 procedure does not cover 

secondary refrigeration systems, and 

agrees with Danfoss and ACEEE that 

controls or other options not affecting 

steady-state energy would also not be 

covered by AHRI 1250. If a 

manufacturer believes that the test 

procedure in its current form does not 

measure the efficiency of the equipment 

in a manner representative of its true 

energy use, the manufacturer may apply 

for a test procedure waiver. DOE also 

notes that should the industry develop 

a test method for WICF units with 

secondary refrigeration systems or 

adaptive controls, or update the existing 

test method so as to include such 

provisions, DOE will consider adopting 

it for WICFs. To address AHRI’s 

comment, DOE will also consider 


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adopting test procedure revisions once 

they are developed. 

C. Certification, Compliance, and 

Enforcement 

In keeping with the requirements of 

EPCA, DOE proposed a compliance date 

of three years from the date of 

publication of the final rule. 78 FR 

55830 (September 11, 2013) DOE 

received a variety of comments 

regarding this issue. Several 

stakeholders commented in favor of a 

three-year period between the final rule 

and the compliance date. Specifically, 

ASAP, et al. urged DOE to adopt a 

compliance date three years after 

publication of the final rule, since 

DOE’s analysis of manufacturer impacts 

suggests that conversion costs to meet 

the proposed standards would be 

modest. (ASAP, et al., No. 113 at p. 5) 

Manitowoc stated that once the standard 

is finalized, three years is a sufficient 

timeframe for compliance. (Manitowoc, 

No. 108 at p. 3) ASAP, et al. noted that 

a compliance date of three years after 

the publication of the final rule is 

reasonable and that a later compliance 

date would result in avoidable loss of 

energy savings. (ASAP et al., No. 113 at 

p. 5) 

Several stakeholders favored a longer 

period between the final rule and the 

compliance date. Hussmann stated that 

DOE should consider the certification 

process when setting the compliance 

date and that the compliance date of the 

proposed standard should be delayed so 

as to allow for an AEDM to be enforced 

before the compliance date. (Hussmann, 

Public Meeting Transcript, No. 88 at p. 

75, and No. 93 at p. 6) Lennox expressed 

concern that a three-year compliance 

timeframe is not adequate. (Lennox, No. 

109 at p. 7) Nor-Lake requested that 

DOE extend the compliance date 

beyond 2017 and noted that a 

compliance date of April 2017 may not 

give manufacturers enough time to 

complete required testing since there are 

currently no known labs in the U.S. that 

can perform the DIN EN 13164/13165 

tests. Nor-Lake observed that 

manufacturers that produce panels and 

refrigeration would be overloaded with 

having to perform both sets of tests. 

(Nor-Lake, No. 115 at pp. 3–5) 

Hillphoenix requested additional time 

for the compliance date and testing to 

allow for more labs to qualify for testing, 

because currently none can. 

(Hillphoenix, No. at p. 69) AHRI 

recommended that the timeline consider 

the fact that there is no AHRI or other 

third-party certification program for 

these products. (AHRI, Public Meeting 

Transcript, No. 88 at p. 76) 

Regarding enforcement, Hussmann 

commented that it was unclear how 

DOE intended to enforce the standard 

for cooling systems, and ACCA 

suggested that an outline of DOE’s 

intended enforcement policy be 

included in the final rule. (Hussmann, 

No. 93 at p. 1; ACCA, No. 119 at p. 2) 

ACCA further urged that DOE simplify 

compliance obligations for the 

assembler, including giving the industry 

one year after adoption of an 

enforcement policy to comply with 

enforcement provisions. (ACCA, No. 

119 at p. 3) 

DOE notes that it has since simplified 

the testing requirements for WICF 

components—in part by eliminating the 

requirement to test panels using the 

ASTM C1363 and DIN EN 13164/13165 

tests. For refrigeration systems, DOE 

established a testing approach for unit 

coolers and condensing units sold 

separately and allowed refrigeration 

systems, unit coolers, and condensing 

units to be rated using an Alternative 

Efficiency Determination Method, or 

AEDM. See 79 FR 27387 (May 14, 2014). 

DOE believes these changes 

substantially simplify the process for 

certification, compliance, and 

enforcement. Therefore, DOE does not 

believe additional time is needed for 

compliance beyond three years from the 

publication of this notice. 

Since component-level standards 

were proposed in the NOPR, DOE 

requested comments on who should be 

responsible for complying with the 

regulation. DOE received comments 

from multiple interested parties in this 

regard. The CA IOUs stated that DOE 

found that the contractor is the 

‘‘manufacturer’’ and that DOE should 

therefore provide a path to certification 

for contractors. (CA IOUs, No. 89 at p. 

20) The CA IOUs further commented 

that manufacturers sell lighting systems 

specifically designed for cold storage 

facilities and these could therefore be 

regulated at the point of manufacture. 

(CA IOUs, No. 110 at p. 4) ACCA noted 

that the assembly of WICF component 

parts is often performed by independent 

heating, ventilation, air-conditioning, 

and refrigeration (HVAC/R) technicians 

not employed by component part 

manufacturers. (ACCA, No. 119 at p. 1) 

US Cooler noted that the proposed 

standard could significantly impact 

manufacturers who made individual 

refrigeration components that were then 

assembled into complete systems by 

contractors. (US Cooler, Public Meeting 

Transcript, No. 88 at p. 344) More 

specifically, US Cooler expressed 

concern that wholesalers and 

contractors would not be held to the 

same level of compliance as component 

manufacturers, which would put US 

Cooler at a competitive disadvantage. 

(US Cooler, Public Meeting Transcript, 

No. 88 at p. 51) American Panel agreed 

that the standards must also apply to 

wholesalers, as well as component 

manufacturers to prevent wholesalers 

from circumventing the regulation (for 

instance, by selling cooler panels for 

freezer applications). (American Panel, 

No. 99 at p. 2) HARDI stated that 

holding the wholesaler responsible 

would limit product availability for 

replacement and repair. (HARDI, Public 

Meeting Transcript, No. 88 at p. 53) 

ACEEE stated that the approach chosen 

should support the goal of legitimate 

repair parts without abusing the system, 

where ‘‘repair’’ components are being 

sold by manufacturers to subvert the 

law. (ACEEE, Public Meeting Transcript, 

No. 88 at p. 54) Danfoss noted that about 

25 percent of WICF refrigeration 

systems are assembled by contractors 

and not sold as combined sets, and 

American Panel noted that 15 percent of 

systems are unit coolers connected to 

rack systems, where below 10 percent 

are dedicated systems matched by a 

contractor. (Danfoss, Public Meeting 

Transcript, No. 88 at p. 60, and APC, 

Public Meeting Transcript, No. 88 at p. 

60) Danfoss further expressed concern 

that the proposed standard would 

preclude manufacturers like itself who 

sold only condensing units, but not 

complete systems, from being able to 

sell products into the WICF market. 

(Danfoss, Public Meeting Transcript, No. 

88 at p. 343) 

In general, DOE notes that the term 

‘‘manufacturer’’ of a walk-in refers to 

any person who (1) manufactures a 

component of a walk-in cooler or walkin freezer that affects energy 

consumption, including, but not limited 

to, refrigeration, doors, lights, windows, 

or walls; or (2) manufactures or 

assembles the complete walk-in cooler 

or walk-in freezer. (See 10 CFR 

431.302.) For purposes of certification, 

DOE will require the manufacturer of 

the walk-in component to certify 

compliance with DOE’s standards, 

which are component-based. Namely, 

the manufacturer of a panel or door that 

is used in a walk-in must certify 

compliance. Manufacturers of 

refrigeration system components— 

namely, unit coolers and condensing 

units—that sell those components 

separately must rate and certify those 

components, while manufacturers of 

complete refrigeration systems whose 

components are not already separately 

certified must rate and certify those 

systems, in a manner consistent with 

DOE’s recent final rule, published at 79 


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12 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 

equipment purchased during 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. 

13 ‘‘Review of Site (Point-of-Use) and Full-FuelCycle Measurement Approaches to DOE/EERE 

Building Appliance Energy- Efficiency Standards,’’ 

(Academy report) was completed in May 2009 and 

included five recommendations. A copy of the 

study can be downloaded at: http://www.nap.edu/ 

catalog.php?record_id=12670. 

FR 27387. This approach will allow 

manufacturers of one refrigeration 

component but not the other to sell their 

products into the WICF market, 

addressing Danfoss’s concern. The 

manufacturer of the complete walk-in, 

or the assembler of any component 

thereof (for example, a person who 

assembles a walk-in refrigeration system 

from a separately-sold unit cooler and 

condensing unit) must use components 

that are certified to and compliant with 

DOE’s WICF standards. This approach 

avoids the compliance and certification 

issues inherent in requiring assemblers 

or contractors to certify WICF 

equipment, while maintaining the 

responsibility of assemblers or 

contractors to abide by the same 

standards as WICF components 

manufacturers, which DOE believes 

addresses US Cooler’s concern about 

competitive disadvantage. This 

approach also requires that newly 

manufactured components comply with 

the DOE standards, regardless of 

whether they are being assembled into 

a new walk-in or being used as a 

replacement component on an existing 

walk-in, which addresses ACEEE’s 

concern about the abuse of the ‘‘repair’’ 

designation. DOE appreciates the 

statements made by Danfoss and 

American Panel, and notes that because 

several paths to ‘‘manufacture’’ are 

available for walk-in coolers, it has 

developed its certification requirements 

accordingly. 

D. 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 part 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.C 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 an 

amended standard for a type or class of 

covered product, it must determine the 

maximum improvement in energy 

efficiency or maximum reduction in 

energy use that is technologically 

feasible for such product. (42 U.S.C. 

6295(p)(1)) Accordingly, in the 

engineering analysis, DOE determined 

the maximum technologically feasible 

(‘‘max-tech’’) improvements in energy 

efficiency for walk-ins using the design 

parameters for the most efficient 

products available on the market or in 

working prototypes. (See chapter 5 of 

the final rule TSD.) The max-tech levels 

that DOE determined for this 

rulemaking are described in section 

V.A.2 of this final rule. 

E. Energy Savings 

1. Determination of Savings 

For each TSL, DOE projected energy 

savings from the equipment at issue that 

are purchased during a 30-year period 

that begins in the year of compliance 

with amended standards (2017–2046). 

The savings are measured over the 

entire lifetime of products purchased in 

the 30-year period.12 The model 

forecasts total energy use over the 

analysis period for each representative 

equipment class at efficiency levels set 

by each of the considered TSLs. DOE 

then compares the energy use at each 

TSL to the base-case energy use to 

obtain the NES. The NIA model is 

described in section IV.I of this notice 

and in chapter 10 of the final rule TSD. 

The NIA spreadsheet model 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 primary 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 energy savings. 76 FR 51282 

(August 18, 2011), as amended at 77 FR 

49701 (August 17, 2012). The full-fuelcycle (FFC) metric includes the energy 

consumed in extracting, processing, and 

transporting primary fuels, and thus 

presents a more complete picture of the 

impacts of energy efficiency standards. 

DOE’s evaluation of FFC savings is 

driven in part by the National Academy 

of Science’s (NAS) report on FFC 

measurement approaches for DOE’s 

Appliance Standards Program.13 The 

NAS report discusses that FFC was 

primarily intended for energy efficiency 

standards rulemakings where multiple 

fuels may be used by a particular 

product. In the case of this rulemaking 

pertaining to walk-ins, only a single 

fuel—electricity—is consumed by the 

equipment. DOE’s approach is based on 

the calculation of an FFC multiplier for 

each of the energy types used by 

covered equipment. Although the 

addition of FFC energy savings in the 

rulemakings is consistent with the 

recommendations, the methodology for 

estimating FFC does not project how 

fuel markets would respond to this 

particular standard rulemaking. The 

FFC methodology simply estimates how 

much additional energy, and in turn 

how many tons of emissions, may be 

displaced if the estimated fuel were not 

consumed by the equipment covered in 

this rulemaking. It is also important to 

note that the inclusion of FFC savings 

does not affect DOE’s choice of 

proposed standards. For more 

information on FFC energy savings, see 

section IV.I. 

2. Significance of Savings 

To adopt more-stringent standards for 

a covered product, DOE must determine 


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14 DOE also presents a sensitivity analysis that 

considers impacts for equipment shipped in a 9- 

year period. 

that such action would result in 

significant additional energy savings. 

(42 U.S.C. 6295(o)(3)(B),(v) and 6316(a)) 

Although the term ‘‘significant’’ is not 

defined in EPCA, the U.S. Court of 

Appeals for the District of Columbia, in 

Natural Resources Defense Council v. 

Herrington, 768 F.2d 1355, 1373 (D.C. 

Cir. 1985), indicated that Congress 

intended significant energy savings in 

the context of EPCA to be savings that 

were not ‘‘genuinely trivial.’’ The energy 

savings for these standards are 

nontrivial, and, therefore, DOE 

considers them ‘‘significant’’ within the 

meaning of section 325 of EPCA. 

F. 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. (42 U.S.C. 6295(o)(2)(B)(i) and 

6316(a)) The following sections 

generally discuss how DOE is 

addressing each of those seven factors in 

this rulemaking. 

a. Economic Impact on Manufacturers 

and Commercial Customers 

In determining the impacts of a 

potential new or amended energy 

conservation standard on 

manufacturers, DOE conducts a 

manufacturer impact analysis (MIA), as 

discussed in section IV.K. First, DOE 

determines its quantitative impacts 

using an annual cash flow approach. 

This includes both a short-term 

assessment (based on the cost and 

capital requirements associated with 

new or amended standards during the 

period between the announcement of a 

regulation and the compliance date of 

the regulation) and a long-term 

assessment (based on the costs and 

marginal impacts over the 30-year 

analysis period 14). The impacts 

analyzed include INPV (which values 

the industry based on 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 

potential impacts on different types of 

manufacturers, paying particular 

attention to impacts on small 

manufacturers. Third, DOE considers 

the impact of new or amended 

standards on domestic manufacturer 

employment and manufacturing 

capacity, as well as the potential for 

new or amended standards to result in 

plant closures and loss of capital 

investment. Finally, DOE takes into 

account cumulative impacts of other 

DOE regulations and non-DOE 

regulatory requirements on 

manufacturers. 

For individual customers, measures of 

economic impact include the changes in 

LCC and the PBP associated with new 

or amended standards. These measures 

are discussed further in the following 

section. For consumers in the aggregate, 

DOE also calculates the national net 

present value of the economic impacts 

applicable to a particular rulemaking. 

DOE also evaluates the LCC impacts of 

potential standards on identifiable 

subgroups of consumers that may be 

affected disproportionately by a national 

standard. 

b. Savings in Operating Costs Compared 

to Increase in Price 

EPCA requires DOE to consider the 

savings in operating costs throughout 

the estimated average life of the covered 

product compared to any increase in the 

price of the covered product that are 

likely to result from the imposition of 

the standard. (42 U.S.C. 

6295(o)(2)(B)(i)(II)) DOE conducts this 

comparison in its LCC and PBP analysis. 

The LCC is the sum of the purchase 

price of equipment (including the cost 

of its installation) and the operating 

costs (including energy and 

maintenance and repair costs) 

discounted over the lifetime of the 

equipment. To account for uncertainty 

and variability in specific inputs, such 

as product lifetime and discount rate, 

DOE uses a distribution of values, with 

probabilities attached to each value. For 

its analysis, DOE assumes that 

consumers will purchase the covered 

products in the first year of compliance 

with amended standards. 

The LCC savings and the PBP for the 

considered efficiency levels are 

calculated relative to a base-case 

scenario, which reflects likely trends in 

the absence of new or amended 

standards. DOE identifies the percentage 

of consumers estimated to receive LCC 

savings or experience an LCC increase, 

in addition to the average LCC savings 

associated with a particular standard 

level. DOE’s LCC and PBP analysis is 

discussed in further detail in section 

IV.G. 

c. Energy Savings 

Although significant conservation of 

energy is a separate statutory 

requirement for adopting an energy 

conservation standard, EPCA also 

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. (42 U.S.C. 

6295(o)(2)(B)(i)(III) and 6316(a)) DOE 

uses NIA spreadsheet results to project 

national energy savings. 

For the results of DOE’s analyses 

related to the potential energy savings, 

see section I.A.3 of this notice. 

d. Lessening of Utility or Performance of 

Equipment 

In establishing classes of equipment, 

and in evaluating design options and 

the impact of potential standard levels, 

DOE seeks to develop standards that 

would not lessen the utility or 

performance of the equipment under 

consideration. DOE has determined that 

none of the TSLs presented in this final 

rule would reduce the utility or 

performance of the equipment 

considered in the rulemaking. (42 U.S.C. 

6295(o)(2)(B)(i)(IV) and 6316(a)) During 

the screening analysis, DOE eliminated 

from consideration any technology that 

would adversely impact customer 

utility. For the results of DOE’s analyses 

related to the potential impact of 

amended standards on equipment 

utility and performance, see section 

IV.C of this notice and chapter 4 of the 

final rule TSD. 

e. Impact of Any Lessening of 

Competition 

EPCA requires DOE to consider any 

lessening of competition that is likely to 

result from setting new or amended 

standards for a covered product. 

Consistent with its obligations under 

EPCA, DOE sought the views of the 

United States Department of Justice 

(DOJ). DOE asked DOJ to provide a 

written determination of the impact, if 

any, of any lessening of competition 

likely to result from the amended 

standards, together with an analysis of 

the nature and extent of such impact. 42 

U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii). To 

assist DOJ in making such a 

determination, DOE provided DOJ with 

copies of both the NOPR and NOPR TSD 

for review. DOJ subsequently 

determined that the amended standards 

are unlikely to have a significant 

adverse impact on competition. 

Accordingly, DOE concludes that this 

final rule would not be likely to lead to 

a lessening of competition. 

f. Need of the Nation To Conserve 

Energy 

DOE also considers the need for 

national energy and water conservation 

in determining whether a new or 

amended standard is economically 

justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI) 

and 6316(a)) The energy savings from 

new or amended standards are likely to 

improve the security and reliability of 


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32066 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

the Nation’s energy system. Reductions 

in the demand for electricity may also 

result in reduced costs for maintaining 

the reliability of the Nation’s electricity 

system. DOE conducts a utility impact 

analysis to estimate how new or 

amended standards may affect the 

Nation’s needed power generation 

capacity. 

Energy savings from amended 

standards for walk-ins are also likely to 

result in environmental benefits in the 

form of reduced emissions of air 

pollutants and GHGs associated with 

energy production (e.g., from power 

plants). For a discussion of the results 

of the analyses relating to the potential 

environmental benefits of the amended 

standards, see sections IV.L, IV.M and 

V.B.6 of this notice. DOE reports the 

expected environmental effects from the 

amended standards, as well as from 

each TSL it considered for walk-ins in 

the emissions analysis contained in 

chapter 13 of the final rule TSD. DOE 

also reports estimates of the economic 

value of emissions reductions resulting 

from the considered TSLs in chapter 14 

of the final rule TSD. 

g. Other Factors 

EPCA allows the Secretary, in 

determining whether a new or amended 

standard is economically justified, to 

consider any other factors that the 

Secretary deems to be relevant. (42 

U.S.C. 6295(o)(2)(B)(i)(VII) and 6316(a)) 

There were no other factors considered 

for this final rule. 

2. Rebuttable Presumption 

As set forth in 42 U.S.C. 

6295(o)(2)(B)(iii) and 6316(a), EPCA 

provides for a rebuttable presumption 

that an energy conservation standard is 

economically justified if the additional 

cost to the customer of equipment that 

meets the new or amended standard 

level is less than three times the value 

of the first-year 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 

that calculate the PBP for customers of 

potential new and amended energy 

conservation standards. These analyses 

include, but are not limited to, the 3- 

year PBP contemplated under the 

rebuttable presumption test. However, 

DOE routinely conducts a full economic 

analysis that considers the full range of 

impacts to the customer, manufacturer, 

Nation, and environment, as required 

under 42 U.S.C. 6295(o)(2)(B)(i) and 

6316(a). The results of these analyses 

serve as the basis for DOE to evaluate 

the economic justification for a potential 

standard level definitively (thereby 

supporting or rebutting the results of 

any preliminary determination of 

economic justification). The rebuttable 

presumption payback calculation is 

discussed in section IV.G.12 of this 

notice. 

IV. Methodology and Discussion of 

Comments 

A. General Rulemaking Issues 

During the October 9, 2013 NOPR 

public meeting, and in subsequent 

written comments, stakeholders 

provided input regarding general issues 

pertinent to the rulemaking, including 

the trial standard levels, the rulemaking 

timeline, and other subjects. These 

issues are discussed in this section. 

1. Trial Standard Levels 

In the NOPR, DOE proposed the 

adoption of TSL 4 as the energy 

conservation standard for walk-ins, 

based on analysis showing that this 

level was both technically and 

economically feasible. 78 FR 55845 

(September 11, 2013) NEEA et al. agreed 

with DOE’s proposal, noting that TSL 4 

represented the highest economically 

justified efficiency level, even though 

higher efficiencies were technologically 

feasible. (NEEA et al., No. 101 at p. 4) 

Reaction to DOE’s proposal was 

somewhat mixed with several parties 

viewing the proposed standard as 

sufficiently aggressive for some 

components but insufficient for other 

components. Specifically, ASAP opined 

that DOE’s proposed efficiency level 

was strong, but urged DOE to consider 

a TSL 4.5, which would combine the 

envelope components of TSL 4, and the 

refrigeration components of TSL 5. 

(ASAP, No. at p. 15) Similarly, the CA 

IOUs, while agreeing with the proposed 

TSL for panels, urged DOE to adopt TSL 

5 for refrigeration systems, since 

enhanced condenser coil, improved 

evaporator fan blades, and improved 

defrost controls—all of which are 

refrigeration systems components— 

offered cost effective options DOE 

should consider. (CA IOUs, Public 

Meeting Transcript, No. 88 at p. 26) 

On the other hand, some commenters 

viewed the proposal as infeasible for 

manufacturers to meet. ThermoKool and 

US Cooler opined that TSL 2 was 

adequate. (US Cooler, Public Meeting 

Transcript, No. 88 at p. 376, 

ThermoKool, No. 97 at p. 5) Lennox 

International also noted that DOE’s 

AWEF values for TSL 4 were overly 

aggressive, based on modeling errors. 

(Lennox, No. 109 at p. 1) 

With regard to the selection of design 

options at each TSL, Nor-Lake 

recommended that TSL 4 should 

consider standard levels requiring 

panels no thicker than 4 inches for class 

SP.L, as this was the current panel 

thickness most common in the industry. 

Nor-Lake noted that increasing panel 

thickness greatly increases production 

time and cost. (Nor-Lake, No. 115 at p. 

2) 

In response to the comments from 

stakeholders, DOE reformulated its 

TSLs. See section V.A for further 

discussion on the TSLs. 

2. Rulemaking Timeline 

A number of stakeholders commented 

on DOE’s proposed rulemaking 

timeline. ICS requested that the target 

date for the final rule be moved beyond 

April 2014 to allow more opportunity 

for discussion and the development of 

a standard, and specifically 

recommended the final rule date be 

extended to at least 2016 to resolve all 

uncertainties in the analysis, using more 

accurate industry data. (ICS, et al., No. 

100 at p. 2 and 6). Lennox 

recommended a twelve-month delay in 

finalizing the proposed rule, in order for 

DOE to address modeling discrepancies 

and assumption errors in addition to 

providing separate performance targets 

for unit coolers and condensing units. 

(Lennox, No. 109 at p. 7) Hillphoenix 

urged DOE to consider extending the 

completion date of the final rule, to 

allow, at minimum, four more 

opportunities for exchange of 

information between DOE and 

manufacturers. (Hillphoenix, No. 107 at 

p. 3) The CA IOUs suggested that DOE 

delay the adoption of energy 

conservation standards for walk-in 

coolers in order to rewrite the standards 

to make them more enforceable, and to 

develop separate standards for 

condensing units. (CA IOUs, No. 110 at 

p. 3) 

Additionally, Bally commented that 

the timeline is probably unrealistic due 

to the need for an additional public 

meeting. (Bally, No. 102 at p. 3) IB 

stated that DOE’s proposal to have a 

final rule in place by April 2014 is very 

ambitious and does not allow enough 

time to make necessary modifications to 

the proposed rule. IB requested 

additional public meetings where the 

analysis assumptions can be reviewed 

in depth with manufacturers. (IB, No. 98 

at p. 4) NCC stated that the time 

provided by DOE for manufacturers to 

evaluate the proposed standard was 

insufficient. (NCC, No. 96 at p. 2) 

Thermo-Kool commented that the target 

date for the final rule should be 

extended in order to allow 

manufacturers to fully understand 

DOE’s analysis, and to facilitate more 

public meetings. (ThermoKool, No. 97 at 


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p. 5) Danfoss urged DOE to consider 

moving forward with the overall 

rulemaking but to take more time with 

the condensing unit and unit cooler 

split, potentially with an SNOPR, and to 

take separated condensing and cooling 

units into account. (Danfoss, Public 

Meeting Transcript, No. 88 at pp. 88 and 

72) 

Public comment was also received 

opposing to extending the schedule. On 

the industry side, ebm-papst 

recommended proceeding quickly with 

the regulation because it raises the bar 

and spurs development toward a more 

sustainable refrigeration industry. (ebmpapst, No. 92 at p. 2) Similarly, AGNY 

commented that the delay in amending 

efficiency standards for walk-ins has led 

to inefficient products staying on the 

market, depriving purchasers of more 

effective options, and further asserted 

that delays have cost the nation $2.2 

billion in lost savings. (AGNY, No. 116 

at p. 2) 

While DOE appreciates the concerns 

expressed by commenters regarding the 

current rulemaking timeline, DOE 

believes that the recent modifications it 

has made will permit manufacturers to 

much more easily address the various 

requirements that will be established by 

this rule. For details regarding the 

separate analysis and certification of 

refrigeration system components, see 79 

FR 27387 (May 14, 2014). 

B. Market and Technology Assessment 

When beginning an energy 

conservation standards rulemaking, 

DOE develops information that provides 

an overall picture of the market for the 

equipment concerned, including the 

purpose of the equipment, the industry 

structure, and market characteristics. 

This activity includes both quantitative 

and qualitative assessments based 

primarily on publicly available 

information (e.g., manufacturer 

specification sheets, industry 

publications) and data submitted by 

manufacturers, trade associations, and 

other stakeholders. The subjects 

addressed in the market and technology 

assessment for this rulemaking include: 

(1) Quantities and types of equipment 

sold and offered for sale; (2) retail 

market trends; (3) equipment covered by 

the rulemaking; (4) equipment classes; 

(5) manufacturers; (6) regulatory 

requirements and non-regulatory 

programs (such as rebate programs and 

tax credits); and (7) technologies that 

could improve the energy efficiency of 

the equipment under examination. DOE 

researched manufacturers of walk-in 

coolers and walk-in freezers and made 

a particular effort to identify and 

characterize small business 

manufacturers. See chapter 3 of the final 

rule TSD for further discussion of the 

market and technology assessment. 

1. Equipment Included in This 

Rulemaking 

a. Panels and Doors 

In the NOPR, 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 

(i.e. 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 did not propose 

to set new standards for walk-in display 

panels. Display panels, however, must 

still follow all applicable design 

standards already prescribed by EPCA. 

See 10 CFR 431.306(b). Additionally, 

DOE declined to propose standards for 

walk-in cooler floor panels because DOE 

determined through manufacturer 

interviews and market research that the 

majority of walk-in coolers are made 

with concrete floors and do not use 

insulated floor panels. DOE did, 

however, propose standards for other 

panels (i.e. door, ceiling and wall). 

Several stakeholders supported DOE’s 

proposal to not set new standards for 

display and cooler floor panels. 

Thermo-Kool and Hillphoenix agreed 

that display panels and cooler floor 

panels should be excluded. (ThermoKool, No. 97 at p. 2; Hillphoenix, No. 

107 at p. 3) NEEA stated that it was 

impractical to regulate or require floors 

for walk-in coolers. (NEEA, No. 101 at 

p. 3) American Panel, however, believed 

that additional energy savings were 

possible while imposing only a minimal 

burden on industry if walk-in coolers 

were required to use insulated floor 

panels or insulated concrete slabs with 

thermal breaks instead of requiring 

panel manufacturers to increase panel 

thickness. (American Panel, No. 99 at p. 

10) DOE agrees with American Panel 

that in theory a walk-in coolers would 

consume less energy with a insulated 

floor. However, EPCA directs DOE to 

adopt performance standards of walk-in 

and thus the Department cannot require 

all walk-in coolers to be installed with 

insulated floors. Additionally, the 

Department expected that setting an Rvalue requirement for walk-in cooler 

floor panels would cause manufactures 

to stop selling cooler floor panels to 

avoid the certification burden. 

American Panel asked if DOE 

considered freezers built inside a walkin that are built inside another walk-in. 

American Panel noted that for coolerfreezer combination units, complicated 

dividing wall panels were required, 

which were complicated to 

manufacture, and would be very 

expensive, should the walk-in freezer 

require 5 inch insulation. (American 

Panel, No. 99 at p. 5) DOE agrees that 

its analysis does not account for the 

specific installation scenarios of walk-in 

panels beyond cooler versus freezer 

applications. However, the Department 

reiterates that it is not establishing 

prescriptive standards so freezer panels 

would not be required to be a specific 

thickness—only that they meet a 

particular thermal resistance value. 

DOE also identified two types of 

doors used in the walk-in market, 

display doors and non-display doors, 

which are discussed in section VI.2.A. 

of this NOPR. All types of doors will be 

subject to the performance standards 

proposed in this rulemaking. 

b. Refrigeration Systems 

Blast Chillers and Blast Freezers 

In the NOPR, DOE did not include 

blast freezers in its rulemaking analysis, 

but proposed to apply the same 

standards to blast freezer refrigeration 

systems as to storage freezer 

refrigeration systems, unless DOE were 

to find that blast freezer refrigeration 

systems would have difficulty 

complying with DOE’s standards. DOE 

requested comments from the public on 

the inclusion of blast freezers within the 

scope of the proposed rule. 78 FR at 

55799. In response, NEEA, et al., 

Hussmann, ACEEE, American Panel, the 

California IOU’s, Heatcraft, Bally, 

Hillphoenix, Lennox, AHRI and NorLake urged DOE to carefully define blast 

chillers and freezers, and to exclude 

them from the products covered by the 

proposed rule, since these were food 

processing equipment, as opposed to 

food storage equipment like most other 

walk-in coolers and freezers. (NEEA, et 

al., No. 101 at p. 5; Hussmann, No. 93 

at p. 7; ACEEE, Public Meeting 

Transcript, No. 88 at p. 112; APC, Public 

Meeting Transcript, No. 88 at p. 111; CA 

IOUs, Public Meeting Transcript, No. 88 

at p. 109; Heatcraft, Public Meeting 

Transcript, No. 88 at p. 108; Bally, 

Public Meeting Transcript, No. 88 at p. 

108; Hillphoenix, No. 107 at p. 3; 

Lennox, No. 109 at p. 4; AHRI, No. 114 

at p. 3; Nor-Lake, No. 115 at p. 1) APC 

recommended that in addition to blast 

freezers, blast chillers should also be 


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excluded from the ambit of the 

proposed rule for similar reasons. (APC, 

No. 99 at p. 3) AHRI, on the other hand, 

suggested that blast coolers and freezers, 

along with ripening rooms, should be 

held to different efficiency standards 

than WICFs. (AHRI, No. 114 at p. 3) 

After considering the comments 

received and conducting additional 

research, DOE agrees with commenters 

that blast chillers and blast freezers are 

food processing equipment and place 

them outside of the definition of a walkin, which is defined as an ‘‘enclosed 

storage space.’’ (42 U.S.C. 6311(20)(A)) 

Additionally, DOE has found that blast 

chillers and blast freezers have very 

different energy consumption 

characteristics from storage coolers and 

freezers, which would justify their 

classification as a distinct product. 

Based on the comments, along with 

other information reviewed by DOE (e.g. 

manufacturer brochures and literature) 

regarding the operation and use of blast 

chillers and blast freezers. DOE is 

declining to treat these equipment 

categories as walk-ins. As a result, these 

two categories of equipment would not 

be required to meet the standards that 

DOE has detailed in this notice. In 

delineating these equipment, in DOE’s 

view, a blast chiller (or shock chiller) 

refers to a type of cooling device that is 

designed specifically to, when fully 

loaded, cool its contents from 150 °F to 

55 °F in less than 90 minutes. Similarly, 

a blast freezer (or shock freezer) refers 

to a type of freezer that is designed 

specifically to, when fully loaded, cool 

its contents from 150 °F to 32 °F in less 

than 90 minutes. 

While DOE believes that the above 

descriptions should be sufficiently clear 

to enable manufacturers to readily 

determine whether a particular device 

they produce falls under these 

descriptions, DOE may revise these 

descriptions in the future through 

guidance should additional clarification 

be necessary. 

Special Application Walk-In Coolers 

Several commenters suggested that 

certain walk-in coolers designed for 

special applications should be excluded 

from the rulemaking. ebm-papst 

commented that the proposed standard 

did not separate low-velocity and lowprofile unit coolers. (ebm-papst, No. 92 

at p. 4) NCC and KeepRite commented 

that two-way or low-velocity coolers 

were designed as food-processing 

workspaces, and should be excluded 

from the scope of the proposed rule. 

(NCC, No. 96 at p. 2; K–RP, No. 105 at 

p. 2) SAF noted that the floriculture 

industry had unique requirements with 

regard to air movement and humidity 

for walk-in coolers since potted plants 

and cut flowers had a rapid rate of 

respiration, and further expressed 

concern that the proposed standard did 

not account for the large degree of 

customization used in the engineering 

of floral storage units due to the higher 

humidity and gentle airflow required. 

(SAF, No. 103 at pp. 3 and 7) 

Manitowoc commented that grouping 

packaged refrigeration systems with 

split systems would make it difficult for 

packaged systems to meet the proposed 

standard levels at a reasonable cost, 

since packaged systems were typically 1 

horsepower (hp) or less, and increased 

efficiency would have a greater cost 

impact. (Manitowoc, No. 108 at p. 2) 

Lennox stated that there were no known 

test laboratories in the U.S. that were 

certified or fully capable of testing the 

range of products and application 

temperatures covered by the proposed 

rule. (Lennox, No. 109 at p. 2) 

With respect to low-velocity and 

floral application coolers, DOE agrees 

that there is a certain category of 

medium- and low-temperature unit 

coolers that are characterized by low 

airflow. In medium-temperature 

applications, these unit coolers may also 

be operated at a higher-than-usual 

temperature difference between the 

evaporator coil and the air, which 

contributes to a high humidity 

environment necessary for some 

applications. (For more details on 

temperature difference, see section 

IV.D.5.b.) Because these products are 

used for both storage and process 

applications, DOE cannot categorically 

exclude them from coverage, although 

DOE notes that equipment used for 

process cooling applications is excluded 

from the WICF standards. Also, DOE has 

not found evidence that such products 

would be at a disadvantage by having to 

satisfy the standards being adopted 

today, when tested under the rating 

conditions in the test procedure. In 

response to Manitowoc’s comment, 

Manitowoc did not provide, nor has 

DOE found, evidence that packaged 

systems would have difficulty meeting 

the proposed standard; DOE notes that 

for dedicated condensing systems, 

which would include packaged systems, 

its standards for smaller systems are 

lower than those for larger systems and 

the required efficiency for smaller 

systems decreases with system size. To 

address Lennox’s concern, if a 

manufacturer believes that the test 

procedure in its current form does not 

measure the efficiency of a model of 

covered equipment in a manner 

representative of its true energy use, the 

manufacturer may apply for a test 

procedure waiver for that model. 

High-Temperature Products 

Hillphoenix commented that the 

definition of a walk-in cooler as having 

a maximum temperature of 55 °F was 

incongruent with the NSF limit of 41 °F 

as the maximum safe temperature for 

food. (Hillphoenix, No. 107 at p. 1) ICS, 

et al., American Panel, IB, Kysor, and 

ThermoKool suggested that DOE revise 

its definition of a walk-in cooler to align 

with the NSF’s requirement of food 

storage at or below 41 °F. (ICS, et al., 

No. 100 at p. 3; APC, No. 99 at p. 2; IB, 

No. 98 at p. 1; Kysor, Public Meeting 

Transcript, No. 88 at p. 40; ThermoKool, 

No. 97 at p. 1) Hussmann expressed 

concern that if the standards cover 

products up to 55 degrees, it may cover 

some products that have very different 

energy profiles than traditional [food] 

storage systems. (Hussmann, Public 

Meeting Transcript, No. 88 at p. 62) 

Lennox, however, agreed with DOE’s 

proposal to base the definition of 

freezers vs. coolers on an operating 

temperature [at or] below and above 

32 °F, respectively. (Lennox, No. 109 at 

p. 5) 

DOE recognizes that the NSF requires 

food storage at 41 °F or below. However, 

DOE is retaining its definition of walkin coolers and freezers because while 

the foodservice industry accounts for a 

large portion of the walk-in cooler 

market, these units also have 

applications in other industries, which 

do not fall within the ambit of the NSF 

standard. DOE notes that it based its 

analysis on coolers operating at 35 °F 

(the AHRI 1250 test procedure rating 

temperature for coolers), which should 

not disadvantage products that must 

comply with the NSF requirement. 

2. Equipment Classes 

In evaluating and establishing energy 

conservation standards, DOE generally 

divides covered equipment into classes 

by the type of energy used, or by 

capacity or other performance-related 

feature that justifies a different standard 

for equipment having such a feature. (42 

U.S.C. 6295(q) and 6316(a)) In deciding 

whether a feature justifies a different 

standard, DOE must consider factors 

such as the utility of the feature to users. 

DOE normally establishes different 

energy conservation standards for 

different equipment classes based on 

these criteria. In the NOPR, DOE 

proposed separate classes for panels, 

display doors, non-display doors, and 

refrigeration systems because each 

component type has a different utility to 

the consumer and possesses different 

energy use characteristics. 


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a. Panels and Doors 

In the NOPR, DOE proposed three 

equipment classes for walk-in panels: 

cooler structural panels, freezer 

structural panels, and freezer floor 

panels. DOE’s proposal was based on 

the understanding 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 

freezer, must often support the load of 

small machines like hand carts and 

pallet jacks. Structural panels are panels 

used to construct the ceiling or wall of 

a walk-in, provide structure for the 

walk-in. 

Structural panels are further divided 

into two more classes based on 

temperature—i.e., cooler versus freezer 

panels. Cooler structural panels are 

rated at an average foam temperature of 

55 °F, as required in the test procedure. 

Freezer structural panels are used in 

walk-in freezers and rated at an average 

foam temperature of 20 °F, also a test 

procedure requirement. See 79 FR at 

27412. Walk-in freezer panels must also 

meet a higher R-value than walk-in 

cooler panels. See 10 CFR 431.306. 

For doors, DOE distinguished 

between two different door types used 

in walk-ins: display doors and nondisplay doors. DOE proposed separate 

classes for display doors and nondisplay 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)) Non-display 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 non-display 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. DOE’s test procedure contains 

an internal rating temperature of 35 °F 

for walk-in cooler display doors and 

¥10 °F for walk-in freezer display 

doors. See 76 FR at 21606 and 10 CFR 

431.303 

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. 

One stakeholder agreed with DOE’s 

classification of equipment. Nor-Lake 

commented that the proposed 

definitions for all three door equipment 

classes appeared to be reasonable. (NorLake, No. 115 at p. 1) 

Other stakeholders recommended 

changes to the envelope equipment 

classes. Hillphoenix noted that 

classifying doors based on whether they 

were display or non-display doors, and 

whether they were hinged or nonhinged would allow for standards that 

would better represent their 

performance. (Hillphoenix, No. 107 at p. 

3) ICS, et al., recommended that DOE 

categorize door panels with wall, floor, 

and ceiling panels and account for 

electrical consuming devices separately. 

(ICS, et al., No. 100 at pp. 2 and 3) 

American Panel also suggested that nondisplay doors should be classified with 

panels for the purpose of this 

rulemaking because they share the same 

R-value. (APC, No. 99 at p. 2) IB agreed 

with the proposed classes of panels and 

requested that door panels be included 

in these categories as they are 

manufactured from the same materials 

as those used in wall, floor and ceiling 

panels. (IB, No. 98 at p. 3) 

DOE agrees that non-display doors are 

very similar to panels because both 

components are primarily composed of 

insulation. However, non-display doors 

have a different utility than panels and 

for that reason may require features, like 

windows or heater wire, which walk-in 

panels do not require. For this reason, 

in this final rule the Department is 

creating separate equipment classes for 

non-display doors and panels. 

The Department did not receive any 

adverse comments regarding the 

equipment classes proposed for display 

doors. 

The equipment classes being adopted 

are listed in Table IV.1 below. 

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 

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

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

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

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

b. Refrigeration Systems 

In the NOPR, DOE divided 

refrigeration systems into classes based 

on condensing unit type (i.e. whether 

the refrigeration system uses a dedicated 

condensing unit or is connected to a 

multiplex system), operating 

temperature (whether the system is 

designed to operate at medium or low 

temperature, corresponding to a walk-in 

cooler or walk-in freezer, respectively), 

location (for dedicated condensing 

systems, whether the condensing unit is 

located indoors or outdoors), and size 

(for dedicated condensing systems, 

whether the gross refrigerating capacity 

exceeds or is less than 9,000 Btu/h). 

DOE received comments on its proposed 

equipment classes. 

General Comments 

NAFEM and Lennox opined that the 

equipment classes defined in the 

proposed rule did not fully encompass 

the variety of products and 

customizations currently available on 

the market. (NAFEM, No. 118 at p. 3; 

Lennox, No. 109 at p. 2) The CA IOUs 

suggested that the standard would be 

more enforceable if, instead of 

classifying products as dedicated 

condensing or multiplex condensing, 

WICF refrigeration is treated like 

commercial refrigeration equipment, 

with separate classes for self-contained 

systems, unit coolers, and condensing 

units. In its view, this approach would 

address the splitting of the unit cooler 

from the condensing unit in cases where 

they are separate. (CA IOUs, No. 89 at 

p. 19 and Public Meeting Transcript, 

No. 88 at pp. 30 and 103) ASAP 

commented that DOE should set a 

standard level for packaged dedicated 

refrigeration systems. (ASAP et al., No. 

113 at p. 2) American Panel pointed out 

that the current classification did not 

account for pre-charged units (i.e. 

refrigeration units that come ‘‘precharged’’ with refrigerant coolant added 

to the unit). (APC, No. 99 at p. 3) 

DOE takes note of manufacturer 

comments that the representative sizes 

in DOE’s analysis do not fully 


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encompass the large variety of products 

and possible customizations. While 

recognizing that it would be impossible 

to model each and every one of these 

niche products, DOE has not changed 

the equipment classes or representative 

units from those analyzed in the NOPR, 

since these classes and units represent 

a large majority of the total market for 

walk-in coolers and freezers. DOE has 

not found, nor have stakeholders 

provided evidence, that ‘‘niche’’ 

products would be unable to meet the 

standards based on current equipment 

classification. DOE believes that its 

approach to testing and certification of 

unit coolers and condensing units sold 

separately addresses the comment from 

CA IOUs, and separate equipment 

classes are not needed; see section III.C 

for further discussion of certification. If 

a manufacturer believes that its design 

is subjected to undue hardship by 

regulations, the manufacturer may 

petition DOE’s Office of Hearings and 

Appeals (OHA) for exception relief or 

exemption from the standard pursuant 

to OHA’s authority under section 504 of 

the DOE Organization Act (42 U.S.C. 

7194), as implemented at subpart B of 

10 CFR part 1003. OHA has the 

authority to grant such relief on a caseby-case basis if it determines that a 

manufacturer has demonstrated that 

meeting the standard would cause 

hardship, inequity, or unfair 

distribution of burdens. 

Condensing Unit Location 

Lennox commented that for dedicated 

condensing units, systems 

manufactured and certified as outdoor 

units should be allowed to be used 

indoors without having to certify their 

units as indoor units as well; this 

approach would greatly reduce the 

testing and certification burden on 

manufacturers. (Lennox. No. 109 at p. 6) 

On the other hand, AHRI noted that it 

was possible for manufacturers to 

market a unit for use indoors, whereas 

contractors could choose to assemble it 

outdoors, where it may not meet the 

requisite standard. (AHRI, Public 

Meeting Transcript, No. 88 at p. 106) 

DOE understands that indoor and 

outdoor refrigeration systems are rated 

differently under the DOE test 

procedure, and this warrants the 

creation of separate equipment classes 

for indoor and outdoor refrigeration 

systems. Furthermore, indoor and 

outdoor refrigeration systems are often 

easily distinguishable visually: outdoor 

systems are characterized by a metal 

cover that protects the system from the 

elements. DOE realizes that a product 

may be used in a different application 

from which it was originally designed. 

In response to Lennox’s comment, the 

standard for an outdoor refrigeration 

system is generally more stringent than 

for an indoor refrigeration system of the 

same size and operating temperature. 

Therefore, DOE is not opposed to 

systems rated as outdoor systems being 

used in practice as indoor systems, 

without having to be separately certified 

as ‘‘indoor’’ systems. Conversely, as 

AHRI pointed out, an indoor system 

used outdoors would not likely meet the 

requisite standard. DOE believes that in 

practice, this is not likely to occur at a 

significant rate because indoor units 

lack the protective features of outdoor 

units and therefore would be very 

unlikely to be installed outdoors. 

However, if DOE finds that indoor 

systems are being installed outdoors so 

as to circumvent the more stringent 

requirements for outdoor systems, DOE 

may promulgate future labeling 

standards specifying that a unit used 

outdoors must be labeled as an outdoor 

unit. 

Capacity 

Lennox commented that the proposed 

classification for unit coolers did not 

fully account for various applications 

and that for dedicated condensing 

systems, the proposed equipment 

classification did not fully reflect the 

range currently available in the market. 

Further, Lennox noted that linear 

equations for units with capacity up to 

36,000BTU/h, and fixed values for units 

with higher capacity, would be 

reasonable. (Lennox, No. 109 at p. 5) 

Similarly, on the classification of 

condensing systems, KeepRite 

commented that the definition between 

large and small classes at 9,000 Btu/hr 

was fairly low, and left a 

disproportionately wide range of 

products in the ‘‘Large’’ category. (K– 

RP, No. 105 at p. 2) American Panel, 

too, made a similar suggestion, 

recommending that equipment be 

divided into three categories—small 

(<10,000 Btu), medium, and large 

(>25,000 Btu)—to better represented the 

market. (APC, No. 99 at p. 3) Heatcraft 

stated that DOE did not look at a broad 

enough range of equipment, and that 

refrigeration systems can get up to 

190,000 Btus in the 3,000 square foot 

range. (Heatcraft, Public Meeting 

Transcript, No. 88 at p. 102) 

In response to the comments from 

Lennox, KeepRite, and American Panel 

suggesting that separating the ‘‘large’’ 

equipment class could better represent 

the market, DOE notes that above the 

threshold for ‘‘large’’ equipment, the 

standard level is equally attainable by 

varying sizes of equipment. DOE did not 

receive data or evidence from Heatcraft 

suggesting that systems larger than the 

ones analyzed would have difficulty 

meeting DOE’s standards. Therefore, 

DOE is maintaining the size thresholds 

for refrigeration system classes proposed 

in the NOPR. 

In this document, the Department is 

adopting the equipment classes listed in 

Table IV.2. 

TABLE IV.2—EQUIPMENT CLASSES FOR REFRIGERATION SYSTEMS

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. 


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3. Technology Assessment 

As part of the market and technology 

assessment performed for the final rule 

analysis, DOE developed a 

comprehensive list of technologies that 

would be expected to improve the 

energy efficiency of walk-in panels, 

non-display doors, display doors, and 

refrigeration systems. Chapter 3 of the 

TSD contains a detailed description of 

each technology that DOE identified. 

Although DOE identified a number of 

technologies that improve efficiency, 

DOE considered in its analysis only 

those technologies that would impact 

the efficiency rating of equipment as 

tested under the DOE test procedure. 

Therefore, DOE excluded several 

technologies from the analysis during 

the technology assessment because they 

would not improve the rated efficiency 

of equipment as measured under the 

specified test procedure. Technologies 

that DOE determined would impact the 

rated efficiency were carried through to 

the screening analysis and are discussed 

in section IV.C. 

ACEEE commented that there were 

significant technology options used 

abroad which could, if included in the 

DOE analysis, provide greater potential 

for energy savings. (ACEEE, Public 

Meeting Transcript, No. 88 at p. 142) 

However, ACEEE did not identify any 

specific technology options and in the 

absence of an actionable 

recommendation, DOE is continuing to 

apply its methodology. DOE notes that 

its methodology does not exclude 

technology options primarily used 

outside the U.S. if they meet the 

requirements of the screening analysis. 

C. 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 are not 

technologically feasible; are not 

practicable to manufacture, install, or 

service; have adverse impacts on 

product utility or product availability; 

or have adverse impacts on health or 

safety. 10 CFR part 430, subpart C, 

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

1. Panels and Doors 

DOE proposed three efficiency 

improvements for walk-in panels: 

insulation thickness, insulation 

material, and framing material. 

Subsequent to the NOPR’s publication, 

DOE modified its regulations to permit 

manufacturers to use ASTM C518— 

which measures panel performance by 

examining the panel’s insulation 

performance—rather than ASTM 

C1363—which accounts for, among 

other things, the impact of structural 

members in a panel.. Because of this 

change, framing materials no longer 

impact the rated efficiency of walk-in 

panels—and hence, are no longer 

considered as design options. 

Some manufacturers and consumers 

urged DOE to screen out any design 

options which would even marginally 

affect the geometry of a unit, either by 

increasing its total footprint or reducing 

the cooled internal space. Specifically, 

these comments referred to DOE’s 

consideration of added insulation 

thickness as a design option. ICS, et al., 

Louisville Cooler, and NRA noted that 

the increased footprint or decreased 

internal volume associated with thicker 

foam panels reduced storage utility and 

increased cost, perhaps even requiring 

full kitchen redesigns.(ICS, et al., No. 

100 at p. 4; Louisville Cooler, No. 81 at 

p. 1; NRA, No. 112 at p. 4) SAF 

expressed concern that some of the 

design options considered in the WICF 

analysis, like thicker insulation, would 

reduce the size of the walk-in and cause 

a substantial negative impact on floral 

industry businesses. (SAF, No. 103 at p. 

7) 

DOE understands stakeholder 

concerns that increased panel thickness 

may reduce the interior space of a walkin and affect the equipment’s utility. 

DOE discussed the relationship between 

panel thickness and interior walk-in 

space during the manufacturer 

interviews. During the interviews, 

manufacturers agreed that the addition 

of 1⁄2′′ of insulation above the baseline 

thicknesses modeled would be accepted 

by commercial customers. 

Manufacturers noted that increased 

panel thickness would require them to 

redesign their equipment and, in some 

cases, replace current foaming fixtures. 

DOE incorporated these potential 

outcomes into its engineering and 

manufacturer impact analyses. 

Regarding insulation greater than 1⁄2 an 

inch above the baseline thickness 

having an impact on the usefulness of 

the product to consumers, DOE notes 

that manufacturers are already 

employing these wall thicknesses in 

currently-available models. DOE 

believes that fact demonstrates that 

using thicker insulation is a viable 

technology option. Accordingly, DOE 

did not screen out increased panel 

thickness from its analysis. 

In the NOPR, DOE proposed to screen 

in the following technologies for nondisplay doors: insulation thickness, 

insulation material, framing material, 

improved window glass systems, and 

anti-sweat heat controls. 

DOE also proposed to ‘‘screen in’’ 

electronic lighting ballasts and highefficiency lighting, occupancy sensors, 

improved glass system insulation 

performance, and anti-sweat heater 

controls as technologies that could 

improve the performance of display 

doors are rated by the test procedure. 

Several manufacturers were 

concerned with DOE’s proposal to 

require tinted glass for transparent 

doors. Hussmann, ACCA and the 

California IOU’s noted that the use of 

low-e coatings on high-performance 

display doors would add a considerable 

tint to the glass, making product 

visibility difficult and impacting 

consumer utility. (Hussmann, No. 93 at 

p. 2) (ACCA, No. 119 at p. 2) (CA IOUs, 

No. 88 at p. 152) SAF commented that 

low-e coating would obscure floral 

products, and have a negative impact on 

the U.S. floral industry. (SAF, No 103 at 

pp. 6–7) 

DOE clarifies that the performance 

standards proposed in the NOPR did not 

require manufacturers to use low-e 

coating on their doors. Low-e coating 

was considered as a design option. In 

the NOPR, DOE proposed TSL 4 which 

mapped to display cooler doors at 

efficiency level 1 (a baseline cooler door 

with LED lighting instead of fluorescent 

lighting) and mapped to baseline freezer 

doors. Baseline cooler doors do have 

one layer of hard coat low-e coating, but 

DOE expects that manufacturers could 

achieve this same level of performance 

by incorporating other design options 

like an additional pane of glass or a 

lighting sensor. Baseline display freezer 

doors do not have low-e coating. DOE 

notes that its market research shows that 

some display doors may have a low-e 

coating. While not all doors may have 

this feature, it is a viable one that 

manufacturers could opt to use in 

certain circumstances when 

appropriate. DOE also would like to 

remind stakeholders that it is not setting 

prescriptive standards, and should 

manufacturers value some features over 

others, they are free to use different 

design paths in order to attain the 

performance levels required by this rule. 

American Panel suggested that DOE 

should consider air curtains, a device 

that blows air parallel to an opening to 

create an infiltration barrier, because the 

technology would reduce air 

infiltration, a major contributor to the 

heat load in a walk-in. American Panel 

commented that air curtains may save 

almost as much energy as freezer panels 

with 5-inches of insulation. (American 

Panel, No. 99 at p. 10) Manitowoc also 

commented that the largest factor to 

energy consumption was door open 

time and that cooler doors may be open 


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more than 200 times per day. 

Manitowoc suggested that door closers 

would significantly reduce energy 

consumption. (Manitowoc, No. 108 at p. 

1) DOE agrees with American Panel and 

Manitowoc that infiltration adds heat 

load to walk-ins and that air curtains 

can be used to reduce infiltration. 

However, DOE’s test procedure 

establishes metrics to measure the 

energy consumption or energy use of 

walk-in components and does not 

include the heat load caused by 

infiltration. See 76 FR at 21594–21595. 

As a result, infiltration-related 

technologies do not improve the rated 

performance of walk-ins. 

2. Refrigeration Systems 

NRA commented that reducing the 

energy usage of walk-ins has the 

potential to reduce cooling recovery 

time for equipment subjected to 

constant door openings and closings in 

busy kitchen environments, which 

could result in food spoilage and create 

public health and safety risks. (NRA, 

No. 112 at p. 3) DOE’s analysis has not 

shown that the improvements in 

equipment efficiency required by its 

standards would negatively impact the 

capacity of that equipment or its cooling 

ability; therefore, DOE does not believe 

its standards alone would be likely to 

increase the risks to public health and 

safety. As noted earlier, DOE has 

screened from consideration particular 

design options that it believes may pose 

undue risks to health and safety. 

D. Engineering Analysis 

The engineering analysis determines 

the manufacturing costs of achieving 

increased efficiency or decreased energy 

consumption. DOE historically has used 

the following three methodologies to 

generate the manufacturing costs 

needed for its engineering analyses: (1) 

The design-option approach, which 

provides the incremental costs of adding 

to a baseline model design options that 

will improve its efficiency; (2) the 

efficiency-level approach, which 

provides the relative costs of achieving 

increases in energy efficiency levels, 

without regard to the particular design 

options used to achieve such increases; 

and (3) the cost-assessment (or reverse 

engineering) approach, which provides 

‘‘bottom-up’’ manufacturing cost 

assessments for achieving various levels 

of increased efficiency, based on 

detailed data as to costs for parts and 

material, labor, shipping/packaging, and 

investment for models that operate at 

particular efficiency levels. 

As discussed in the Framework 

document, preliminary analysis, and 

NOPR analysis, DOE conducted the 

engineering analyses for this rulemaking 

using a design-option approach for 

walk-ins. The decision to use this 

approach was made due to several 

factors, including the wide variety of 

equipment analyzed, the lack of 

equipment efficiency data regarding 

currently available equipment, and the 

prevalence of relatively easily 

implementable energy-saving 

technologies applicable to this 

equipment. More specifically, DOE 

identified design options for analysis, 

used a combination of industry research 

and teardown-based cost modeling to 

determine manufacturing costs, and 

employed numerical modeling to 

determine the energy consumption for 

each combination of design options 

used to increase equipment efficiency. 

Additional details of the engineering 

analysis are available in chapter 5 of the 

final rule TSD. 

1. Representative Equipment for 

Analysis 

In performing its engineering analysis, 

DOE selected representative units for 

each primary equipment class to serve 

as analysis points in the development of 

cost-efficiency curves. 

a. Panels and Doors 

DOE proposed three different panel 

sizes to represent the variations within 

each class. Table IV.3 shows each 

equipment class and the representative 

sizes associated with that class. 

TABLE IV.3—SIZES ANALYZED: PANELS

Equipment family name Equipment 

family code 

Temperature 

code Size code Representative height (feet) 

Representative 

width (feet) 

Structural Members ................................................................... S .................. C ................. S .................. 8 1 .5 

M ................. 8 4 

L .................. 9 5 .5 

F .................. S .................. 8 1 .5 

M ................. 8 4 

L .................. 9 5 .5 

Floor Panels .............................................................................. F .................. F .................. S .................. 8 2 

M ................. 8 4 

L .................. 9 6 

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. 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 family name Equipment 

family code 

Temperature 

code Size code Representative height (feet) 

Representative 

width (feet) 

Passage Doors ........................................................................ D ................. C ................. S .................. 6 .5 2 .5 

M ................. 7 3 

L .................. 7 .5 4 

F .................. S .................. 6 .5 2 .5 

M ................. 7 3 

L .................. 7 .5 4 

Freight Doors .......................................................................... F .................. C ................. S .................. 8 5 

M ................. 9 7 

L .................. 12 7 


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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. 

TABLE IV.4—SIZES ANALYZED: NON-DISPLAY DOORS—Continued 

Equipment family name Equipment 

family code 

Temperature 

code Size code Representative height (feet) 

Representative 

width (feet) 

F .................. S .................. 8 5 

M ................. 9 7 

L .................. 12 7 

TABLE IV.5—SIZES ANALYZED: DISPLAY DOORS

Equipment family name Equipment 

family code 

Temperature 

code Size code Representative height (feet) 

Representative 

width (feet) 

Display Doors .......................................................................... D ................. C .................. S .................. 5 .25 2 .25 

M ................. 6 .25 2 .5 

L .................. 7 3 

F .................. S .................. 5 .25 2 .25 

M ................. 6 .25 2 .5 

L .................. 7 3 

American Panel commented that 

freight doors are typically more than 5 

ft wide in order to allow for forklifts to 

pass through. (American Panel, No. 99 

at p. 3) DOE notes that all the freight 

doors evaluated were 5ft or more in 

width, as shown in Table IV.4. 

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.B.2.b. In addition to the multiple 

analysis points, scroll, hermetic, and 

semi-hermetic compressors were also 

investigated because different 

compressor types have different 

efficiencies and costs.15

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 

TSD includes additional details on the 

representative equipment sizes and 

classes used in the analysis. 

TABLE IV.6—SIZES ANALYZED FOR REFRIGERATION SYSTEM ANALYSIS

Equipment class Sizes analyzed 

(Btu/h) Compressor types 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. Refrigerants 

DOE used R404A, a 

hydrofluorocarbon (HFC) refrigerant 

blend, in its analysis for this NOPR 

because it is widely used currently in 

the walk-in industry, but requested 

comment on the ability of systems using 

other refrigerants to meet a standard 

based on systems with 404A. 78 FR at 

55799. Several stakeholders suggested 

that future refrigerant policy would play 

a role in dictating which refrigerant 

would be used with future refrigeration 

systems and noted this possibility in 

response to the engineering analysis. 


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AHRI commented that future changes in 

refrigerant policy were likely to drive 

the market towards low global warming 

potential (GWP) refrigerants, which 

could detrimentally affect the 

performance and efficiency of units. 

(AHRI, No. 114 at p. 5) KeepRite stated 

that policies in the near future may 

require the phase-out of 404A in favor 

of low-GWP refrigerants which may be 

less efficient than 404A, making it more 

difficult to meet the proposed standard. 

(KeepRite, No. 105 at p. 2) Hussmann 

agreed that upcoming policies would 

likely require the phasing-out of 404A 

in favor of low-GWP refrigerants, which 

could negatively affect system 

performance (Hussmann, No. 93 at p. 2) 

ICS, et al. opined that the DOE analysis 

did not sufficiently factor in the 

impending phase-out of HFCs. (ICS, et 

al., No. 100 at p. 10) Lennox agreed that 

alternative refrigerants were likely to see 

growing adoption in walk-ins over the 

timeline of the rule, but added that this 

factor may affect the achievable 

efficiency of a unit either positively or 

negatively. It suggested that DOE should 

be prepared to establish separate classes 

for equipment that uses non-HFC 

refrigerants if they have an adverse 

impact on equipment performance. 

(Lennox, No. 109 at p. 4) Danfoss noted 

that a change in policy requiring lowGWP refrigerants would greatly impact 

the cost of production of refrigeration 

systems, as WICF units use a relatively 

large volume of charge. (Danfoss, Public 

Meeting Transcript, No. 88 at p. 164) 

Manitowoc stated that moving from 

HFCs to alternative refrigerants would 

increase cost. (Manitowoc, No. 108 at p. 

2) 

At this time, DOE does not believe 

that there is sufficient specific, 

actionable data presented at this 

juncture to warrant a change in its 

analysis and assumptions regarding the 

refrigerants used in walk-in cooler and 

freezer applications. As of now, there is 

inadequate publicly-available data on 

the design, construction, and operation 

of equipment featuring alternative 

refrigerants to facilitate the level of 

analysis of equipment performance 

which would be needed for standardsetting purposes. DOE is aware that 

many low-GWP refrigerants are being 

introduced to the market, and wishes to 

ensure that this rule is consistent with 

the phase-down of HFCs proposed by 

the United States under the Montreal 

Protocol. DOE continues to welcome 

comments on experience within the 

industry with the use of low-GWP 

alternative refrigerants. However, there 

are currently no mandatory initiatives 

such as refrigerant phase-outs driving a 

change to alternative refrigerants. 

Absent such action, DOE will continue 

to analyze the most commonly-used, 

industry-standard refrigerants in its 

analysis. 

DOE wishes to clarify that it will 

continue to consider WICF models 

meeting the definition of walk-in 

coolers and freezers to be part of their 

applicable covered equipment class, 

regardless of the refrigerant that the 

equipment uses. If a manufacturer 

believes that its design is subjected to 

undue hardship by regulations, the 

manufacturer may petition DOE’s Office 

of Hearing and Appeals (OHA) for 

exception relief or exemption from the 

standard pursuant to OHA’s authority 

under section 504 of the DOE 

Organization Act (42 U.S.C. 7194), as 

implemented at subpart B of 10 CFR 

part 1003. OHA has the authority to 

grant such relief on a case-by-case basis 

if it determines that a manufacturer has 

demonstrated that meeting the standard 

would cause hardship, inequity, or 

unfair distribution of burdens. 

3. Baseline Specifications 

a. Panels and Doors 

In the NOPR, 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. More detail about the 

specifications for each baseline model 

can be found in chapter 5 of the TSD. 

DOE proposed that the baseline cooler 

structural panels would be comprised of 

3.5 inches of polyurethane insulation, 

with wood framing members around the 

perimeter of the panel. Baseline freezer 

structural panels had 4-inches of 

polyurethane insulation, with wood 

framing members around the perimeter 

of the panel. Baseline freezer floor 

panels had 3.5 inches of polyurethane 

insulation with wood framing materials 

around the perimeter of the panel and 

additional wood structural material in 

the panel. 

Nor-Lake and Thermo Kool 

commented that DOE’s baseline panels 

seemed reasonable. (Nor-Lake, No. 115 

at p. 2; Thermo Kool, No 97 at p. 2) 

American Panel made a number of 

suggestions regarding baseline panels. 

American Panel stated that 85% of the 

floor panels they built did not need 

additional structural members because 

they were going into restaurants. Thus, 

the floor panel is very similar to the 

structural panel. (American Panel, 

Public Meeting Transcript, No. 88 at p. 

90) Additionally, American Panel 

commented that a 3.5-inch thick wood 

framed panel is not representative of the 

baseline for walk-in cooler structural 

panels. Baseline structural cooler panels 

should be 4 inches thick because that 

has the food service industry standard 

for the last 10 to 20 years. Regarding 

freezer panels materials, American 

Panel estimated that less than 5% of the 

total market share has wood framing 

materials. (American Panel, No. 99 at p. 

4) At the NOPR public meeting, 

American Panel generally stated that 

wood and hard nose framing material is 

not commonly used with foam-in-place 

polyurethane insulation. (American 

Panel, Public Meeting Transcript, No. 88 

at p. 128) Kinser also stated that 4-inch 

thick urethane panels without framing 

materials would be a representative 

baseline. (Kinser, No. 81 at p. 1) US 

Cooler also disagreed with the baseline 

assumptions and noted that by 

misrepresenting the baseline, DOE 

could overestimate the monetary and 

emissions savings resulting from this 

rulemaking. (US Cooler, Public Meeting 

Transcript, No. 88 at p. 129) NEEA 

stated that most panel manufacturers 

were using high density PU foam as 

panel framing instead of wood. (NEEA, 

No. 101 at p. 3) 

DOE agrees with stakeholders that 

wood is not the predominate type of 

framing material in the WICF market, 

but it is present in the market. In a 

separate rulemaking, DOE proposed to 

eliminate the ASTM C1363 test, which 

measures the full panel thermal 

conductivity and accounts for features 

such as framing materials. (DOE 

subsequently finalized that proposal. 

See 79 FR at 27391 and 27405–27406.) 

Therefore, the impacts of framing 

material would not be captured by the 

WICF test procedure and framing 

material was no longer considered a 

design option for walk-in panels. In the 

final rule analysis, DOE incorporated 

high density polyurethane as the 

framing material for walk-in panels in 

order to more accurately capture the 

typical construction and cost of a 

baseline panel. However, for nondisplay doors, DOE continued to use 

wood as the baseline framing material, 

but DOE accounted for the market share 

of the baseline type unit and other 

design options in its efficiency 

distribution as part of the shipments 

analysis. See TSD chapter 9. 

At the NOPR public meeting, Arctic 

noted that solid core foam insulation, 

which DOE interprets as extruded 

polystyrene, is also found in the walkin market. (Arctic, Public Meeting 

Transcript, No. 88 at p. 126) US Cooler 

also commented that a sizable number 


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of units on the market use extruded 

polystyrene. US Cooler opined that 

polyurethane insulation did not have 

better long term thermal performance 

than extruded polystyrene. (US Cooler, 

No. 75 at p. 1) DOE agrees that some 

walk-ins use extruded polystyrene 

insulation, but found that the majority 

of panels are made with poured-in-place 

polyurethane. For its analysis of a 

representative panel, DOE continued to 

use one type of insulation material (i.e. 

poured-in-place polyurethane) in order 

to more accurately evaluate the energy 

consumption of a representative 

baseline walk-in panel. DOE notes that 

manufacturers can use any insulation or 

other features so long as they meet the 

energy conservation standard levels. 

In this final rule, DOE based its 

analysis on a representative model of a 

cooler structure panel by assuming that 

it is comprised of 3.5 inches of 

polyurethane insulation. Baseline 

freezer structural panels had 4-inches of 

polyurethane insulation. Baseline 

freezer floor panels had 3.5 inches of 

polyurethane insulation. As previously 

stated, DOE accounted for high density 

polyurethane framing materials in all 

types of panels, but the framing 

materials did not have an impact on the 

panel’s measured energy efficiency. 

DOE modeled a baseline cooler 

structural panel, freezer structural 

panel, and freezer floor panel to portray 

an industry representative baseline 

panel for these equipment classes. 

These baseline panels correspond to the 

most common, least efficient component 

found in the market that complies with 

the standards set forth in EPCA. (42 

U.S.C. 6313(f)(1)(3)) In the case of walkin cooler structural panels, the 

Department found that the most 

common, least efficient panel has an Rvalue that is higher than the current 

levels prescribed by EISA. However, the 

Department recognizes that there are 

other panel thicknesses and insulation 

materials employed in the WICF market. 

DOE used the baseline representative 

panels in its cost benefit evaluation to 

determine if energy efficiency 

improvements based on panel thickness 

were technologically feasible and 

economically justifiable. 

DOE’s NOPR analysis assumed that 

the baseline non-display doors are 

constructed in a similar manner to 

baseline panels. Therefore, DOE uses 

baseline non-display doors that consist 

of wood framing materials, foamed-inplace polyurethane insulation. Passage 

doors were assumed to have a 2.25- 

square foot window with anti-sweat 

heater wire. The small freight doors 

have a 2.25-square foot window with 

anti-sweat heater wire and both the 

medium and large freight doors have a 

4-square foot window with anti-sweat 

heater wire. DOE did not include heater 

wire in the perimeter of the cooler doors 

in its models, but included heater wire 

in the perimeter of freezer doors. 

Bally stated DOE should add heater 

wire to cooler doors because condensate 

from cooler doors could cause a 

workplace safety issue. (Bally, No. 102 

at p. 3) DOE agrees with Bally and for 

this reason added heater wire to the 

perimeter of non-display cooler doors. 

Nor-Lake, ICS, et al., and American 

Panel remarked that non-display doors 

typically do not have windows. (NorLake, No. 115 at pp. 1 and 2; ICS, et al., 

No. 100 at p. 4; American Panel, Public 

Meeting Transcript, No. 88 at p. 121) 

American Panel stated that less than 

20% of their non-display doors have 

windows. (American Panel, Public 

Meeting Transcript, No. 88 at p. 121) 

Manitowoc commented that 25% of 

non-display doors sold by its company 

were fitted with 1.36-square foot 

windows and 5% of non-display doors 

sold had 2.23-square foot windows. 

(Manitowoc, No. 108 at p. 2) DOE found 

from its manufacturer interviews that 

windows in non-display doors serve a 

specific utility for consumers by 

allowing the user to look through the 

window instead of opening the door 

causing heat gain through infiltration. 

Therefore, DOE modeled its walk-in 

cooler doors with windows. 

At the public meeting Bally noted that 

consumers may choose to have 

windows on WICF doors, and these 

windows would need additional power 

to eliminate condensation. Therefore, 

Bally urged DOE to regulate doors 

(which DOE interprets to mean the door 

insulation) separately from windows 

and other electrical components. (Bally, 

Public Meeting Transcript, No. 88 at p. 

379). DOE agrees with Bally that 

windows require heater wire to 

eliminate condensation and accounted 

for this power consumption in the 

engineering analysis. DOE is choosing 

not to regulate windows and electrical 

components separately from the door 

because they are inherent to a given 

door’s total energy consumption. Each 

of these components contributes to the 

door’s efficiency performance, much 

like the insulation in the door does. 

Hillphoenix commented that passage 

doors do not have complete frames, but 

instead use backings made of wood, 

fiber re-enforced plastic, or other 

materials. (Hillphoenix, Public Meeting 

Transcript, No. 88 at p. 131) DOE’s own 

research through manufacturer 

interviews or market research did not 

indicate that a majority of walk-in nondisplay doors were constructed with 

wood backings instead of wood framing 

material. Accordingly, DOE continued 

to model the baseline non-display door 

with a complete wood frame. 

Nor-Lake expressed concern that DOE 

misinterpreted EPCA’s requirements for 

windows in non-display doors, but 

offered no specific details as to how 

DOE misinterpreted EPCA. (Nor-Lake, 

No. 115 at p. 2) DOE notes that all the 

windows and display doors must meet 

the design requirements specified in 10 

CRF 431.306(b). 

Nor-Lake commented that freezer 

windows in non-display doors tend not 

to be gas-filled since they have heated 

glass and the heater wires allow the gas 

to escape. (Nor-Lake, No. 115 at p. 2) In 

the display door market, DOE found that 

freezer display doors have both gas fill 

and anti-sweat heater wire. From an 

engineering perspective, it is unclear 

why windows in non-display doors 

would be significantly different from the 

glass packets used in display doors. 

DOE received no other comments 

stating that windows in freezer nondisplays would lose all gas fill due to 

anti-sweat heater wire. Accordingly, 

both design features are included in the 

analysis. 

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, 

hard coat low emittance or low-e 

coating, 2.9 Watts per square foot of 

anti-sweat heater wire, no heater wire 

controller, and one fluorescent light. 

The baseline display freezer doors 

modeled in DOE’s analysis consist of 

three panes of glass, argon gas, and soft 

coat low-e coating, 15.23 watts per 

square foot of anti-sweat heater wire 

power, an anti-sweat heater wire 

controller, and one fluorescent light. 

Thermo-Kool commented that the 

Department’s baseline for panels and 

doors was accurate. (Thermo-Kool, No. 

97 at p. 2) US Cooler noted that DOE 

considered heater wire in doors that 

remained on all the time, whereas most 

units in the market used wires which 

only came on as needed. (US Cooler, 

Public Meeting Transcript, No. 88 at p. 

143) DOE included heater wire 

controllers as a design option as a result 

of US Cooler’s comment. Bally remarked 

that a typical cooler display door draws 

about 1.15 amps or 1.6 Wh/day. (Bally, 

Public Meeting Transcript, No. 88 at p. 

135; Bally No. 102 at p.4) However, DOE 

found in its research that display doors 

typically drew more than 1.6 Wh/day— 

which prompted DOE to include a 

higher power draw in its engineering 

analysis. 


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16 Dew-point temperature is the vapor-liquid 

equilibrium point for a refrigerant mixture where 

the temperature of the mixture at a defined pressure 

is the maximum temperature required for a liquid 

drop to form in the vapor. (ANSI/ASHRAE 

Standard 23.1–2010, ‘‘Methods of Testing for Rating 

the Performance of Positive Displacement 

Refrigerant Compressors and Condensing Units that 

Operate at Subcritical Temperatures of the 

Refrigerant.’’) 

b. Refrigeration 

DOE determined baseline 

characteristics for refrigeration systems 

based on typical low-cost, lowefficiency products currently on the 

market that meet the standards set forth 

in EPCA See 42 U.S.C. 6313(f)(1)–(3). In 

the NOPR, DOE asked for comment on 

its assumptions about baseline 

equipment and received several 

responses, which are addressed below. 

In the NOPR, DOE tentatively 

proposed 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 

requested comment on this assumption. 

Hussmann agreed with DOE’s proposal 

that equipment such as piping that is 

used for final installation should not be 

included in the rulemaking. (Hussmann, 

No. 93 at p. 4) Thus, DOE has continued 

not to include such final installation 

components in its analysis. 

DOE made certain assumptions 

regarding the baseline temperature 

difference (TD) between saturated 

condensing temperature (SCT) and 

ambient air temperature for the 

condenser and between walk-in internal 

air temperature and saturated 

evaporating temperature (SET) for the 

evaporator that it used in the analysis 

for freezers and coolers and indoor and 

outdoor units. The SCT is the dew-point 

temperature 16 of the refrigerant that 

corresponds to the refrigerant pressure 

in the compressor discharge line at the 

entrance to the condenser, while the 

SET is the dew-point temperature of the 

refrigerant that corresponds to the 

refrigerant pressure at the exit of the 

evaporator. DOE’s baseline assumptions 

for the NOPR are listed in Table IV.10 

below. DOE notes that the temperatures 

of air entering the evaporator and 

condenser coils are prescribed by the 

test procedure. The temperature 

difference (TD) is calculated as the 

difference between the air temperature 

and the refrigerant temperature (SET or 

SCT). 

TABLE IV.10—SATURATION TEMPERATURES ASSUMED IN THE NOPR 

Application 

Temperature of air 

entering the evaporator 

coil 

(°F) 

Saturated evaporating 

temperature (SET) 

(°F) 

Temperature difference 

(TD) between entering 

air and SET 

(°F) 

Evaporator 

Medium Temperature .................................................................. 35 25 10 

Low Temperature ......................................................................... ¥10 ¥20 10 

Condenser 

Application Temperature of air entering the condenser coil 

(°F) 

Saturated condensing 

temperature (SCT) 

(°F) 

Temperature difference 

(TD) between entering 

air and SCT 

(°F) 

Medium Temperature Indoor ....................................................... 90 115 25 

Medium Temperature Outdoor .................................................... 95 115 20 

Low Temperature Indoor ............................................................. 90 110 20 

Low Temperature Outdoor .......................................................... 95 110 15 

Several interested parties commented 

on the values of SET, SCT, and/or TD 

used in the analysis. Nor-Lake pointed 

out that the TD for evaporators could 

range from 7 °F to 25 °F depending on 

the application. (Nor-Lake, No. 115 at p. 

2) Lennox commented that the DOE 

model used a constant condenser TD for 

fixed, floating, and variable speed 

calculations. (Lennox, No. 109 at p. 7) 

Lennox also stated that baseline SCT 

values of 120 °F for medium 

temperature applications and 115 °F for 

low temperature applications would be 

more in line with industry practice. 

(Lennox, No. 109 at p. 7) Heatcraft noted 

that the TDs DOE assumed were lower 

than industry standards. (Heatcraft, 

Public Meeting Transcript, No. 88 at p. 

135) 

DOE conducted further testing in 

preparing the final rule and observed 

the following SET, SCT, and TDs at the 

highest ambient rating condition (that 

is, a 95 °F ambient air temperature for 

the units tested): 


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TABLE IV.11—SATURATION TEMPERATURES OBSERVED DURING TESTING

Unit tested 

Temperature of air 

entering the evaporator 

coil 

(°F) 

Saturated evaporating 

temperature (SET) 

(°F) 

Temperature 

difference (TD) between 

entering air and SET 

(°F) 

Evaporator 

Medium Temperature Outdoor—Unit 1 ....................................... 35 22 13 

Medium Temperature Outdoor—Unit 2 ....................................... 35 20 15 

Low Temperature Outdoor—Unit 3 ............................................. ¥10 ¥10 10 

Low Temperature Outdoor—Unit 4 ............................................. ¥10 ¥21 11 

Condensor 

Unit tested 

Temperature of air 

entering the condenser 

coil 

(°F) 

Saturated condensing 

temperature (SCT) 

(°F) 

Temperature 

difference (TD) between 

entering air and SCT 

(°F) 

Medium Temperature Outdoor—Unit 1 ....................................... 95 109 14 

Medium Temperature Outdoor—Unit 2 ....................................... 95 114 20 

Low Temperature Outdoor—Unit 3 ............................................. 95 106 11 

Low Temperature Outdoor—Unit 4 ............................................. 95 106 11 

The test results for evaporator TDs are 

close to the values DOE assumed in the 

NOPR, while the test results for 

condenser TDs are equal to or lower 

than the values DOE assumed in the 

NOPR. Based on these test results, DOE 

continued to use its assumed values in 

Table IV.10 for SET, SCT, and TD at the 

highest ambient rating condition, with 

the exception of unit cooler (evaporator) 

TD for medium temperature systems, 

which DOE changed to 14 °F. To 

address Nor-Lake’s comment, DOE 

acknowledges that some units may 

operate with different evaporator TDs, 

and notes that if a manufacturer believes 

that the test procedure in its current 

form does not measure the efficiency of 

the equipment in a manner 

representative of its true energy use, the 

manufacturer may apply for a test 

procedure waiver. In response to 

Lennox’s comment about constant 

condenser TD, DOE has updated its 

model such that, for lower ambient 

rating conditions, the model 

recalculates the TD based on the head 

pressure, with different values for fixed 

and floating head pressure. The model’s 

treatment of the variable speed 

condenser fan option also takes the 

differences in TD into account. DOE 

discusses these calculations in more 

detail in chapter 5 of the TSD. To 

address Lennox’s and Heatcraft’s 

concern about baseline SCT values, DOE 

notes that it did not observe a higher 

condenser TD in testing than its 

baseline assumptions. Although DOE 

recognizes that some units on the 

market may have higher TDs, DOE is 

unaware of specific units that have 

higher TDs. Additionally, assigning a 

higher TD for the baseline might 

overestimate the energy savings of 

design options that lower the TD, such 

as having a larger condenser coil. 

4. Cost Assessment Methodology 

a. Teardown Analysis 

To calculate the manufacturing costs 

of the different walk-in components, 

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 

input 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 product class analyzed. See 

chapter 5 of the 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. 


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b. Cost Model 

The cost model is one of the 

analytical tools DOE used in 

constructing cost-efficiency curves. DOE 

derived the cost model curves 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 TSD 

describes DOE’s cost model and 

definitions, assumptions, data sources, 

and estimates. 

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 product 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.K). 

In discussing earlier comments 

received from interested parties, the 

NOPR’s preamble erred in 

characterizing comments from 

American Panel as stating that panel 

costs were around $0.25 per square foot. 

As a result, US Cooler and American 

Panel stated that $0.25 per square foot 

was too low a cost for panels. (US 

Cooler, Public Meeting Transcrip, No. 

88, at p. 19; American Panel, Public 

Meeting Transcript, No. 88 at p. 20) 

However, in the NOPR’s actual analysis, 

the Department estimated that the 

manufacturer production cost of walk-in 

panels was considerably higher than 

$0.25 per square foot. The panel costs 

used in the analysis are listed in Table 

IV.7. 

TABLE IV.7—NOPR INSULATION THICKNESS MATERIAL AND LABOR COST

Insulation thickness 

in Material 

Material/labor cost for 

non-floor panels 

$/ft 2

Material/labor cost for 

floor panels 

$/ft 2

3.5 ................................................................. Polyurethane ................................................ $5.06 $5.50 

4 .................................................................... Polyurethane ................................................ 5.22 5.64 

5 .................................................................... Polyurethane ................................................ 5.58 5.99 

6 .................................................................... Polyurethane ................................................ 5.92 6.33 

Based on manufacturer feedback, the 

Department further revised its cost 

model, which resulted in increased 

insulation prices. The material and 

labor prices used to characterize the cost 

of walk-in panels used in the analysis 

for this final rule are listed in Table 

IV.8. 

TABLE IV.8—FINAL RULE INSULATION THICKNESS MATERIAL AND LABOR COST

Insulation thickness 

in Material 

Material/labor cost for 

non-floor panels 

$/ft 2

Material/labor cost for 

floor panels 

$/ft 2

3.5 ................................................................. Polyurethane ................................................ $6.62 $7.14 

4 .................................................................... Polyurethane ................................................ 6.83 7.34 

5 .................................................................... Polyurethane ................................................ 7.248 7.81 

6 .................................................................... Polyurethane ................................................ 7.652 8.21 

In the NOPR, in an effort to capture 

the anticipated cost reduction in LED 

fixtures in the analyses, DOE 

incorporated price projections from its 

Solid State Lighting program into its 

MPC values for the primary equipment 

classes. The price projections for LED 

case lighting were developed from 

projections developed 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’’). ASAP, et 

al. supported the use of price 

projections in DOE’s analysis because 

LED prices are likely to drop in the 

future as market penetration increases. 

(ASAP et al., No. 113 at p. 4) More 

details about DOE price projections for 

LEDs are described in Chapter 5 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 


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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, listed in 

Table IV.9. 

TABLE IV.9—MANUFACTURER

MARKUPS

Walk-in component Markup 

(percent) 

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

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

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

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

e. Shipping Costs 

The shipping rates in the NOPR, were 

developed by conducting market 

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 non-display 

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. 

American Panel commented that the 

estimated shipping costs for 5-inch 

panels could be significantly higher 

than shipping costs for 4-inch panels 

and could range for a 67 percent to 140 

percent increase. (American Panel, No. 

99 at p. 6) Artic Industries commented 

that shipping has generally increased 

over the years and thicker panels will 

cause additional increases in the 

shipping price. (Artic Industries, No. 88 

at pp. 301–304) US Cooler commented 

that DOE should not estimate shipping 

just by weight and volume because less 

than truck load shipment limit the 

amount of square footage a 

manufacturer can use per shipment. (US 

Cooler, No. 88 at p. 305) DOE 

appreciates American Panel’s and Artic 

Industries comment on shipping. The 

Department found that while insulation 

thickness was a factor in increased 

shipping costs, so was the size of the 

walk-in being shipped. DOE modeled 

six different sized walk-ins each with 

3.5-inch, 4-inch, 5-inch and 6-inch thick 

insulation. DOE used a weighted 

average based on using each walk-in’s 

estimated market share to develop a 

shipping price for square foot of panel. 

DOE appreciates US Coolers comment 

and accounted for a square footage limit 

in the shipping costs. 

5. Energy Consumption Model 

In the NOPR, DOE proposed using an 

energy consumption model to estimate 

separately the energy consumption of 

panels, display doors, non-display doors 

and entire refrigeration systems at 

various performance levels using a 

design-option approach. DOE developed 

the model as a Microsoft Excel 

spreadsheet. 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. The model did 

not account for interactions between 

refrigeration systems and envelope 

components, nor did it address how a 

design option for one component may 

affect the energy consumption of other 

components. 

At the public meeting, Heatcraft 

requested that DOE share modeling tool 

and baseline assumptions used for the 

engineering analysis. (Heatcraft, Public 

Meeting Transcript, No. 88 at p. 123) 

DOE posted the spreadsheets used to 

model the energy consumption of walkin panels, doors, and refrigeration 

systems to the WICF energy 

conservation standards rulemaking 

docket Web page, located at: http://

www.regulations.gov/

#!docketDetail;D=EERE-2008-BT-STD0015 

In comments on the NOPR, Lennox 

stated that the results of the DOE model 

were not validated with actual 

laboratory results. (Lennox, No. 109 at 

p. 2) KeepRite noted that the DOE 

model was not verified through testing 

or prototyping, and was therefore 

overestimating the efficiency gain 

achievable by manufacturers. (KeepRite, 

No. 105 at p. 1) Since the publication of 

the NOPR, DOE has conducted 

additional testing to support its 

analysis. See chapter 5 for details. 

a. Panels and Doors 

In the NOPR performance model for 

walk-in panels, doors, and display 

doors, DOE used various assumptions to 

estimate the performance of each WICF 

component. In the NOPR, DOE used 

polyurethane insulation with a thermal 

resistance of 6.82 ft-h-°F/Btu-in for 

panels and non-display doors. This 

thermal resistance accounted for the 

aging of insulation when measuring 

walk-in panel performance. See 76 FR at 

21612. DOE proposed in a separate 

rulemaking to eliminate the long term 

thermal aging test procedure. In this 

final rule, DOE’s analysis used as its 

industry representative baseline panel a 

panel comprised of polyurethane 

insulation, which has as a thermal 

resistance value, without accounting for 

long term thermal aging, of 8 ft-h-°F/

Btu-in. DOE also received a comment on 

the thermal resistance used in the nondisplay door model. IB commented that 

the insulation’s age had no significant 

impact on door performance. (IB, No. 98 

at p. 2) DOE agrees with IB’s comment. 

The aging of insulation in non-display 

doors is not measured by the DOE test 

procedure and therefore does not have 

an impact on the door’s performance. In 

the final rule analysis, DOE modeled its 

non-display doors assuming they would 

use polyurethane insulation with a 

thermal resistance of 8 ft-h-°F/Btu-in. 

In the NOPR, DOE requested 

comment on the performance data of 

panels, non-display doors, and display 

doors which was calculated by the 

Department’s energy consumption 

models and found in appendix 5A of the 

NOPR TSD. DOE requested that 

interested parties produce additional 

data regarding about the thermal 

resistance performance of panels, 

display doors, or non-display doors and 

their design options. Bally commented 

that DOE’s evaluation of non-display 

doors was inappropriate because it did 

not account for the impact of the door 

frame. Bally recommended DOE 

evaluate the door frame along with the 

door cap. (Bally, No. 102 at p. 4) Bally 

added that the majority of heat through 

non-display doors was at the periphery 

rather than the center of the door. 

(Bally, Public Meeting Transcript, No. 

88 at p. 122) Bally expanded on this 

comment by explaining that doors are 

not sealed tightly and it recommended 

that DOE account for the heat gain 

caused by these gaps. (Bally, No. 102 at 

p. 4) DOE appreciates Bally’s comment, 

but notes that it did not account for gaps 

around the perimeter of doors. The 

Department did not adopt a test 

procedure that measured heat gain via 

infiltration and therefore did not 

consider gaps in the doors to have an 

impact on the performance of the door 

as measured by the DOE test procedure. 

In the NOPR, DOE evaluated the 

energy consumption associated with 

individual panels and doors at various 

sizes. As a result of this methodology, 

DOE associated design options such as 

occupancy sensors with one door. DOE 

recognizes that in the marketplace, one 


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occupancy sensor may serve multiple 

doors, and received a comment from 

NEEA, et al. confirming this practice. 

(NEEA, et al., No. 101 at p. 5) However, 

DOE is regulating display doors as 

single component and therefore 

assumed that all the costs and benefits 

of an occupancy sensor would be 

associated with the individual door. 

Although occupancy sensors may be 

applied over multiple doors, it is 

possible that a single display door could 

be installed in a walk-in with a single 

occupancy sensor. The Department 

chose this more conservative path and 

assumed one occupancy sensor per 

door. 

b. Refrigeration Systems 

The CA IOUs made several 

recommendations for changing the 

refrigeration system model, particularly 

for the condensing unit. First, they 

noted that published condensing unit 

capacity ratings are overestimated by 

approximately 35 percent because they 

rely on compressor capacity information 

based on a 65 °F return gas temperature, 

whereas return gas temperature is more 

likely to be around 41 °F for coolers and 

5 °F for freezers. Furthermore, they 

stated that the productive capacity of a 

walk-in system is more closely 

represented by the enthalpy difference 

between the liquid line enthalpy and 

the enthalpy of the refrigerant at 

approximately 10 °F superheat. (CA 

IOUs, No. 110 at pp. 3–4) 

DOE agrees with the assessment by 

the CA IOUs that current published 

capacity ratings for WICF components 

are not necessarily indicative of the 

capacity of a system made up of those 

components when that system is tested 

under AHRI 1250, because AHRI 1250 

has different rating conditions than the 

test procedures currently used to rate 

the components individually. DOE has 

adjusted its engineering model to more 

closely replicate unit performance 

under the test procedure based on 

additional test data developed during 

the NOPR phase. In the energy 

consumption model, return gas 

temperature is calculated based on an 

assumed evaporator superheat (i.e., 

heating of the refrigerant gas above its 

saturation temperature, measured at the 

evaporator exit) and compressor 

superheat (i.e., heating of the refrigerant 

gas above its saturation temperature, 

measured at the suction line entrance to 

the condensing unit), which are in turn 

based on test results. The evaporator 

superheat can be manually set by 

adjusting the expansion valve; 

manufacturers typically include 

recommended evaporator superheat 

ranges in their installation literature (for 

instance, one manufacturer recommends 

an evaporator superheat of 4 to 6 °F for 

low temperature applications). The 

compressor superheat is equal to the 

evaporator superheat plus additional 

refrigerant temperature rise in the 

suction line plus the dew point 

temperature reduction associated with 

the suction line pressure drop. The 

energy model calculates the capacity of 

the system based on the refrigerant 

enthalpy difference between the unit 

cooler entrance (liquid line) and exit 

(suction line), accounting for evaporator 

superheat, as recommended by CA 

IOUs. Additional warming of the 

refrigerant in the suction line is not 

considered to represent additional 

capacity, but it reduces refrigerant 

density and, by extension, condensing 

unit capacity. The model assumes that 

the unit does not use a suction line heat 

exchanger. Similarly, pressure drop in 

the suction line is also accounted for in 

the model. 

With respect to modeling systems 

with electric defrost in the NOPR, DOE’s 

analysis applied a temperatureterminated defrost approach for all 

defrost control schemes (baseline or 

higher)—that is, once a defrost is 

initiated, the defrost mechanism 

continues to heat the evaporator coil 

until the coil temperature reaches 45 °F, 

which ensures that the coil is fully 

defrosted. In the engineering model for 

electric defrost, DOE calculated the 

defrost time based on the amount of 

heat applied by the defrost mechanism 

and the amount of heat energy it would 

take to heat the coil and melt the ice, 

with a ‘‘bypass factor’’ accounting for 

heat lost into the coil’s surroundings 

and not used to heat the coil. 

Lennox commented that DOE’s 

calculations for defrost time were too 

short, and that a typical defrost duration 

would be in the 20 to 30 minute range, 

and upwards of 45 to 60 minutes for 

larger electric defrost units. (Lennox, 

No. 109 at p. 7) 

After further evaluation, DOE agrees 

with Lennox’s assessment. DOE 

conducted testing of low temperature 

refrigeration systems and found defrost 

times of approximately 30 minutes. DOE 

updated its assumptions in the 

engineering analysis to assume a 30- 

minute defrost duration for electric 

defrost systems smaller than 50,000 Btu/ 

h. In the absence of test data for very 

large systems, DOE believes Lennox’s 

estimates are reasonable and has 

increased the assumed defrost time to 

45 minutes for electric defrost systems 

between 50,000 and 75,000 Btu/h and 1 

hour for electric defrost systems larger 

than 75,000 Btu/h for larger electric 

defrost units it analyzed. 

DOE also included drain line heater 

wattage in the NOPR analysis for lowtemperature units. Lennox noted that 

drain-line heaters are not typically 

supplied by the manufacturer of the 

main component (i.e. the unit cooler). 

(Lennox, No. 109 at p. 7) Accordingly, 

DOE has removed this from the energy 

model. 

For more details on the energy model, 

see chapter 5 of the TSD. 

6. Design Options 

a. Panels and Doors 

DOE evaluated 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 

• Electronic lighting ballasts and 

high-efficiency lighting 

• Occupancy sensors 

• Display and window glass system 

insulation performance 

• Anti-sweat heater controls 

• No anti-sweat systems 

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 

DOE received a number of comments 

on increased panel thickness. In the 

NOPR, DOE increased the thickness of 

walk-in panels from the market 

representative baseline of 3.5 inches of 

polyurethane for walk-in cooler 

structural panels and freezer floor 

panels to 4 inches, 5 inches, and 6 

inches. For walk-in freezer structural 

panels DOE increased the panel 

thickness from the baseline of 4 inches 

to 5 inches and 6 inches. Nor-Lake and 

American Panel commented that 

increased insulation thickness resulted 

in longer cure times. These 

manufacturers commented that it takes 

25 or 30 minutes to cure 4 inch thick 

panels, 45 minutes to cure 5 inch thick 

panels, and 60 minutes to cure 6 inch 

thick panels. (Nor-Lake, No. 115 at p. 1; 

American Panel, No. 99 at pp. 5 and 6) 

In response to these comments, DOE 

accounted for increased cure time in the 

panel cost model. 

Nor-Lake and Manitowoc also stated 

that increasing the thickness of 

insulation provided only a minimal 

amount of R-value improvement. (Norlake, No. 115 at p. 1; Manitowoc, No. 


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108 at p. 3) DOE notes that it found that 

increasing the thickness of a panel 

directly improves the panel’s efficiency. 

Accordingly, in preparing the analysis 

for this final rule, DOE continued to use 

increased panel thickness as a design 

option. 

To improve the insulation material, 

DOE evaluated hybrid panels, which are 

a sandwich of polyurethane and 

vacuum-insulated panels (VIPs). NorLake commented that vacuum-insulated 

panels were cost prohibitive and 

technologically infeasible. (Nor-Lake, 

No. 115 at p. 2) Bally also commented 

that VIPs were not economically 

practical and therefore should be 

excluded as a design option. (Bally, No. 

102 at p. 2) Thermo-Kool remarked that 

VIPs were too fragile and too expensive 

to be used in walk-ins. (Thermo-Kool, 

No. 97 at p. 2) 

DOE considered vacuum-insulated 

panels as a design option in its 

engineering analysis because they have 

the potential to improve equipment 

efficiency, are available on the market 

today, are currently used in refrigeration 

products. 10 CFR part 430, subpart C, 

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

DOE agrees with Thermo-Kool that VIPs 

may be too fragile for walk-in 

applications and therefore incorporated 

VIPs as part of a hybrid panel, which 

sandwiches the VIPs in 2-inch 

polyurethane layers. However, DOE 

understands that there is a high level of 

cost required in implementing this 

design option, including redesign costs, 

and sought to reflect that through 

appropriate cost values obtained from 

manufacturer interviews and other 

sources and included in its analyses. As 

a result, vacuum-insulated panels 

appear only in max-tech designs for 

each equipment class, and are not 

included in any of the modeled 

configurations selected in setting the 

standard levels put forth in this rule. 

Bally commented that DOE should 

consider pocket connectors as a design 

option for panels (Bally, Public Meeting 

Transcript, No. 88 at p. 148) DOE 

appreciates Bally’s suggestion, but as 

previously described in this final rule 

notice the Department’s test procedure 

for walk-in panels only measures the 

insulation’s thermal resistance. 

Therefore, this technology would not 

result in energy savings as measured by 

the test procedure. 

DOE received a few comments on the 

design options evaluated for display 

doors. NEEA, et al. and the CA IOUs 

suggested that DOE consider low-e, gas 

filled glazing for medium temperature 

display doors. (NEEA et al., No. 101 at 

p.5; CA IOUs, No. 110 at p. 4) DOE 

clarifies that it evaluated 3 improved 

glass packs above the baseline, which 

included more efficient gas fills lowemissivity glazed panes, and additional 

glass panes. Chapter 5 of the TSD 

explains the design options for display 

doors in more detail. 

NEEA, et al. also recommended that 

DOE exclude lighting from the door 

frame assembly because it is not 

physically part of the door and because 

LEDs are already common in the WICF 

market. NEEA, et al. stated that the 

inclusion of lighting into the standards 

for doors would cause difficulty in 

enforcing compliance because no doors 

are shipped with lighting. (NEEA, et al., 

No. 101 at p. 5). In its market 

assessment, DOE found that lighting is 

typically installed and sold as part of 

the door assembly. Therefore, DOE 

continued to account for lighting used 

with display doors. DOE does not 

expect that including lighting will 

complicate enforcement of DOE 

standards because it is sold with the 

display door as integrated componentry. 

DOE agrees that LEDs are common in 

the WICF market and has accounted for 

the market share of LEDs as part of the 

efficiency distribution in the shipments 

analysis, detailed in chapter 9 of the 

TSD. 

Bally remarked that it was unclear as 

to what technology DOE was referring to 

by ‘‘automatic door opener/closer.’’ 

Bally asked for clarification as to how 

the power draw of opening and closing 

devices was to be evaluated. (Bally, No. 

102 at p.5) DOE notes that because the 

test procedure does not measure heat 

gain from infiltration, it did not account 

for door openings and closings as part 

of its list of potential design options. 

See section III.B, infra. 

IB commented that edging material 

had no significant impact on door 

performance. (IB, No. 98 at p. 2) IB may 

be correct in that the edging material 

does not have a significant impact on 

door performance in real world 

applications. However, the DOE test 

procedure for doors measures the 

thermal performance for the entire door, 

including any materials in the edge of 

the door. Additionally, DOE notes that 

the edge materials, which could act like 

a thermal bridge, would have an impact 

on the performance of the door. For this 

reason, DOE continued to evaluate the 

possibility of using improved framing 

materials for non-display doors. 

b. Refrigeration 

DOE included 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 

DOE described the design options in 

detail in chapter 5 of the NOPR TSD. In 

the notice, DOE requested comment on 

the design options, particularly 

improved condenser coil, fan motor 

efficiency, fan motor controls, and 

floating head pressure. In response, DOE 

received comments on these and other 

options. 

Larger Condenser Coil 

In the NOPR, DOE considered a larger 

condenser coil as a design option, 

which would reduce the condenser TD, 

increasing system capacity and resulting 

in a higher AWEF. DOE increased the 

fan power proportionally to coil size, 

but requested comment on whether 

increasing the condenser coil size 

would require an increase in evaporator 

coil size. 78 FR at 55816. Hussmann 

commented that a larger condenser coil 

would not require a larger evaporator 

coil. (Hussmann, No. 93 at p. 5) 

Furthermore, DOE’s analysis did not 

indicate that a larger evaporator coil 

would be required. Accordingly, DOE is 

not implementing a larger evaporator 

coil along with the larger condenser coil 

design option in the final rule analysis. 

Defrost Controls 

In the preliminary analysis, DOE 

assumed that a demand defrost control 

would be tested using the optional 

demand defrost test in AHRI 1250, 

section C11.2 and would have the 

equivalent effect of reducing the number 

of defrosts per day by 50 percent. 

However, stakeholder comments on the 

preliminary analysis stated that a 50 

percent reduction was too difficult to 

achieve using current technologies. 

Therefore, in the NOPR, for the defrost 

controls design option, DOE applied a 

generic defrost control that would have 

the effect of reducing the number of 

defrosts per day by 40 percent. 78 FR at 

55818. In comments on the NOPR 

assumption, Manitowoc noted that 

demand-defrost systems had been 

shown to reduce the number of defrost 

cycles as much as 80 percent compared 

to ‘‘timed defrost’’ systems. (Manitowoc, 

No. 108 at p. 3) DOE acknowledges that 

the energy savings due to demanddefrost systems may vary widely 

depending on the control mechanism; 

however, given the range of stakeholder 

comments it has received on the issue, 

believes an 80 percent reduction is too 

aggressive. DOE notes that its recently 


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adopted approach with respect to the 

measurement of refrigeration system 

performance [79 FR 27387], provides a 

default value for the reduction in 

defrosts from 4 to 2.5 defrosts per day 

due to demand-defrost controls. DOE 

has applied this default value in the 

engineering analysis for the final rule. 

For more details, see chapter 5. 

Hot Gas Defrost 

In the NOPR, DOE included hot gas 

defrost as a design option for multiplex 

condensing systems because it assumed 

the unit cooler could use hot gas 

generated by the compressor rack. DOE 

did not include hot gas defrost as a 

design option for dedicated condensing 

systems because DOE did not believe it 

was effective at saving energy. 78 FR at 

55804. In response, Heat Transfer 

commented that it manufactured many 

dedicated systems with hot gas defrost, 

which increased the efficiency of the 

unit. (Heat Transfer, Public Meeting 

Transcript, No. 88 at p. 140) After 

further review, DOE agrees with Heat 

Transfer that hot gas defrost is a valid 

design option for dedicated condensing 

systems as well as unit coolers 

connected to multiplex systems, and has 

implemented this option in the analysis. 

Heat Transfer’s literature claims that hot 

gas defrost causes systems to defrost 

four times faster, but did not have 

specific details on the energy savings. 

See chapter 5 for further details on the 

hot gas defrost design option. 

Fan and Motor Efficiency 

In the NOPR, DOE assumed that 

baseline evaporator fan motors would be 

electronically commutated motors 

(ECMs), while baseline condenser fan 

motors would be permanent split 

capacitor (PSC) motors. One design 

option was to replace PSC motors in 

condenser fans with more-efficient 

ECMs. This approach was consistent 

with EPCA, which specified that 

evaporator fan motors of under 1 

horsepower and less than 460 volts 

must use electronically commutated 

motors or 3-phase motors and condenser 

fan motors of under 1 horsepower must 

use electronically commutated motors, 

permanent split capacitor-type motors, 

or 3-phase motors. (42 U.S.C. 

6313(f)(1)(E)-(F)) In the NOPR, DOE 

screened out 3-phase motors from its 

design options because not all 

customers have 3-phase power, 

although it noted that this would in no 

way prohibit manufacturers from using 

them to improve rated energy use. 78 FR 

at 55805. 

In comments on the NOPR, RegalBeloit noted that three-phase motors 

and multi-horsepower ECMs could 

greatly improve unit efficiency. ebmpapst also commented that evaporator 

fans for WICFs did not necessarily have 

to be axial fans and that other types of 

air-moving devices, such as backward 

curved motorized impellers, may be a 

more efficient choice for certain 

refrigeration systems due to their 

aerodynamic characteristics. (ebmpapst, No. 92 at p. 5) Hussmann stated 

that the only way to accurately obtain 

fan motor power is to test the fan motors 

in-unit, or reference the fan, motor, and 

coil operating curves to determine 

power consumption at the desired CFM 

and pressure differential. (Hussmann, 

No. 93 at p. 5) 

DOE agrees with Regal-Beloit and 

ebm-papst that other, more efficient 

types of fans and motors may exist and 

may be used by manufacturers to 

improve the efficiency of their WICF 

equipment. DOE is continuing to screen 

out 3-phase motors based on utility to 

the consumer, because not all customers 

would have 3-phase power. In response 

to Hussmann’s comment, DOE notes 

that Hussmann did not provide any 

detailed fan information for WICFs that 

DOE could use in the analysis. 

Furthermore, DOE does not believe that 

the consideration of such detailed 

information would significantly 

improve the analysis, as DOE believes it 

has made reasonable, conservative 

estimates for fan efficiency based on 

stakeholder comments and market 

research. 

Evaporator Fan Controls 

In the NOPR, DOE applied both 

modulated evaporator fan controls and 

variable speed evaporator fan controls 

design options for all classes analyzed. 

A modulated fan control cycles the fans 

at a 50 percent duty cycle when the 

compressor cycles off, while variable 

speed fan control reduces fan speed 

during the off-cycle. To account for 

these types of controls, DOE’s analysis 

reduced the fan speed to 50 percent. 

Lennox commented that the model takes 

into account variable speed during 

refrigeration, which would incorrectly 

reflect a greater AWEF value. (Lennox, 

No. 109 at p. 7) Hussmann mentioned 

that fan modulation always requires an 

electronic expansion valve (EEV) to 

function properly, which is not always 

accounted for in TSL 4. (Hussmann, No. 

93 at p. 5) DOE notes that it has applied 

variable speed evaporator fans to those 

refrigeration applications where unit 

coolers are connected to a multiplex 

condensing unit in order to determine 

the fan speed during high and low load 

periods as specified in AHRI 1250, 

section 7.9. (That section requires that 

for unit coolers with variable speed 

evaporator fans that modulate fan speed 

in response to load, the fan shall be 

operated under its minimum, maximum 

and intermediate speed that equals to 

the average of the maximum and 

minimum speeds, respectively during 

the unit cooler test, and quadratic fit 

equations relating evaporator net 

capacities, fan operating speed, and fan 

power consumption be developed.) To 

address Hussmann’s comment, DOE 

notes that the analysis is conservative 

regarding the fan speed reduction, with 

a maximum fan speed reduction of 50 

percent. DOE does not expect that the 

system would need an EEV for this 

control approach. 

Refrigeration Summary 

After considering all the comments it 

received on the design options, DOE 

applied the following design options in 

the final rule 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 

E. Markups Analysis 

DOE applies multipliers called 

‘‘markups’’ to the MSP to calculate the 

customer purchase price of the analyzed 

equipment. These markups are in 

addition to the manufacturer markup 

(discussed in section IV.D.3.d) and are 

intended to reflect the cost and profit 

margins associated with the distribution 

and sales of the equipment. DOE 

identified two major distribution 

channels for walk-ins, and markup 

values were calculated for each 

distribution channel based on industry 

financial data. The overall markup 

values were then calculated by 

weighted-averaging the individual 

markups with market share values of the 

distribution channels. 

In estimating markups for walk-ins 

and other equipment, DOE developed 

separate markups for the cost of baseline 

equipment and the incremental cost of 

higher-efficiency equipment. 

Incremental markups are applied as 

multipliers only to the MSP increments 

of higher-efficiency equipment 

compared to baseline, and not to the 

entire MSP. 

See chapter 6 of the final rule TSD for 

more details on DOE’s markups 

analysis. 


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F. 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 and 

NIA. 

The estimates for the annual energy 

consumption of each analyzed 

representative refrigeration system (see 

section IV.C.2) were derived 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 system produces 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 depend on the 

methodology adopted for sizing, the 

implied assumptions and the extent of 

oversizing. The sizing methodology is 

further discussed later in this section. 

For the envelopes, the estimates of 

equipment 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 

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. 

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. DOE used the same 

approach for the final rule’s analysis. 

1. Sizing Methodology for the 

Refrigeration System 

The load profile of WICF equipment 

that DOE used broadly follow the load 

profile assumptions of the industry test 

procedure for refrigeration systems— 

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, equipment loading 

events, and other design load factors, 

and a low-load 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. 

For this final rule, DOE concluded 

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. 

As it did for the NOPR, DOE used a 

nominal run time of 16 hours per day 

for coolers and 18 hours per day for 

freezers over a 24-hour period to 

calculate the capacity of a ‘‘perfectly’’ 

sized refrigeration system. A fixed 

oversize factor of 10 percent was 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. 

2. Oversize Factors 

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. Based on discussions with 

purchasers of walk-ins, DOE found that 

it is customary in the industry to add a 

10 percent safety margin to the aggregate 

24-hour load, resulting in 10 percent 

oversizing of the refrigeration system. 

Further, 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 mass-produced 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. 

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. 

In preparing the NOPR analysis, DOE 

considered comments from interested 

parties and recalculated the mismatch 

factor because compressors for the lower 

capacity units are available at smaller 

size increments than what DOE had 

initially assumed in the preliminary 

analysis. 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 


tkelley on DSK3SPTVN1PROD with RULES2
32084 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

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, 

for the final rule DOE applied a uniform 

average mismatch factor of 10 percent 

over the entire capacity range of 

refrigeration systems. 

To estimate the runtimes for the 

NOPR, DOE started with nominal 

runtimes of 16 hours for coolers, and 18 

hours for freezers. However, these 

runtimes are appropriate for perfectly 

sized refrigeration systems, and do not 

account for equipment oversizing. DOE 

estimated runtimes as a function of this 

oversizing in accordance with industry 

practice (see chapter 7 of the final rule 

TSD). 

Several stakeholders commented that 

the runtime assumptions were too short, 

and should be increased to 18 hours for 

larger walk-ins used by convenience 

and grocery stores (ACCA, No. 119, at p. 

3), or 16 hours for walk-in coolers and 

20 hours for walk-in freezers (NorLake, 

No. 115, at p. 2), or 16 hours for walkin coolers and 18 hours for walk-in 

freezers (Manitowoc, No. 108; at p. 3). 

It is not clear whether the values cited 

in the comments refer to nominal 

runtimes. If so, DOE’s assumptions are 

roughly similar to the values cited in the 

comments. Because the comments 

regarding runtimes do not provide 

enough evidence for DOE to revise its 

assumptions, DOE maintained the same 

approach for estimating runtimes as it 

used in the NOPR. 

G. Life-Cycle Cost and Payback Period 

Analysis 

DOE conducts LCC and PBP analyses 

to evaluate the economic impacts of 

potential energy conservation standards 

for walk-ins on individual customers— 

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 

piece of equipment, 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 equipment. The PBP is 

defined as the estimated number of 

years it takes customers to recover the 

increased purchase cost (including 

installation) of more efficient 

equipment. 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. 

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 

equipment—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, equipment lifetimes, discount 

rates, and the year that compliance with 

standards is required. DOE created 

probability distributions for equipment 

lifetime inputs to account for their 

uncertainty and variability. 

DOE developed refrigeration and 

envelope component spreadsheet 

models to calculate the LCC and PBP. 

Chapter 8 of the final rule 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.12 summarizes DOE’s 

approach and data used to derive inputs 

to the LCC and PBP calculations for the 

NOPR and the changes made for this 

final rule. 

TABLE IV.12—SUMMARY OF INPUTS AND METHODS IN THE LCC AND PBP ANALYSIS* 

Inputs NOPR analysis Changes for final rule 

Installed Costs 

Equipment Cost ................... • Derived by multiplying manufacturer cost by manufacturer and retailer markups and sales tax, as appropriate.• No change for systems, and display doors, DOE 

maintain its use of a declining price trend. 

• For non-display doors and panels the manufacture 

experience curve was revised to use constant real 

prices. 

• Includes a factor for estimating equipment price 

trends due to manufacturer experience.

Installation Costs .................. Based on RS Means Mechanical Cost Data 2012. Assumed no change with efficiency level.No change. 


tkelley on DSK3SPTVN1PROD with RULES2
Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 32085 

17Bureau of Labor Statistics, Producer Price Index 

Industry Data, Series: PCU3334153334153. 

18Reed Construction Data, RSMeans Mechanical 

Cost Data 2012 Book, 2012. 

TABLE IV.12—SUMMARY OF INPUTS AND METHODS IN THE LCC AND PBP ANALYSIS*—Continued 

Inputs NOPR analysis Changes for final rule 

Operating Costs 

Annual Energy Use .............. DOE calculated 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.

No change. 

Energy Prices ....................... Commercial and industrial prices of electricity based on 

Form EIA–826 Database Monthly Electric Utility 

Sales and Revenue Data.

No change. 

Energy Price Trends ............ Forecasted using AEO2013 price forecasts ................... No change. 

Repair and Maintenance 

Costs.

• Annualized repair and maintenance costs of the combined system were derived from RS Means 2012 

walk-in cooler and freezer maintenance data. Doors 

and refrigeration systems were replaced during the 

lifetime.

Increased refrigerant recharge cost to $500, to reflect 

industry practice, 

• Refrigerant recharge cost set at $0.

Present Value of Operating Cost Savings 

Equipment Lifetime .............. Based on manufacturer interviews. Variability: characterized using Weibull probability distributions.Revised to reflect stakeholder comments, see section 

IV.G.7 for details. 

Discount Rates ..................... Based on Damodaran Online, October 2012 ................. No change. 

Compliance Date ................. 2017 ................................................................................ No change. 

* 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 customer equipment 

costs, DOE multiplied the MSPs 

developed in the engineering analysis 

by the distribution channel markups, 

described in section IV.E. DOE applied 

baseline markups to baseline MSPs, and 

incremental markups to the MSP 

increments associated with higher 

efficiency levels. 

For the NOPR, DOE developed an 

equipment price trend for WICFs based 

on the inflation-adjusted index of the 

producer price index (PPI) for air 

conditioning, refrigeration, and forced 

air heating from 1978 to 2012.17 A linear 

regression of the inflation-adjusted PPI 

shows a downward trend. To project a 

future trend, DOE extrapolated the 

historic trend using the regression 

results. For the LCC and PBP analysis, 

this default trend was applied between 

the present and the first year of 

compliance with amended standards, 

2017. 

Several commenters stated that, since 

prices for metal and urethane chemicals 

have increased about 3 percent annually 

over the last 20 years, there is no 

justification for DOE’s assumed decrease 

in prices. (APC, No. 99, at p. 8; 

ThermoKool, No. 97 at p. 4) Hussmann 

noted that a large portion of WICF 

manufacturer cost comes from copper 

coil and sheet metal; since the prices of 

these commodities have more than 

doubled in the last 10 years, Hussmann 

expects materials costs to increase in the 

future. (Hussmann, No.93, at p. 6) US 

Cooler pointed out that WICF prices 

have not decreased since 1986. (US 

Cooler, No. PMeeting, at pp. 310–311) 

US Cooler also argued that the WICF 

industry is dependent on the price of 

metals. (US Cooler, No. 99 at p. 8) 

DOE believes that the comments on 

past prices likely refer to nominal 

prices, since that is what manufacturers 

see. The PPI index that DOE used shows 

a slight increasing trend from 1980 to 

2012. DOE uses real (inflation-adjusted) 

prices throughout its analysis, however, 

and the inflation-adjusted PPI shows a 

slight declining trend. For the final rule, 

DOE used a more disaggregated PPI: for 

commercial refrigerators and related 

equipment. The exponential fit that was 

derived exhibits a very slight declining 

trend, which DOE generally applied for 

WICFs. 

However, DOE determined that this 

trend was inappropriate for panels and 

non-display doors, where the majority 

of the manufacturer cost is polyurethane 

foam insulation. For these equipment 

classes DOE used constant real prices 

when estimating future equipment 

price. For details on the estimation of 

future equipment price, see appendix 

8D of the final rule TSD. 

2. Installation Costs 

Installation cost includes labor, 

overhead, and any miscellaneous 

materials and parts needed to install the 

equipment. For the NOPR analysis, DOE 

included refrigeration system 

component installation costs based on 

RS Means Mechanical Cost Data 2012.18

Refrigeration system installation costs 

included separate installation costs for 

the condensing unit and unit cooler. 

DOE continued with this approach for 

refrigeration systems in preparing this 

final rule. 

For the NOPR, 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 non-display 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 along with the other 

walk-in components and that and the 

installation costs for the display doors 

are included in the ‘‘mark-up’’ amounts 

for the OEM channel. 

DOE received several comments 

regarding panel installation costs as a 

result of increased foam insulation 

thickness. ICS stated that panels 

requiring more than 4 inches of foam 

insulation will require thermal barriers 

and automatic fire suppression, which 

are expensive and will place a burden 

on manufacturers and add unnecessary 

costs on end users. (ICS, No. 100, at p. 

7) Similarly, Nor-Lake asserted that 

building codes may require a thermal 

barrier, sprinkler system, or other tests 


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32086 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

19 International Code Council, Inc., International 

Building Code, 2012, ISBN: 978–1–60983–040–3. 

20Section 2603.4.1.2 states that foam plastics 

used in cooler and freezer walls up to a maximum 

thickness of 10 inches shall be protected by an 

automatic sprinkler system. Where the cooler or 

freezer is within a building, both the cooler or 

freezer and the part of building in which it is 

located shall be sprinklered. 

21Section 2603.4 defines a thermal barrier 

material where the average temperature of the 

exposed surface does not rise more than 250 °F after 

15 minutes of fire exposure. One can meet this 

criterion using 0.5 inch gypsum which is rated at. 

22Reed Construction Data, RSMeans Facilities 

Maintenance & Repair 2013 Cost Data Book, 2013. 

23Reed Construction Data, RSMeans Facilities 

Maintenance & Repair 2013 Cost Data Book. 2013. 

24U.S. Energy Information Administration. EIA– 

826 Sales and Revenue Spreadsheets. (Last 

accessed May 16, 2012). www.eia.doe.gov/cneaf/

electricity/page/eia826.html. 

25The spreadsheet tool that DOE used to conduct 

the LCC and PBP analyses allows users to select 

price forecasts from either AEO’s High Economic 

Growth or Low Economic Growth Cases. Users can 

thereby estimate the sensitivity of the LCC and PBP 

results to different energy price forecasts. 

if panel foam thickness increases above 

4 inches. (Nor-Lake, No. 115 at p. 4) 

For cooler and freezer walls greater 

than 400 ft2, the International Building 

Code 19 (IBC) requires sprinkler systems 

and other fire safety criteria regardless 

of panel thickness.20 Therefore, there 

would be no additional installation 

costs for walk-ins of this size that would 

be dependent on foam thickness. 

For walk-in coolers up to 400 ft2, 

Section 2603.4.1.3 of the IBC states that 

these coolers do not require special 

consideration for foam thickness up to 

4 inches if the metal facing is of greater 

thickness than 0.032-inch or 0.016-inch 

for aluminum or steel, respectively. For 

foam thicknesses greater than 4 inches 

and up to 10 inches, a thermal barrier 

is required. DOE added the cost of 

installing a 0.5-inch gypsum thermal 

barrier when the panel foam thickness 

exceeds 4 inches.21 The cost of materials 

and labor was estimated at $1.53 ft2 (this 

includes the installation cost for taped, 

and finished (level 4 finish) fire 

resistant 0.5-inch gypsum) based on 

RSMeans Facilities Construction Cost 

Data, 2013 22. This cost was applied to 

all installations of walk-ins up to 400 ft2

where foam thickness is greater than 4 

inches and up to 10 inches. 

3. Maintenance and Repair Costs 

Maintenance costs are associated with 

maintaining the equipment’s 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 preparing the final rule’s analysis, 

DOE followed the same approach that it 

applied for the NOPR analysis with 

regard to maintenance for display doors 

with lights. 78 FR 55781, 55828. 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 Facilities Maintenance 

and Repair Cost Data, 2013,23 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 2013 

data provided general maintenance 

costs for display and storage walk-ins. 

For this final rule, the total annual 

maintenance costs for a walk-in unit 

range from $172 to $265; of this DOE 

assumed $152 would be spent on the 

refrigeration system and the rest would 

be spent on the display and passage 

doors of the envelope. Maintenance 

costs were assumed to be the same 

across small, medium, and large door 

sizes in the case of both non-display 

doors and display doors. As stated 

previously, annual maintenance costs 

for the envelope wall and floor panels 

were assumed to be negligible and were 

not considered. 

Several parties stated that DOE had 

underestimated the maintenance costs 

associated with refrigerant leakage and 

refrigerant charge. (ACCA, No. 119, at p. 

3; Nor-Lake, No. 115, at p. 2; ICS, et al., 

No. 100 at p. 5; NRA No. 112, at p.3). 

ICS, et al. recommended an annual cost 

of $500 to $700, while Nor-Lake 

suggested $600. 

Based on the comments received, 

DOE used an annual cost of $500 to 

account for system refrigerant 

recharging. 

4. Annual Energy Consumption 

Typical annual energy consumption 

of walk-ins at each considered 

efficiency level is obtained from the 

energy use analysis results (see section 

IV.F of this notice). 

5. Energy Prices 

DOE calculated average State 

commercial electricity prices using the 

U.S. Energy Information 

Administration’s (EIA’s) ‘‘Database of 

Monthly Electric Utility Sales and 

Revenue Data.’’ 24 DOE calculated an 

average State commercial price by (1) 

estimating an average commercial price 

for each utility company by dividing the 

commercial revenues by commercial 

sales; and (2) weighting each utility by 

the number of commercial customers it 

served by state. 

6. Energy Price Projections 

To estimate energy prices in future 

years, DOE extrapolated the average 

State electricity prices described above 

using the forecast of annual average 

commercial electricity prices developed 

in the Reference Case from AEO2013.25

AEO2013 forecasted prices through 

2040. To estimate the price trends after 

2040, DOE assumed the same average 

annual rate of change in prices as from 

2031 to 2040. 

7. Equipment Lifetime 

For the NOPR, DOE estimated 

lifetimes for the individual components 

analyzed instead of the entire unit. It 

used an average lifetime of 15 years for 

panels, 14 years for display and nondisplay doors, and 12 years for 

refrigeration systems. DOE reflects the 

uncertainty of equipment lifetimes in 

the LCC analysis for equipment 

components by using probability 

distributions. 

A number of stakeholders asserted 

that DOE had overestimated the 

equipment lifetimes, and that in general 

the average lifetime for WICFs is 10 

years. (NAFEM, No. 118, at p. 3; Bally, 

No. 102, at p. 2; APC, No. PMeeting, at 

p. 246; Louisville Cooler, No. PMeeting, 

at p. 249; Hillphoenix, No. 107 at p. 5) 

Louisville Cooler stated that WICFs 

have a wide range of lifetimes, and that 

a typical fast food or convenience store 

walk-in unit will have a 10-year life, but 

institutional walk-ins would have a life 

up to 20 years. (Louisville Cooler, No. 

81 at p. 1) 

For refrigeration systems, 

ThermoKool agreed with the assumed 

lifetime of 12 years (ThermoKool, No. 

97 at p. 3), while Bally and Manitowoc 

suggested that average system lifetimes 

are between 6 and 10 years. (Bally, No. 

102 at p. 2; Manitowoc, No. 108, at p. 

4) 

Nor-Lake commented that typical 

panel lifetime is 10 to 15 years (NorLake, No. 115, at p. 3), while Manitowoc 

commented that 10 years is more 

typical. (Manitowoc, No. 108, at p. 4) 

Several comments stated that panel 

lifetimes from 7 to 10 years are 

representative. (IB, No. 98, at p. 3; 

ThermoKool, No. 97, at p. 3; 

Hillphoenix, No. 107, at p. 7) Further, 

IB stated that panel lifetimes should not 

be less than the minimum lifetime of the 

door. (IB, No. 98, at p. 3) APC asserted 

that customers will likely replace the 

entire WICF when the panels fail if the 

remaining components are close to endof-life. (APC, No. PMeeting at p. 244) 

ThermoKool and Bally commented 

that doors have lifetimes of 3 to 5 years 

and 4 to 6 years, respectively. 

(ThermoKool, No. 97, at p. 3; Bally, No. 


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26The LCC analysis estimates the economic 

impact on the individual customer from that 

customer’s own economic perspective in the year of 

purchase and therefore needs to reflect that 

individual’s own perceived cost of capital. By way 

of contrast DOE’s analysis of national impact 

requires a societal discount rate. These rates used 

in that analysis are 7 percent and 3 percent, as 

required by OMB Circular A–4, September 17, 2003. 

27Harris, R.S. Applying the Capital Asset Pricing 

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

ssrn.com/abstract=909893. 

102, at p. 2) Danfoss, Hillphoenix, APC, 

and IB asserted that doors are replaced 

every 3 years. (Danfoss, No. PMeeting at 

p. 239; Hillphoenix, No. 107, at p. 5; 

APC, No. PMeeting, at p. 246; IB, No. 

98, at p. 3) The CA IOUs, after 

contacting end-users of walk-in doors, 

stated that their lifetime is 

approximately 15 years. (CA IOUS, No. 

110, at p. 6) CA IOUs further stated that 

while there is a wide range of lifetimes 

for freight and panel doors, 8 to 9 years 

is typical. (CA IOUs, No. 110, at p. 6) 

Nor-Lake stated that the typical lifetime 

of a passage door is 8 to 10 years, and 

the typical lifetime of a freight door is 

5 to 7 years. (Nor-Lake, No. 115, at p. 

3) 

Based on the stakeholder comments, 

DOE revised its lifetime estimates for 

this final rule. In all cases, DOE reduced 

the average equipment lifetime, as 

shown in Table IV.13. Equipment 

lifetimes are described in detail in 

chapter 8 of the final rule TSD. 

TABLE IV.13—AVERAGE EQUIPMENT LIFETIMES FOR WALK-IN COOLERS AND FREEZERS (IN YEARS) 

Component NOPR 

Final Rule 

Small All other sizes 

Display Door ................................................................................ 14 12 12 

Freight Door ................................................................................. 14 12 6 

Passage Door .............................................................................. 14 12 6 

Panel Wall/Floor .......................................................................... 15 12 12 

Refrigeration System ................................................................... 12 10 10 

8. Discount Rates 

In calculating the LCC, DOE applies 

discount rates to estimate the present 

value of future operating costs to the 

customers of walk-ins.26 DOE derived 

the discount rates for the walk-in 

analysis by estimating the average cost 

of capital for a large number of 

companies similar to those that could 

purchase walk-ins. This approach 

resulted in a distribution of potential 

customer discount rates from which 

DOE sampled in the LCC analysis. 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. 

DOE estimated the cost of equity 

financing by using the Capital Asset 

Pricing Model (CAPM).27 The CAPM 

assumes that the cost of equity is 

proportional to the amount of 

systematic risk associated with a 

company. 

9. Compliance Date of Standards 

Amended standards for WICFs 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. 

6313(f)(4)(B)) In the absence of any 

information indicating that 3 years is 

inadequate, DOE projects 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. 

10. 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 

equipment efficiencies that consumers 

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

case without new energy efficiency 

standards). DOE refers to this 

distribution of equipment efficiencies as 

a base-case efficiency distribution. 

For the NOPR, 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. 

For panels and non-display doors, 

DOE estimated that 100 percent of the 

equipment sold under the base case 

would consist of equipment at the 

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 would have 

LED lighting, corresponding to the first 

efficiency level above the baseline. (See 

section IV.C for a discussion of the 

efficiency levels and design options in 

the engineering analysis). For further 

information on DOE’s estimate of basecase efficiency distributions, see chapter 

8 of the final rule TSD. 

11. Inputs to Payback Period Analysis 

Payback period is the amount of time 

it takes the customer to recover the 

higher purchase cost of more energy 

efficient equipment as a result of lower 

operating costs. Numerically, the PBP is 

the ratio of the increase in purchase cost 

to the decrease in annual operating 

expenditures. This type of calculation is 

known as a ‘‘simple’’ PBP because it 

does not take into account changes in 

operating cost over time or the time 

value of money; that is, the calculation 

is done at an effective discount rate of 

zero percent. PBPs are expressed in 

years. PBPs greater than the life of the 

equipment mean that the increased total 


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32088 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

28North American Association of Food 

Equipment Manufacturers. 2012 Size and Shape of 

Industry. Chicago, IL. 

installed cost of the more-efficient 

equipment is not recovered in reduced 

operating costs over the life of the 

equipment. 

The inputs to the PBP calculation are 

the total installed cost to the customer 

of the equipment for each efficiency 

level and the average annual operating 

expenditures for each efficiency level in 

the first year. The PBP calculation uses 

the same inputs as the LCC analysis, 

except that electricity price trends and 

discount rates are not used. 

12. Rebuttable-Presumption Payback 

Period 

Sections 325(o)(2)(B)(iii) and 

345(e)(1)(A) of EPCA (42 U.S.C. 

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

6316(a)(A)) establish a rebuttable 

presumption applicable to walk-ins. The 

rebuttable presumption states that a new 

or amended standard is economically 

justified if the Secretary finds that the 

additional cost to the consumer of 

purchasing equipment 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. 

This rebuttable presumption test is an 

alternative way of establishing 

economic justification. 

To evaluate the rebuttable 

presumption, DOE estimated the 

additional cost of purchasing moreefficient, standards-compliant 

equipment, and compared this cost to 

the value of the energy saved during the 

first year of operation of the equipment. 

DOE views the increased cost of 

purchasing standards-compliant 

equipment as including the cost of 

installing the equipment for use by the 

purchaser. DOE calculated the 

rebuttable presumption payback period 

(RPBP), or the ratio of the value of the 

increased installed price above the 

baseline efficiency level to the first 

year’s energy cost savings. When the 

RPBP is less than 3 years, the rebuttable 

presumption is satisfied; when the 

RPBP is equal to or more than 3 years, 

the rebuttable presumption is not 

satisfied. Note that this PBP calculation 

does not include other components of 

the annual operating cost of the 

equipment (i.e., maintenance costs and 

repair costs). 

While DOE examined the rebuttable 

presumption, it also considered whether 

the standard levels considered are 

economically justified through a more 

detailed analysis of the economic 

impacts of these levels pursuant to 42 

U.S.C. 6295(o)(2)(B)(i). Consistent with 

its usual practice, DOE conducted this 

more thorough analysis to help ensure 

the completeness of its analysis of the 

standards under consideration. The 

results of this analysis served as the 

basis for DOE to evaluate the economic 

justification for a potential standard 

level definitively (thereby supporting or 

rebutting the results of any preliminary 

determination of economic 

justification). 

H. Shipments 

Forecasts of equipment shipments are 

used to calculate the national impacts of 

standards on energy use, NPV, and 

future manufacturer cash flows. 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 equipment 

shipments as inputs to estimate the age 

distribution of in-service equipment 

stocks for all years. The age distribution 

of in-service equipment 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. Detailed description of the 

procedure to calculate future shipments 

is presented in chapter 9 of the final 

rule TSD. 

In DOE’s shipments model, shipments 

of walk-in units and their components 

are driven by new purchases and stock 

replacements due to failures. Equipment 

failure rates are related to equipment 

lifetimes, which were revised for the 

final rule, as described in section IV.G.7. 

DOE modeled its growth rate projections 

for new equipment using the 

commercial building floor space growth 

rates from the AEO 2013 NEMS–BT 

model. 

Complete historical shipments data 

for walk-ins could not be obtained from 

any one single source. Therefore, for the 

NOPR DOE used data from multiple 

sources to estimate historical shipments. 

NEEA suggested that DOE use 

industry data such as those collected by 

NAEFEM to forecast shipments, even if 

it does not cover all manufacturers. 

(NEEA, No. 101, at p. 6) DOE contacted 

NAFEM, which provided DOE with 

recent copies of their ‘‘Size and Shape 

of the Industry’’ reports.28 These reports 

contain data on the annual sales of 

walk-in units in the food service sector 

for 2002–2012. DOE analyzed the data 

received from NAFEM and also 

obtained other data from manufacturer 

interviews and other sources. For the 

final rule, DOE included these new data 

into its shipments analysis. 

a. Share of Shipments and Stock by 

Equipment Class 

For the NOPR, DOE estimated that 

dedicated condensing units account for 

approximately 70 percent of the 

refrigeration market and the remaining 

30 percent consists of unit coolers 

connected to multiplex condensing 

systems. For dedicated condensing 

refrigeration systems, DOE estimated 

that approximately 66 percent and 3 

percent of the shipments and stock of 

the refrigeration market is accounted for 

by outdoor and indoor dedicated 

condensing refrigeration systems, 

respectively. For unit coolers connected 

to multiplex systems, DOE estimated 

that medium temperature units account 

for about 25 percent of the shipments 

and stock. 

Regarding the relative shares of stock 

or shipments between walk-in coolers 

and freezers, for the NOPR, DOE 

estimated 71 percent share for coolers 

and 29 percent for freezers. DOE 

estimated that shares by size of walk-in 

units are 52 percent, 40 percent, and 8 

percent for small, medium, and large 

units, respectively. 

DOE received no comments on the 

above estimates, and for this final rule 

DOE maintained the same values that 

were used in the NOPR. 

2. Impact of Standards on Shipments 

For various equipment, price 

increases due to standards could lead to 

more refurbishing of equipment (or 

purchase of used equipment), which 

would have the effect of deferring the 

shipment of new equipment for a period 

of time. For the NOPR, DOE did not 

have enough information on customer 

behavior to explicitly model the extent 

of refurbishing at each TSL. 

ACCA and Hussmann stated that 

additional panel insulation will 

encourage businesses to extend the life 

of old units or purchase a used unit 

rather than a new unit. (ACCA, No. 93, 

at p.7; Hussmann, No. 93, at p. 7) 

However, Manitowoc noted that there is 

a very limited market for used 

equipment because the panel design 

does not lend itself to multiple cycles. 

(Manitowoc, No. 108, at p. 4) ACCA 

pointed out that while there is a large 

market for used small WICFs typically 

used in restaurants, larger WICFs found 

in grocery stores are less likely to be 

resold. (ACCA, No 119, at p. 3) 

DOE acknowledges that price 

increases from amended standards 

could lead to increases in equipment 

refurbishing or the purchase of used 

equipment. DOE did not have enough 


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Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 32089 

information on WICF customer behavior 

to explicitly model the extent of 

refurbishing at each TSL. However, DOE 

believes that the degree of refurbishing 

would not be significant enough to 

change the ranking of the TSLs 

considered for this rule. 

Manitowoc argued that if the price of 

a WICF is too high, customers will use 

other appliances to keep their food cold, 

such as reach-ins and under-counter 

coolers, which would cause higher 

energy consumption. (Manitowoc, No. 

108, at p. 4) Thermo-Kool agreed that 

higher prices would encourage 

customers to buy alternative means to 

keep products cold or frozen (ThermoKool, No. 97 at p. 3). 

DOE is releasing a concurrent 

standard for commercial refrigeration 

equipment, which includes the 

alternative equipment mentioned by 

Manitowoc and Thermo-Kool. The 

equipment covered under that rule will 

be subject to similar price increases as 

WICFs. Therefore, DOE believes that 

there will be limited incentive for 

customers to purchase alternatives to 

WICFs that meet the standards in this 

final rule. 

I. National Impact Analysis—National 

Energy Savings and Net Present Value 

The NIA assesses the NES and the 

NPV of total customer costs and savings 

that would be expected as a result of 

amended energy conservation 

standards. The NES and NPV are 

analyzed at specific efficiency levels for 

each walk-in equipment class. DOE 

calculates the NES and NPV based on 

projections of annual equipment 

shipments, along with the annual 

energy consumption and total installed 

cost data from the LCC analysis. For the 

final rule analysis, DOE forecasted the 

energy savings, operating cost savings, 

equipment costs, and NPV of customer 

benefits over the lifetime of equipment 

sold from 2017 through 2046. 

DOE evaluated the impacts of the 

amended standards by comparing basecase projections with standards-case 

projections. The base-case projections 

characterize energy use and customer 

costs for each equipment class in the 

absence of any amended energy 

conservation standards. DOE compares 

these projections with projections 

characterizing the market for each 

equipment class if DOE were to adopt 

an amended standard at specific energy 

efficiency levels for that equipment 

class. 

DOE uses a Microsoft Excel 

spreadsheet model to calculate the 

energy savings and the national 

customer costs and savings from each 

TSL. The final rule TSD and other 

documentation that DOE provides 

during the rulemaking help explain the 

models and how to use them, and 

interested parties can review DOE’s 

analyses by interacting with these 

spreadsheets. The NIA spreadsheet 

model uses average values as inputs (as 

opposed to probability distributions of 

key input parameters from a set of 

possible values). 

For the final rule analysis, the NIA 

used projections of energy prices and 

commercial building starts from the 

AEO2013 Reference Case. In addition, 

DOE analyzed scenarios that used 

inputs from the AEO2013 Low 

Economic Growth and High Economic 

Growth Cases. These cases have lower 

and higher energy price trends, 

respectively, compared to the Reference 

Case. NIA results based on these cases 

are presented in appendixes 10A and 

10B of the final rule TSD. 

A detailed description of the 

procedure to calculate NES and NPV, 

and inputs for this analysis are provided 

in chapter 10 of the final rule TSD. 

1. 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. As 

discussed in section IV.G, DOE used 

data collected from manufacturers and 

an analysis of market information to 

develop 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. 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. 

To estimate market behavior in the 

standards cases, DOE uses a ‘‘roll-up’’ 

scenario. Under the roll-up scenario, 

DOE assumes that equipment 

efficiencies in the base case that do not 

meet the standard level under 

consideration would ‘‘roll up’’ to meet 

the new standard level, and equipment 

efficiencies above the standard level 

under consideration would be 

unaffected. 

The estimated efficiency trends in the 

base case and standards cases are 

further described in chapter 8 of the 

final rule TSD. 

2. National Energy Savings 

For each year in the forecast period, 

DOE calculates the NES for each 

potential standard level by multiplying 

the stock of equipment affected by the 

energy conservation standards by the 

estimated per-unit annual energy 

savings. DOE typically considers the 

impact of a rebound effect in its 

calculation of NES for a given piece of 

equipment. A rebound effect occurs 

when users operate higher efficiency 

equipment more frequently and/or for 

longer durations, thus offsetting 

estimated energy savings. DOE did not 

incorporate a rebound factor for walkins because they are operated 24 hours 

a day, and therefore there is no potential 

for a rebound effect. 

Major inputs to the NES calculation 

are annual unit energy consumption, 

shipments, equipment stock, a site-toprimary energy conversion factor, and a 

full fuel cycle factor. 

The annual unit energy consumption 

is the site energy consumed by a walkin component in a given year. Because 

the equipment classes analyzed in this 

rule represent a range of different 

equipment that is sold across a range of 

sizes, DOE adopted different ‘‘unit’’ 

definitions for panels, and all other 

walk-in equipment. For panels, NES is 

expressed as a square footage of 

equipment, while for all other 

components NES is expressed per unit. 

DOE determined annual forecasted 

shipment-weighted average equipment 

efficiencies that, in turn, enabled 

determination of shipment-weighted 

annual energy consumption values. 

The NES spreadsheet model keeps 

track of the total square feet of walk-in 

cooler and freezer panels, and 

component units shipped each year. 

The walk-in stock in a given year is the 

total number of walk-ins shipped from 

earlier years that is still in use in that 

year, based on the equipment lifetime. 

DOE did not include any rebound 

effect for WICFs in its NOPR analysis. 

Several commenters agreed that there 

would be no rebound effect for WICFs. 

(ThermoKool, No. 97, at p. 4; APC, No. 

99, at p.8; NEEA et al., No. 101, at p. 6; 

Hillphoenix, No. 107, at p. 5) DOE 

maintained the same approach in 

preparing the final rule. 

To estimate the national energy 

savings expected from energy 

conservation standards, DOE uses a 

multiplicative factor to convert site 

energy consumption (energy use at the 

location where the appliance is 

operated) into primary or source energy 

consumption (the energy required to 

deliver the site energy). For this final 

rule, DOE used conversion factors based 

on AEO 2013. For electricity, the 

conversion factors vary over time 

because of projected changes in 

generation sources (i.e., the types of 

power plants projected to provide 

electricity to the country). Because the 

AEO does not provide energy forecasts 


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beyond 2040, DOE used conversion 

factors that remain constant at the 2040 

values throughout the rest of the 

forecast. 

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) After evaluating 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 the most appropriate tool for 

its FFC analysis and its intention to use 

NEMS for that purpose. 77 FR 49701 

(August 17, 2012). The approach used 

for this final rule, and the FFC 

multipliers that were applied, are 

described in appendix 10E of the final 

rule TSD. NES results are presented in 

both primary energy and FFC savings in 

section V.B.3.a. 

3. Net Present Value of Customer 

Benefit 

The inputs for determining the NPV 

of the total costs and benefits 

experienced by walk-in customers are: 

(1) Total annual installed cost; (2) total 

annual savings in operating costs; and 

(3) a discount factor. DOE calculated net 

national customer savings for each year 

as the difference between the base-case 

scenario and standards-case scenarios in 

terms of installation and operating costs. 

DOE calculated operating cost savings 

over the life of each piece of equipment 

shipped in the forecast period. 

DOE multiplied monetary values in 

future years by the discount factor to 

determine the present value of costs and 

savings. DOE estimated national 

impacts using both a 3-percent and a 7- 

percent real discount rate as the average 

real rate of return on private investment 

in the U.S. economy. These discount 

rates are used in accordance with the 

Office of Management and Budget 

(OMB) guidance to Federal agencies on 

the development of regulatory analysis 

(OMB Circular A–4, September 17, 

2003), and section E, ‘‘Identifying and 

Measuring Benefits and Costs,’’ therein. 

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 the 3- 

percent rate to capture the potential 

effects of amended standards on private 

consumption. This rate represents the 

rate at which society discounts future 

consumption flows to their present 

value. DOE defined the present year as 

2014 for the analysis. 

J. Customer Subgroup Analysis 

In analyzing the potential impact of 

new or amended standards on 

commercial customers, DOE evaluates 

the impact on identifiable groups (i.e., 

subgroups) of customers, such as 

different types of businesses that may be 

disproportionately affected. Small 

businesses typically face a higher cost of 

capital. In general, the higher the cost of 

capital, the more likely it is that an 

entity would be disadvantaged by a 

requirement to purchase higher 

efficiency equipment. Based on data 

from the 2007 U.S. Economic Census 

and size standards set by the U.S. Small 

Business Administration (SBA), DOE 

determined that a majority of small 

restaurants fall under the definition of 

small businesses. It believes that this 

subgroup is broadly representative of 

small businesses that use walk-in 

coolers and walk-in freezers. 

DOE estimated the impacts on the 

identified customer subgroup using the 

LCC spreadsheet model. The inputs for 

small restaurants were fixed to ensure 

that the discount rates, electricity 

prices, and equipment lifetime 

associated with that subgroup were 

selected. The discount rate was further 

increased by applying the small firm 

premium to the WACC. Apart from 

these changes, all other inputs for the 

subgroup analysis are the same as those 

in the LCC analysis. Details of the data 

used for the subgroup analysis and 

results are presented in chapter 11 of 

the final rule TSD. 

K. Manufacturer Impact Analysis 

1. Overview 

DOE performed an MIA to estimate 

the financial impact of new energy 

conservation standards on 

manufacturers of walk-in equipment 

and to determine the impact of such 

standards on employment and 

manufacturing capacity. The MIA has 

both quantitative and qualitative 

aspects. The quantitative part of the 

MIA primarily relies on the Government 

Regulatory Impact Model (GRIM), an 

industry cash-flow model with inputs 

specific to this rulemaking. The key 

GRIM inputs 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 markup 

scenarios will produce different results. 

The qualitative part of the MIA 

addresses factors such as equipment 

characteristics, impacts on particular 

subgroups of manufacturers, and 

important market and product trends. 

The complete MIA is outlined in 

chapter 12 of the final rule TSD. 

DOE conducted the MIA for this 

rulemaking in three phases. In Phase 1 

of the MIA, DOE prepared a profile of 

the walk-in industry that includes a topdown cost analysis of manufacturers 

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 an energy 

conservation standard. In general, morestringent energy conservation standards 

can affect manufacturer cash flow in 

three distinct ways: (1) By creating a 

need for increased investment; (2) by 

raising production costs per unit; and 

(3) by altering revenue due to higher 

per-unit prices and possible changes in 

sales volumes. 

In Phase 3 of the MIA, DOE 

conducted structured, detailed 

interviews with a representative crosssection 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. 

Also in Phase 3, DOE evaluated 

subgroups of manufacturers that may be 

disproportionately impacted by 

amended standards, or that may not be 

accurately represented by the average 

cost assumptions used to develop the 

industry cash-flow analysis. For 

example, small manufacturers, niche 

players, or manufacturers exhibiting a 

cost structure that largely differs from 

the industry average could be more 

negatively affected. 

DOE identified one subgroup, small 

manufacturers, for separate impact 

analyses. DOE applied the small 

business size standards published by 

the SBA to determine whether a 

company is considered a small business. 

65 FR 30836, 30848 (May 15, 2000), as 

amended at 65 FR 53533, 53544 (Sept. 

5, 2000) and codified at 13 CFR part 


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121. 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 or fewer 

employees. The 750-employee threshold 

includes all employees in a business’s 

parent company and any other 

subsidiaries. The small businesses were 

further sub-divided 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 this notice 

and in Chapter 12 of the final rule TSD. 

2. Government Regulatory Impact Model 

DOE uses the GRIM to quantify the 

changes in the walk-in industry cash 

flow due to amended standards that 

result in a higher or lower industry 

value. The GRIM analysis uses a 

standard, annual cash-flow analysis that 

incorporates manufacturer costs, 

markups, shipments, and industry 

financial information as inputs, and 

models changes in costs, investments, 

and manufacturer margins that would 

result from new energy conservation 

standards. The GRIM spreadsheet uses 

the inputs to arrive at a series of annual 

cash flows, beginning with the base year 

of the analysis, 2013 in this case, and 

continuing to 2046. DOE calculated 

INPVs by summing the stream of annual 

discounted cash flows during this 

period. 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 energy conservation 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 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 

(1) Manufacturer Production Costs 

Manufacturing higher efficiency 

equipment is typically more expensive 

than manufacturing baseline equipment 

due to the use of more complex 

components, which are more costly than 

baseline components. The changes in 

the MPCs of the analyzed WICF 

components can affect the revenues, 

gross margins, and cash flow of the 

industry, making these production 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.D and further 

detailed in chapter 5 of the NOPR TSD. 

In addition, DOE used information from 

its teardown analysis, described in 

section IV.D.3, to disaggregate the MPCs 

into material, labor, and overhead costs. 

To calculate the MPCs for equipment 

above the baseline, DOE added 

incremental material, labor, overhead 

costs from the engineering costefficiency curves to the baseline MPCs. 

These cost breakdowns and equipment 

markups were validated with 

manufacturers during manufacturer 

interviews. 

(2) 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. 

(3) Product and Capital Conversion 

Costs 

New energy conservation standards 

will cause manufacturers to incur 

conversion costs to bring their 

production facilities and product 

designs into compliance. For the MIA, 

DOE classified these conversion costs 

into two major groups: (1) Product 

conversion costs and (2) capital 

conversion costs. Product conversion 

costs are investments in research, 

development, testing, marketing, and 

other non-capitalized costs necessary to 

make product designs comply with a 

new or amended energy conservation 

standard. Capital conversion costs are 

investments in property, plant, and 

equipment necessary to adapt or change 

existing production facilities such that 

new product 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 section 

IV.D.3. For the final rule, adjustments 

were made to the capital conversion 

costs based on feedback in the NOPR 

written comments and changes in the 

test procedure for panels and 

refrigeration components. 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. 

Industry certification costs included fire 

safety testing by Underwriter 

Laboratories (UL) and food safety 

certifications by the NSF International 

(NSF). Manufacturers’ data was 

aggregated to better reflect the industry 

as a whole and to protect confidential 

information. For the final rule, 

adjustments were made to product 

conversion costs based on feedback in 

the NOPR written comments and 

changes in the test procedure for panels 

and refrigeration components. 

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 an 

amended standard. The investment 

figures used in the GRIM can be found 

in section V.B.2.a of this notice. For 

additional information on the estimated 

product conversion and capital 

conversion costs, see chapter 12 of the 

final rule TSD. 


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b. Government Regulatory Impact Model 

Scenarios 

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 

markups to the MPCs estimated in the 

engineering analysis and then added in 

the cost of shipping. Modifying these 

markups in the standards case yields 

different sets of impacts on 

manufacturers. For the MIA, DOE 

modeled two standards-case markup 

scenarios to represent the uncertainty 

regarding the potential impacts on 

prices and profitability for 

manufacturers following the 

implementation of amended energy 

conservation standards: (1) A 

preservation of gross margin percentage 

markup scenario; and (2) a preservation 

of operating profit markup scenario. 

These scenarios lead to different 

markups values that, when applied to 

the inputted MPCs, result in varying 

revenue and cash flow impacts. 

Under the preservation of gross 

margin percentage scenario, DOE 

applied a single uniform ‘‘gross margin 

percentage’’ markup across all efficiency 

levels. As production costs increase 

with efficiency, this scenario implies 

that the absolute dollar markup will 

increase as well. Based on publicly 

available financial information for walkin manufacturers, submitted comments, 

and information obtained during 

manufacturer interviews, DOE assumed 

the non-production cost markup— 

which includes SG&A expenses, R&D 

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 1 year after the 

compliance date of the amended energy 

conservation standard is the same as in 

the base case. Under this scenario, as 

the cost of production and the cost of 

sales rise, manufacturers generally must 

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 

During the October 2013 NOPR public 

meeting, interested parties commented 

on the assumptions and results of the 

analyses as described in the TSD. Oral 

and written comments addressed 

several topics, including refrigerants, 

installation contractors, impacts on 

small manufacturers, the base case 

markup, and the number of small panel 

manufacturers in the industry. 

a. Refrigerants 

NAFEM and ICS requested that DOE 

incorporate the phase out of HFCs in its 

analysis. NAFEM stated that alternative 

refrigerants could add to overall 

engineering costs and reduce energy 

savings. (NAFEM, No. 118 at p. 4) (ICS, 

et al., No. 100 at p. 7) (IB, No. 98 at p. 

2). The use of alternative refrigerants is 

not a direct result of this rule and is not 

included in this analysis. Furthermore, 

there is no regulatory requirement to use 

alternative refrigerants at this time. DOE 

does not include the impacts of pending 

legislation or regulatory proposals in its 

analysis, as any impact would be 

speculative. For this final rule, DOE 

does not include the impact of 

alternative refrigerants in its analysis. 

b. Installation Contractors 

ACCA noted that the MIA did not 

assess the impact on installation 

contractors. (ACCA, No. 88 at p. 338) 

Consistent with EPCA, and in keeping 

with industry’s requests submitted at 

the Preliminary Analysis and 

summarized in the proposal, DOE has 

taken a component-based approach in 

setting standards for WICF. (42 U.S.C. 

6311(20)) As such, the MIA focuses on 

manufacturers of WICF panels, WICF 

refrigeration, and WICF doors. DOE 

does not consider the installation 

contractors to be manufacturers for the 

purpose for the Manufacturer Impact 

Analysis as they do not produce the 

panels, refrigeration components, or 

doors being tested, labeled, and 

certified. 

c. Small Manufacturers 

In written comments, manufacturers 

stated that new energy efficiency 

standards would impose severe 

economic hardship on small business 

manufacturers. (Manitowoc, No. 108 at 

p. 4) (Hillphoenix, No. 107 at p. 6) 

(APC, No.99 at p. 20) NAFEM stated 

that small businesses do not have the 

R&D resources to create and implement 

the design options necessary to meet the 

standards. (NAFEM, No. 118 at p. 4) A 

large number of comments focused on 

the economic hardship of small 

business manufacturers that DOE 

considered to be primarily 

manufacturers of WICF panels. These 

comments focused on capital 

conversion costs, product conversion 

costs, and production capacity impacts. 

Hillphoenix and ICS commented that 

increased panel thickness would result 

in excessive capital conversion costs, 

especially for small manufacturers. 

(Hillphoenix, No. 107 at p. 6) (ICS, et 

al., No. 100 at p. 7) US Cooler stated that 

small manufacturers using foamed-inplace polyurethane that do not currently 

have the capability to manufacture 5’’ 

insulation would be faced with costs of 

$800,000 for two foamed-in-place 

fixtures. Arctic stated that in order to 

manufacture 5’’ foamed-in-place 

polyurethane panels, small 

manufacturers would be required to 

invest at least $1M. (Arctic, No. 117 at 

p. 2) Thermo-Kool estimated that the 

equipment cost required to manufacture 

thicker insulation panels would likely 

be in excess of $1 million for each 

manufacturer. (ThermoKool, No. 97 at p. 

2) Arctic and US Cooler added that 

moving from a 4-inch to a 5-inch 

insulation panel would result in 

prohibitive retooling and labor costs for 

small manufacturers currently making 

4-inch panels. (Arctic, No. 117 at p. 1) 

(US Cooler, No. 104 at p. 1) ICS further 

noted that requiring more than 4 inches 

of foam insulation will require thermal 

barriers and automatic fire suppression, 

which are expensive and will add to 

manufacturer burdens and place 

unnecessary costs on end users. (ICS, et 

al., No. 100 at p. 7) US Cooler and 

Arctic asserted that small manufacturers 

using extruded polystyrene (EPS) would 

need to make extensive and costly 

changes to their manufacturing process 

and materials to meet a standard above 

baseline since EPS is only sold in 4’’ 

thick sheets. (US Cooler, No. 104 at p. 

2) (Arctic, No. 117 at p. 1). 

Manufacturers were also concerned 

about the product conversion costs 

related to the standard proposed in the 

NOPR. Specifically, commenters cited 

high testing costs and limited 

availability of test labs accredited to 

perform ASTM C1363 as prohibitive 

barriers to small manufacturers 

complying with the standard. 

(Hillphoenix, No. 107 at p. 6) 

(Hussmann, No. 93 at p. 6) (Arctic, No. 

117 at p. 1) (US Cooler, No. 100 at p. 


tkelley on DSK3SPTVN1PROD with RULES2
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29See North Carolina v. EPA, 550 F.3d 1176 (D.C. 

Cir. 2008); North Carolina v. EPA, 531 F.3d 896 

(D.C. Cir. 2008). 

30See EME Homer City Generation, LP v. EPA, 

696 F.3d 7, 38 (D.C. Cir. 2012). 

6) APC commented that the ASTM 

C1363 test had an excessive cost-burden 

of around $4,000 for each test. (APC, 

No. 99 at p. 1) IB estimated the total cost 

of testing to be in the range of $2.5 

million for a manufacturer and stated 

that such a cost would be prohibitive for 

small businesses. (IB, No. 98 at p. 4) 

Aside from capital conversion costs 

and product conversion costs, panel 

manufacturers noted other concerns 

related to a standard that would require 

an increase in panel thickness. Nor-Lake 

noted that increased panel thickness 

would raise production costs. These 

higher production costs stem in part 

from the additional curing time needed 

for thicker panels—Nor-Lake pointed 

out that a 4’’ panel took approximately 

25 minutes to cure, while 5’’ and 6’’ 

panels took 45 minutes and one hour, 

respectively, to cure. (Nor-Lake, No. 115 

at p. 1) APC agreed with Nor-Lake’s cure 

time estimates and further noted that a 

5’’ panel would force manufacturers to 

lose 1/3rd of their production capacity. 

(APC, No. 99 at p. 4) Manitowoc stated 

that thicker panels would be heavier, 

necessitating longer curing times and 

raising safety concerns during the 

manufacturing process. (Manitowoc, No. 

108 at p. 3) 

DOE has taken the industry’s feedback 

on capital conversion costs, product 

conversion costs, production capacity 

implications into account in its final 

rule analysis. As a result, DOE selected 

a standard level that is equivalent to the 

current baseline for WICF panels. 

Consequently, DOE expects that no new 

investment in capital equipment or 

outside testing would be necessary to 

meet the standard, thereby minimizing 

impacts on small manufacturers. 

d. Mark Up Scenarios 

Manufacturers submitted several 

comments with regard to manufacturer 

markups. Hussmann stated that the 

market does not use a simple markup 

and that markups vary based on 

customer payback periods and each 

manufacturer’s ability to maximize 

profits. (Hussmann, No.93 and p.3) 

Thermokool submitted a comment that 

DOE’s markups are extremely 

undervalued. (ThermoKool, No 97 at 

p.3) APC noted that panel markups are 

closer to 1.46 (rather than DOE’s value 

of 1.32) and refrigeration markups are 

closed to 1.45 (rather than DOEs markup 

of 1.35). (APC, No 99 at p.6) 

While applying a simple markup on 

manufacturer production cost may not 

be a common practice to arrive at a 

selling price for walk-in panel 

manufacturers, DOE believes applying a 

simple industry-average markup is a 

useful tool for modeling the industry as 

a whole. DOE validated its markup 

values with eight different panel 

manufacturers during manufacturer 

interviews. While the industry-average 

markup values may be low for specific 

companies, especially for small 

manufacturers, DOE notes that using 

low markup assumptions provides a 

more conservative analysis, which 

ensures that DOE does not understate 

the potential negative impacts on 

industry. 

e. Number of Small Businesses 

American Panel commented on the 

number of manufacturers in the WICF 

panel industry. It estimates that there 

are only 5 large manufacturers of walkin panels. Therefore, American Panel 

suggested that 42 of 47 walk-in panel 

manufacturers (89%) are small 

businesses, not 42 of 52 (81%) as 

estimated by DOE in the NOPR. 

DOE identified 5 parent companies 

with 10 subsidiaries that produce walkin panels. This is consistent with 

American Panel’s written comment that 

there are only 5 large manufacturers of 

walk-in panels. DOE has revised its 

regulatory flexibility analysis to more 

accurately reflect the number of large 

and small manufacturers identified in 

the industry. 

L. Emissions Analysis 

In the emissions analysis, DOE 

estimated the reduction in power sector 

emissions of CO2, NOX, sulfur dioxide 

(SO2) and Hg from amended energy 

conservation standards for walk-in 

coolers and walk-in 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)) 77 FR 49701 (August 17, 

2012), 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 for CO2

and most of the other gases derived from 

data in 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 13 of the final rule TSD. 

EIA prepares the Annual Energy 

Outlook using 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, 2012. 

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 (42 U.S.C. 7651 et 

seq.) 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. CAIR 

was remanded to the U.S. 

Environmental Protection Agency (EPA) 

by the U.S. Court of Appeals for the 

District of Columbia but it remained in 

effect.29 In 2011, EPA issued a 

replacement for CAIR, the Cross-State 

Air Pollution Rule (CSAPR). 76 FR 

48208 (Aug. 8, 2011). On August 21, 

2012, the D.C. Circuit issued a decision 

to vacate CSAPR.30 The court ordered 

EPA to continue administering CAIR. 

The AEO 2013 emissions factors used 

for this final rule 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 a new or 

amended 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 capand-trade system, but it concluded that 

negligible reductions in power sector 

SO2 emissions would occur as a result 

of standards. 

Beginning around 2015, however, SO2

emissions will fall as a result of the 

Mercury and Air Toxics Standards 

(MATS) for power plants. 77 FR 9304 

(Feb. 16, 2012). In the final MATS rule, 

EPA established a standard for hydrogen 

chloride as a surrogate for acid gas 

hazardous air pollutants (HAP), and also 

established a standard for SO2 (a nonHAP acid gas) as an alternative 


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32094 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

31National Research Council. Hidden Costs of 

Energy: Unpriced Consequences of Energy 

Production and Use. 2009. National Academies 

Press: Washington, DC. 

equivalent surrogate standard for acid 

gas HAP. The same controls are used to 

reduce HAP and non-HAP acid gas; 

thus, SO2 emissions will be reduced as 

a result of the control technologies 

installed on coal-fired power plants to 

comply with the MATS requirements 

for acid gas. AEO2013 assumes that, in 

order to continue operating, coal plants 

must have either flue gas 

desulfurization or dry sorbent injection 

systems installed by 2015. Both 

technologies, which are used to reduce 

acid gas emissions, also reduce SO2

emissions. Under the MATS, NEMS 

shows a reduction in SO2 emissions 

when electricity demand decreases (e.g., 

as a result of energy efficiency 

standards). Emissions will be far below 

the cap that would be established by 

CAIR, so it is unlikely that excess SO2

emissions allowances resulting from the 

lower electricity demand would be 

needed or used to permit offsetting 

increases in SO2 emissions by any 

regulated EGU. Therefore, DOE believes 

that energy efficiency standards will 

reduce SO2 emissions in 2015 and 

beyond. 

CAIR established a cap on NOX

emissions in 28 eastern States and the 

District of Columbia. Energy 

conservation standards are expected to 

have little effect on NOX emissions in 

those States covered by CAIR because 

excess NOX emissions allowances 

resulting from the lower electricity 

demand could be used to permit 

offsetting increases in NOX emissions. 

However, standards would be expected 

to reduce NOX emissions in the States 

not affected by the caps, so DOE 

estimated NOX emissions reductions 

from the standards considered in this 

final rule 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 factors 

based on AEO2013, which incorporates 

the MATS. 

M. Monetizing Carbon Dioxide and 

Other Emissions Impacts 

As part of the development of the 

standards in this final rule, DOE 

considered the estimated monetary 

benefits from the reduced emissions of 

CO2 and NOX that are expected to result 

from each of the TSLs considered. In 

order to make this calculation analogous 

to the calculation of the NPV of 

customer benefit, DOE considered the 

reduced emissions expected to result 

over the lifetime of equipment shipped 

in the forecast period for each TSL. This 

section summarizes the basis for the 

monetary values used for each of these 

emissions and presents the values 

considered in this final rule. 

For this final rule, DOE is relying on 

a set of values for the SCC that was 

developed by a Federal interagency 

process. The basis for these values is 

summarized below, and a more detailed 

description of the methodologies used is 

provided as an appendix to chapter 14 

of the final rule 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. 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 challenges. A report from the 

National Research Council 31 points out 

that any assessment will suffer from 

uncertainty, speculation, and lack of 

information about (1) future emissions 

of GHGs; (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 questions of science, 

economics, and ethics and should be 

viewed as provisional. 

Despite the limits of both 

quantification and monetization, SCC 

estimates can be useful in estimating the 

social benefits of reducing CO2

emissions. 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. 

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. Development of Social Cost of Carbon 

Values 

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 

Federal 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 


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32 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. 

33Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United 

States Government, February 2010. 

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

inforeg/for-agencies/Social-Cost-of-Carbon-forRIA.pdf. 

34Technical Update of the Social Cost of Carbon 

for Regulatory Impact Analysis Under Executive 

Order 12866. Interagency Working Group on Social 

Cost of Carbon, United States Government. May 

2013; revised November 2013. http://www.white

house.gov/sites/default/files/omb/assets/inforeg/

technical-update-social-cost-of-carbon-for-regulator

-impact-analysis.pdf. 

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 

After the release of the interim values, 

the interagency group reconvened on a 

regular basis to generate improved SCC 

estimates. Specially, the group 

considered public comments and 

further explored the technical literature 

in relevant fields. The interagency group 

relied on three integrated assessment 

models (IAMs) commonly used to 

estimate the SCC: The FUND, DICE, and 

PAGE models. These models are 

frequently cited in the peer-reviewed 

literature and were used in the last 

assessment of the Intergovernmental 

Panel on Climate Change. Each model 

was given equal weight in the SCC 

values that were developed. 

Each model takes a slightly different 

approach to model how changes in 

emissions result in changes in economic 

damages. A key objective of the 

interagency process was to enable a 

consistent exploration of the three 

models, while respecting the 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 IAMs, 

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, was included to represent higher 

than expected impacts from temperature 

change further out in the tails of the 

SCC distribution. The values grow in 

real terms over time. Additionally, the 

interagency group determined that a 

range of values from 7 percent to 23 

percent should be used to adjust the 

global SCC to calculate domestic 

effects,32 although preference is given to 

consideration of the global benefits of 

reducing CO2 emissions. 

Table IV.14 presents the values in the 

2010 interagency group report,33 which 

is reproduced in appendix 14A of the 

final rule TSD. 

TABLE IV.14—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050 

[2007 Dollars per metric ton CO2] 

Year 

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 this rule 

were generated using the most recent 

versions of the three integrated 

assessment models that have been 

published in the peer-reviewed 

literature.34 Table IV.15 shows the 

updated sets of SCC estimates in 5-year 

increments from 2010 to 2050. The full 

set of annual SCC estimates between 

2010 and 2050 is reported in appendix 

14B of the final rule 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. 

Table IV.15 Annual SCC Values from 

2013 Interagency Report, 2010–2050 

(2007 dollars per metric ton) 


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35Available at: http://www.whitehouse.gov/sites/

default/files/omb/inforeg/social_cost_of_carbon_

for_ria_2013_update.pdf. 

36Available at: http://www.cio.noaa.gov/services_

programs/pdfs/OMB_Peer_Review_Bulletin_m05- 

03.pdf. 

TABLE IV.15—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050 

[2007 Dollars per metric ton] 

Year 

Discount rate 

5% 3% 2.5% 3% 

Average Average Average 95th percentile 

2010 ................................................................................................................. 11 32 51 89 

2015 ................................................................................................................. 11 37 57 109 

2020 ................................................................................................................. 12 43 64 128 

2025 ................................................................................................................. 14 47 69 143 

2030 ................................................................................................................. 16 52 75 159 

2035 ................................................................................................................. 19 56 80 175 

2040 ................................................................................................................. 21 61 86 191 

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

2050 ................................................................................................................. 26 71 97 220 

It is important to recognize that a 

number of key uncertainties remain, and 

that current SCC estimates should be 

treated as provisional and revisable 

since they will evolve with improved 

scientific and economic understanding. 

The interagency group also recognizes 

that the existing models are imperfect 

and incomplete. The 2009 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 analytic challenges that are 

being 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 2013$ using the GDP price 

deflator. For each of the four sets of SCC 

values, the values for emissions in 2015 

were $12.0, $40.5, $62.4, and $119 per 

metric ton avoided (values expressed in 

2013$). 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. 

In responding to the walk-in coolers 

and walk-in freezers NOPR, many 

commenters questioned the scientific 

and economic basis of the SCC values. 

These commenters made extensive 

comments about: the alleged lack of 

economic theory underlying the models; 

the sufficiency of the models for policymaking; potential flaws in the models’ 

inputs and assumptions (including the 

discount rates and climate sensitivity 

chosen); whether there was adequate 

peer review of the three models; 

whether there was adequate peer review 

of the TSD supporting the 2013 SCC 

values; 35 whether the SCC estimates 

comply with OMB’s ‘‘Final Information 

Quality Bulletin for Peer Review’’ 36 and 

DOE’s own guidelines for ensuring and 

maximizing the quality, objectivity, 

utility and integrity of information 

disseminated by DOE; and why DOE is 

considering global benefits of carbon 

dioxide emission reductions rather than 

solely domestic benefits. (See AHRI, No. 

83; ANGA, et al./Chamber of Commerce, 

No.95; Cato, No. 106; Mercatus, No. 91). 

Several other parties expressed support 

for the derivation and application of the 

SCC values. (EDF, et al., No. 94; ASAP, 

No. 113; Kopp, No. 80) 

In response to the comments on the 

SCC values, DOE acknowledges the 

limitations in the SCC estimates, which 

are discussed in detail in the 2010 

interagency group report. Specifically, 

uncertainties in the assumptions 

regarding climate sensitivity, as well as 

other model inputs such as economic 

growth and emissions trajectories, are 

discussed and the reasons for the 

specific input assumptions chosen are 

explained. Regarding discount rates, 

there is not consensus in the scientific 

or economics literature regarding the 

appropriate discount rate to use for 

intergenerational time horizons. The 

SCC estimates thus use a reasonable 

range of discount rates, from 2.5% to 

5%, in order to show the effects that 

different discount rate assumptions 

have on the estimated values. More 

information about the choice of 

discount rates can be found in the 2010 

interagency group report starting on 

page 17. 

Regarding peer review of the models, 

the three integrated assessment models 

used to estimate the SCC are frequently 

cited in the peer-reviewed literature and 

were used in the last assessment of the 

IPCC. In addition, new versions of the 

models that were used in 2013 to 

estimate revised SCC values were 

published in the peer-reviewed 

literature (see appendix 16B of the DOE 

final rule TSD for discussion). 

DOE believes that the SCC estimates 

comply with OMB’s Final Information 

Quality Bulletin for Peer Review and 

DOE’s own guidelines for ensuring and 

maximizing the quality, objectivity, 

utility and integrity of information 

disseminated by DOE. 

As to why DOE is considering global 

benefits of carbon dioxide emission 

reductions rather than solely domestic 

benefits, a global measure of SCC 

because of the distinctive nature of the 

climate change problem, which is 

highly unusual in at least two respects. 

First, it involves a global externality: 

emissions of most greenhouse gases 

contribute to damages around the world 

even when they are emitted in the 

United States. Second, climate change 

presents a problem that the United 

States alone cannot solve. The issue of 

global versus domestic measures of the 

SCC is further discussed in appendix 

16A of the DOE final rule TSD. 

In November 2013, OMB announced 

minor technical corrections to the 2013 

SCC values and a new opportunity for 


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37The values for NOX emissions originally came 

from: 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. In 

2001$, the NOX values range from $370 to $3,800 

per short ton. DOE converted the 2001$ values to 

2013$ using gross domestic product (GDP) price 

deflators from the Bureau of Economic Analysis 

(BEA) (see http://research.stlouisfed.org/fred2/

series/GDPDEF/). 

public comment on the interagency 

technical support document underlying 

the SCC estimates. See 78 FR 70586. 

The comment period for the OMB 

announcement closed on February 26, 

2014. OMB is currently reviewing 

comments and considering whether 

further revisions to the 2013 SCC 

estimates are warranted to the 

underlying science and economic basis 

of the SCC estimates resulting from the 

interagency process. DOE stands ready 

to work with OMB and the other 

members of the interagency working 

group on further review and revision of 

the SCC estimates as appropriate. 

AHRI stated that DOE calculates the 

present value of the costs of standards 

to consumers and manufacturers over a 

30-year period, but the SCC values 

reflect the present value of future 

climate related impacts well beyond 

2100. AHRI stated that DOE’s 

comparison of 30 years of cost to 

hundreds of years of presumed future 

benefits is inconsistent and improper. 

(AHRI, No. 114 at p. 6) 

For the analysis of national impacts of 

the proposed standards, DOE 

considered the lifetime impacts of 

products shipped in a 30-year period. 

With respect to energy and energy cost 

savings, impacts continue past 30 years 

until all of the products shipped in the 

30-year period are retired. With respect 

to the valuation of CO2 emissions 

reductions, DOE considers the avoided 

emissions over the same period as the 

energy savings. CO2 emissions have on 

average a very long residence time in 

the atmosphere. Thus, emissions in the 

period considered by DOE would 

contribute to global climate change over 

a very long time period, with associated 

social costs. The SCC for any given year 

represents the discounted present value, 

in that year and expressed in constant 

dollars, of a lengthy stream of future 

costs estimated to result from the 

emission of one ton of CO2. It is worth 

pointing out that because of 

discounting, the present value of costs 

in the distant future is very small. DOE’s 

accounting of energy cost savings and 

the value of avoided CO2 emissions 

reductions is consistent—both consider 

the complete impacts associated with 

products shipped in the 30-year period. 

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 emissions caps. 

DOE estimated the monetized value of 

NOX emissions reductions resulting 

from each of the TSLs considered for 

this final rule based on estimates found 

in the relevant scientific literature. 

Estimates of monetary value for 

reducing NOX from stationary sources 

range from $476 to $4,893 per ton 

(2013$).37 DOE calculated monetary 

benefits using a medium value for NOX

emissions of $2,684 per short ton (in 

2013$), and real discount rates of 3 

percent and 7 percent. 

DOE is evaluating how to 

appropriately monetize avoided SO2

and Hg emissions in energy 

conservation standards rulemakings. It 

has not included monetization of these 

emissions in the current analysis. 

N. 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 from the NIA the energy 

savings inputs associated with 

efficiency improvements made to the 

equipment under consideration. DOE 

conducts the utility impact analysis as 

a scenario that departs from the latest 

AEO Reference Case. In the analysis for 

this 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 15 of the final rule 

TSD. 

O. Employment Impact Analysis 

Employment impacts are one of the 

factors that DOE considers in selecting 

an efficiency standard. Employment 

impacts include direct and indirect 

impacts. Direct employment impacts are 

any changes that affect the ability of 

walk-in equipment manufacturers, their 

suppliers, and related service firms to 

employ workers. Indirect impacts are 

changes in employment 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. Direct 

employment impacts are analyzed as 

part of the MIA. Indirect impacts are 

assessed as part of the employment 

impact analysis. 

Indirect employment impacts from 

amended standards consist of the net 

jobs created or eliminated in the 

national economy, other than in the 

manufacturing sector being regulated, as 

a consequence of (1) reduced spending 

by end users on electricity; (2) reduced 

spending on new energy supplies by the 

utility industry; (3) increased spending 

on the purchase price of new covered 

equipment; and (4) the effects of those 

three factors throughout the Nation’s 

economy. DOE expects the net monetary 

savings from amended 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 for these 

standard, DOE estimated indirect 

national employment impacts using an 

input/output model of the U.S. economy 

called Impact of Sector Energy 

Technologies, Version 3.1.1 (ImSET). 

ImSET is a special-purpose version of 

the ‘‘U.S. Benchmark National InputOutput’’ (I–O) model, which was 

designed to estimate the national 

employment and income effects of 

energy-saving technologies. The ImSET 

software includes a computer-based I–O 

model having structural coefficients that 

characterize economic flows among the 

187 sectors. ImSET’s national economic 

I–O structure is based on a 2002 U.S. 

benchmark table, specially aggregated to 

the 187 sectors most relevant to 

industrial, commercial, and residential 

building energy use. DOE notes that 

ImSET is not a general equilibrium 

forecasting model, and understands the 

uncertainties involved in projecting 

employment impacts, especially 

changes in the later years of the 

analysis. Because ImSET does not 

incorporate price changes, the 

employment effects predicted by ImSET 

may over-estimate actual job impacts 

over the long run. For the NOPR, DOE 

used ImSET only to estimate short-term 

employment impacts. 

For more details on the employment 

impact analysis and its results, see 

chapter 16 of the final rule TSD. 

V. Analytical Results 

A. Trial Standard Levels 

As discussed in section III.B, DOE is 

setting separate performance standards 

for the refrigeration system and for the 

envelope’s doors and panels. The 


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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. Each TSL consists of a standard 

for refrigeration systems, a standard for 

panels, a standard for non-display 

doors, and a standard for display doors. 

1. Trial Standard Level Selection 

Process 

This section describes how DOE 

selected the TSLs. First, DOE selected 

several potential efficiency levels for 

refrigeration systems by performing LCC 

and NIA analyses for refrigeration 

systems. Second, DOE selected levels 

for the envelope components by 

performing LCC and NIA analyses for 

the envelope components paired with 

each of the selected refrigeration system 

levels alone. Third, DOE chose three 

composite TSLs from the combinations 

of the potential levels for the 

refrigeration systems and the 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. 

DOE enumerated up to ten potential 

efficiency levels for each of the 

refrigeration system classes and capacity 

points. Each analyzed capacity point in 

any refrigeration system had efficiency 

levels corresponding to an added 

applicable design option (described in 

section IV.D). DOE also analyzed three 

competing compressor technologies for 

each dedicated condensing refrigeration 

system class. These compressor 

technologies are: Hermetic 

reciprocating, semi-hermetic, and scroll. 

(For a detailed description regarding 

each of these compressor technologies, 

see chapter 5 of the final rule TSD.) 

At a given efficiency level, the 

compressor with the lowest 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 three for 

further analysis. The first refrigeration 

system levels were based on the 

maximum technology from the 

engineering analysis, the second their 

relative energy saving potential while 

maintaining positive national net 

present values for each equipment class. 

The last was based on maximizing the 

national net present value (‘‘Max NPV’’). 

After the three 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 

refrigeration system efficiency levels. 

Each panel and door class has between 

four 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 

final rule TSD. 

DOE selected envelope component 

levels for further analysis based on the 

following criteria: maximum NPV, 

maximum NES with positive NPV, and 

maximum NES (Max Tech). 

Finally, DOE chose three composite 

TSLs by selecting from the 

combinations of the three potential 

levels for the refrigeration systems and 

the three potential levels for the 

envelope components. The composite 

TSLs and criteria for each one are 

shown in Table V.1. The composite 

TSLs are numbered from 1 to 3 in order 

of least to most energy savings. 

TABLE V.1—CRITERIA DESCRIPTION FOR THE COMPOSITE TSLS

TSL Component requirement System requirement 

1 ......................................................................... Max NPV @7% discount rate .......................... Max NPV @7% discount rate. 

2 ......................................................................... Max NES with NPV >$0 ................................... Max NES with NPV >$0. 

3 ......................................................................... Max Tech ......................................................... Max Tech. 

* NPV is evaluated discounted at 7%. 

TSL 3 is the max-tech level for each 

equipment class for all components. 

TSL 2 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 1 

corresponds to the efficiency level with 

the maximum NPV at a 7-percent 

discount rate for refrigeration system 

classes and components. Table V.2 

shows the mapping of TSLs to analysis 

point ELs and capacity. For more details 

on the criteria for the TSLs, see chapter 

10 of the final rule TSD. 


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TABLE V.2—MAPPING BETWEEN TSLS AND ANALYTICAL POINT ELS

Equipment class 

Nominal 

size 

(Btu/h) 

Baseline TSL 1 TSL 2 TSL 3 

Compressor 

technology EL Compressor technology EL Compressor technology EL Compressor technology EL 

DC.M.I. .......................................................... 6,000 HER ........... 0 SEM ........... 6 SEM ........... 6 SEM ........... 6 

DC.M.I. .......................................................... 18,000 HER ........... 0 HER ........... 6 HER ........... 6 HER ........... 6 

DC.M.I. .......................................................... 54,000 SEM ........... 0 SEM ........... 6 SEM ........... 6 SEM ........... 6 

DC.M.I. .......................................................... 96,000 SEM ........... 0 SEM ........... 6 SEM ........... 6 SEM ........... 6 

DC.M.O. ........................................................ 6,000 HER ........... 0 SEM ........... 4 SEM ........... 7 SEM ........... 7 

DC.M.O. ........................................................ 18,000 HER ........... 0 HER ........... 7 SCR ........... 8 SCR ........... 8 

DC.M.O. ........................................................ 54,000 SEM ........... 0 SCR ........... 6 SCR ........... 10 SCR ........... 10 

DC.M.O. ........................................................ 96,000 SEM ........... 0 SCR ........... 8 SCR ........... 9 SCR ........... 9 

DC.L.I. ........................................................... 6,000 HER ........... 0 HER ........... 7 SCR ........... 7 SCR ........... 7 

DC.L.I. ........................................................... 9,000 HER ........... 0 HER ........... 7 SCR ........... 7 SCR ........... 7 

DC.L.I. ........................................................... 54,000 SEM ........... 0 SEM ........... 7 SEM ........... 8 SEM ........... 8 

DC.L.O. ......................................................... 6,000 HER ........... 0 HER ........... 4 SCR ........... 10 SCR ........... 10 

DC.L.O. ......................................................... 9,000 HER ........... 0 HER ........... 6 SCR ........... 11 SCR ........... 11 

DC.L.O. ......................................................... 54,000 SEM ........... 0 SCR ........... 9 SCR ........... 10 SCR ........... 10 

DC.L.O. ......................................................... 72,000 SEM ........... 0 SEM ........... 8 SEM ........... 12 SEM ........... 12 

MC.M.N. ........................................................ 4,000 6FIN ........... 0 6FIN ........... 3 6FIN ........... 3 6FIN ........... 3 

MC.M.N. ........................................................ 9,000 6FIN ........... 0 6FIN ........... 3 6FIN ........... 3 6FIN ........... 3 

MC.M.N. ........................................................ 24,000 6FIN ........... 0 6FIN ........... 3 6FIN ........... 3 6FIN ........... 3 

MC.L.N. ......................................................... 4,000 4FIN ........... 0 4FIN ........... 4 4FIN ........... 4 4FIN ........... 4 

MC.L.N. ......................................................... 9,000 6FIN ........... 0 6FIN ........... 4 6FIN ........... 4 6FIN ........... 4 

MC.L.N. ......................................................... 18,000 4FIN ........... 0 4FIN ........... 3 4FIN ........... 5 4FIN ........... 5 

MC.L.N. ......................................................... 40,000 4FIN ........... 0 4FIN ........... 3 4FIN ........... 5 4FIN ........... 5 

While DOE maintained the same 

methodology in the final rule as it did 

in the NOPR for mapping ELs to TSLs, 

the number of TSLs has changed for this 

final rule. In the NOPR DOE established 

six TSLs to specifically examine the 

impacts of a standard where (a) all 

compressor technologies could meet a 

minimum efficiency as a system 

requirement, and (b) only display doors 

had an NPV > $0 as a component 

requirement. These criteria were created 

in addition to the three TSL criteria 

used in this final rule, for to a total of 

six NOPR TSLs. The criteria for 

selecting TSL in the NOPR and this final 

rule are shown in Table V.3, as shown 

in this table, the NOPR TSLs 4 through 

6 are equivalent to the final rule TSLs 

1 through 3. 

TABLE V.3—COMPARISON OF NOPR TO FINAL RULE TSL CRITERIA

NOPR TSL criteria Final rule TSL criteria 

TSL System requirement Component 

requirement TSL System requirement Component requirement 

1 .......... All Compressors Max NPV .. Max NPV (all components). 

2 .......... Max NPV .............................. Display Doors, NPV > $0. 

3 .......... All Compressors NPV > $0 .. Max NES, NPV > $0. 

4 .......... Max NPV .............................. Max NPV .............................. 1 Max NPV .............................. Max NPV. 

5 .......... Max NES, NPV > $0 ............ Max NES, NPV > $0 ............ 2 Max NES, NPV > $0 ............ Max NES, NPV > $0. 

6 .......... Max Tech ............................. Max Tech ............................. 3 Max Tech ............................. Max Tech. 

The ‘‘All Compressors’’ NOPR 

refrigeration systems TSLs (TSLs 1, and 

3) were added to the NOPR in response 

to stakeholder comments during the 

initial phase of the rule-making. For this 

final rule, the three TSLs considered by 

DOE are inclusive of all compressor 

types. Subsequently, the ‘‘All 

Compressors’’ TSLs are redundant in 

this final rule; and were therefore 

dropped from the analysis. 

The ‘‘Display Doors, NPV > $0’’ NOPR 

component TSL (TSL 2) was dropped 

from the final rule because Max NPV, 

and Max NES where NPV is greater than 

$0 only occur in this final rule under 

conditions where all components are 

held at the baseline except for the 

equipment classes covering display 

doors. Hence, for this final rule TSLs 1 

and 2 effectively use the ‘‘Display 

Doors’’ criterion. 

2. Trial Standard Level Equations 

For panels, DOE expresses the TSLs 

in terms of R-value. As discussed in 

section III.B.1, DOE is no longer 

requiring the performance-based 

procedures to calculate a U-value of a 

walk-in panel. The Department reverted 

to thermal resistance, or R-value, as 

measured by ASTM C518, as the metric 

for establishing performance standards 

for walk-in cooler and freezer panels. 

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 


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surface area is defined in the walk-in 

cooler and freezer test procedure final 

rule. 

For refrigeration systems, the TSLs are 

expressed as a minimum efficiency level 

(AWEF) that the system must meet. For 

low temperature, dedicated condensing 

systems (DC.L classes), DOE calculated 

the AWEF differently for small and large 

classes based on DOE’s expectation that 

small-sized equipment may have 

difficulty meeting the same efficiency 

standard as large equipment. 

Specifically, DOE observed that for low 

temperature systems, higher-capacity 

equipment tended to be more efficient 

than lower-capacity equipment (DOE 

did not observe strong trends of this 

form for medium temperature 

equipment). DOE expressed the AWEF 

for the small capacity dedicated 

condensing systems as a linear equation 

normalized to the system’s gross 

capacity, where the equation was based 

on the AWEFs for the smallest two 

capacities analyzed. DOE expressed the 

AWEF for large capacity dedicated 

condensing systems as a single number 

corresponding to a value continuous 

with the standard level for the small 

capacity class at the boundary capacity 

point between the classes (i.e., 9,000 

Btu/h). DOE calculated a single 

minimum efficiency for each multiplex 

condensing system class because DOE 

found that equipment capacity did not 

have a significant effect on equipment 

efficiency. See chapter 10 of the final 

rule TSD for details regarding the AWEF 

calculations. 

Table V.4, Table V.5, Table V.6, Table 

V.7, Table V.8, Table V.9, and Table 

V.10 show the R-values or equations 

analyzed for structural cooler panels, 

structural freezer panels, freezer floor 

panels, display doors, non-display 

passage doors, non-display freight 

doors, and refrigeration systems, 

respectively. For walk-in cooler 

structural panels, DOE evaluated a 

market baseline R-value that is higher 

than the current energy conservation 

levels in TSLs 1 and 2. As explained 

further in section IV.D.3, DOE 

established an industry representative 

baseline for walk-in components, but 

this baseline assumed a specific 

insulation material and thickness while 

EISA established R-value standards 

irrespective of such features. 

Additionally, DOE notes 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 

2) is the same as the efficiency level 

corresponding to max-tech (TSL 3). 

TABLE V.4—R-VALUES FOR ALL

STRUCTURAL COOLER PANEL TSLS

TSL 

Equations for 

R-value 

(h-ft2-°F/Btu) 

Baseline ............................ 28 

TSL 1 ................................ 28 

TSL 2 ................................ 28 

TSL 3 ................................ 90 

TABLE V.5—R-VALUES FOR ALL

STRUCTURAL FREEZER PANEL TSLS

TSL 

Equations for 

R-value 

(h-ft2-°F/Btu) 

Baseline ............................ 32 

TSL 1 ................................ 32 

TSL 2 ................................ 32 

TSL 3 ................................ 90 

TABLE V.6—R-VALUES FOR ALL

FREEZER FLOOR PANEL TSLS

TSL 

Equations for 

maximum 

R-value 

(h-ft2-°F/Btu) 

Baseline ............................ 28 

TSL 1 ................................ 28 

TSL 2 ................................ 28 

TSL 3 ................................ 90 

TABLE V.7—EQUATIONS FOR ALL DISPLAY DOOR TSLS

TSL 

Equations for maximum energy 

consumption (kWh/day) 

DD.M DD.L 

Baseline .................................................................................................................................................. 0.14 × Add + 0.82 0.04 × Add + 0.88 

TSL 1 ...................................................................................................................................................... 0.05 × Add + 0.39 0.09 × Add + 1.9 

TSL 2 ...................................................................................................................................................... 0.04 × Add + 0.41 0.15 × Add + 0.29 

TSL 3 ...................................................................................................................................................... 0.008 × Add + 0.29 0.11 × Add + 0.32 

*Add represents the surface area of the display door. 

TABLE V.8—EQUATIONS FOR ALL PASSAGE DOOR TSLS

TSL 

Equations for maximum energy 

consumption (kWh/day) 

PD.M PD.L 

Baseline .................................................................................................................................................. 0.05 × And + 1.7 0.14 × And + 4.8 

TSL 1 ...................................................................................................................................................... 0.05 × And + 1.7 0.14 × And + 4.8 

TSL 2 ...................................................................................................................................................... 0.05 × And + 1.7 0.14 × And + 4.8 

TSL 3 ...................................................................................................................................................... 0.04 × And + 1.6 0.13 × And + 3.9 

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


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TABLE V.9—EQUATIONS FOR ALL FREIGHT DOOR TSLS

TSL 

Equations for maximum energy 

consumption (kWh/day) 

FD.M FD.L 

Baseline .................................................................................................................................................. 0.04 × And + 1.9 0.12 × And + 5.6 

TSL 1 ...................................................................................................................................................... 0.04 × And + 1.9 0.12 × And + 5.6 

TSL 2 ...................................................................................................................................................... 0.04 × And + 1.9 0.12 × And + 5.6 

TSL 3 ...................................................................................................................................................... 0.03 × And + 1.9 0.09 × And + 5.2 

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

TABLE V.10—AWEFS FOR ALL REFRIGERATION SYSTEM TSLS

Equipment class 

Equations for minimum AWEF (Btu/W-h)* 

Baseline TSL 1 TSL 2 TSL 3 

DC.M.I, <9,000 ............................................................... 3.51 5.61 5.61 5.61 

DC.M.I, ≥9,000 ............................................................... 3.51 5.61 5.61 5.61 

DC.M.O, <9,000 ............................................................. 3.14 6.99 7.60 7.60 

DC.M.O, ≥9,000 ............................................................. 3.14 6.99 7.60 7.60 

DC.L.I, <9,000 ................................................................ 1.39 × 10¥4 × Q + 

0.98 

8.67 × 10¥5 × Q + 

2.00 

5.93 × 10¥5 × Q + 

2.33 

5.93 × 10¥5 × Q + 

2.33 

DC.L.I, ≥9,000 ................................................................ 2.23 2.78 3.10 3.10 

DC.L.O, <9,000 .............................................................. 1.96 × 10¥4 × Q + 

0.82 

3.21 × 10¥4 × Q + 

1.29 

2.30 × 10¥4 × Q + 

2.73 

2.30 × 10¥4 × Q + 

2.73 

DC.L.O, ≥9,000 .............................................................. 2.57 4.17 4.79 4.79 

MC.M .............................................................................. 6.11 10.89 10.89 10.89 

MC.L ............................................................................... 3.29 5.58 6.57 6.57 

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

B. Economic Justification and Energy 

Savings 

1. Economic Impacts on Commercial 

Customers 

a. Life-Cycle Cost and Payback Period 

Customers affected by new or 

amended standards usually incur higher 

purchase prices and 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 final rule. 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 equipment use. 

DOE created 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. 

Table V.11 through Table V.19 show 

key results of the LCC and PBP analysis 

for each equipment class. Each table 

presents the mean LCC, mean LCC 

savings, median PBP, and distribution 

of customer impacts in the form of 

percentages of customers who 

experience net cost, no impact, or net 

benefit. Generally, customers who 

currently buy equipment in the base 

case scenario at or above the level of 

performance specified by the TSL under 

consideration would be unaffected if the 

amended standard were to be set at that 

TSL. Customers who buy equipment 

below the level of the TSL under 

consideration would be affected if the 

amended standard were to be set at that 

TSL. Among these affected customers, 

some may benefit (lower LCC) and some 

may incur net cost (higher LCC). 

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

SYSTEMS—OUTDOOR CONDENSER

TSL 

Energy 

consumption 

kWh/yr 

Mean values 2013$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Annual 

operating 

cost 

LCC 

Average 

savings 

2013$ 

Customers that experience 

Net cost 

% 

No 

impact 

% 

Net benefit 

% 

1 ............... 13484 11153 2172 28825 6382 0 0 100 1.1 

2 ............... 12414 12060 2087 29036 6533 0 0 100 2.2 

3 ............... 12414 12060 2087 29036 6533 0 0 100 2.2 


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TABLE V.12—SUMMARY LCC AND PBP RESULTS FOR MEDIUM-TEMPERATURE DEDICATED CONDENSING REFRIGERATION

SYSTEMS—INDOOR CONDENSER

TSL 

Energy 

consumption 

kWh/yr 

Mean values 

2013$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Annual 

operating 

cost 

LCC 

Average 

savings 

2013$ 

Customer that experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

1 ............... 7550 5997 1512 18320 1485 0 0 100 2.8 

2 ............... 16396 11484 2560 32218 5942 2 0 98 3.5 

3 ............... 16396 11484 2560 32218 5942 2 0 98 3.5 

TABLE V.13—SUMMARY OF LCC AND PBP RESULTS FOR LOW-TEMPERATURE DEDICATED-CONDENSING REFRIGERATION

SYSTEMS—OUTDOOR CONDENSER

TSL 

Energy 

consumption 

kWh/yr 

Mean values 

2013$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Annual 

operating 

cost 

LCC 

Average 

savings 

2013$ 

Customer that experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

1 ............... 18598 9408 2712 31375 6463 0 0 100 1.0 

2 ............... 16396 11484 2560 32218 5942 2 0 98 3.5 

3 ............... 16396 11484 2560 32218 5942 2 0 98 3.5 

TABLE V.14—SUMMARY OF LCC AND PBP RESULTS FOR LOW-TEMPERATURE DEDICATED-CONDENSING REFRIGERATION

SYSTEMS—INDOOR CONDENSER

TSL 

Energy 

consumption 

kWh/yr 

Mean values 

2013$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Annual 

operating 

cost 

LCC 

Average 

savings 

2013$ 

Customer that experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

1 ............... 11958 5452 1974 21483 2157 0 0 100 1.7 

2 ............... 11497 5882 1948 21697 2078 0 0 100 1.6 

3 ............... 11497 5882 1948 21697 2078 0 0 100 1.6 

TABLE V.15—SUMMARY LCC AND PBP RESULTS FOR MEDIUM-TEMPERATURE MULTIPLEX REFRIGERATION SYSTEMS

[Unit coolers only] 

TSL 

Energy 

consumption 

kWh/yr 

Mean values 

2013$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Annual 

operating 

cost 

LCC 

Average 

savings 

2013$ 

Customer that experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

1 ............... 5634 2288 1214 12931 362 0 0 100 3.1 

2 ............... 5634 2288 1214 12931 362 0 0 100 3.1 

3 ............... 5634 2288 1214 12931 362 0 0 100 3.1 

TABLE V.16—SUMMARY LCC AND PBP RESULTS FOR LOW-TEMPERATURE MULTIPLEX REFRIGERATION SYSTEMS

[Unit coolers only] 

TSL 

Energy 

consumption 

kWh/yr 

Mean values 

2013$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Annual 

operating 

cost 

LCC 

Average 

savings 

2013$ 

Customer that experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

1 ............... 9264 2381 1577 16143 598 0 0 100 2.7 

2 ............... 9240 2453 1575 16195 547 0 0 100 3.1 

3 ............... 9240 2453 1575 16195 547 0 0 100 3.1 


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TABLE V.17—SUMMARY LCC AND PBP RESULTS FOR STRUCTURAL AND FLOOR PANELS

[per ft2] 

TSL 

Energy 

consumption 

kWh/yr 

Life-cycle cost 

2013$ 

Life-cycle cost savings 

2013$ 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

Consumers that 

experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

Medium Temperature Structural Panel 

1 ............. 0 15.0 0.2 16.4 — 0 100 0 — 

2 ............. 0 15.0 0.1 16.3 — 0 100 0 — 

3 ............. 0 .5 36.5 0.0 36.9 ¥20.7 100 0 0 238.6 

Low Temperature Structural Panel 

1 ............. 0 15.5 0.6 21.2 — 0 100 0 — 

2 ............. 0 15.5 0.6 20.7 — 0 100 0 — 

3 ............. 2 36.6 0.2 38.4 ¥17.7 100 0 0 58.8 

Low Temperature Floor Panel 

1 ............. 0 15.9 0.6 20.9 — 0 100 0 — 

2 ............. 0 15.9 0.5 20.5 — 0 100 0 — 

3 ............. 2 37.6 0.2 39.0 ¥18.6 100 0 0 64.7 

Note: ‘‘—’’ indicates no impact because all purchases are at or above the given TSL in the base case. 

TABLE V.18—SUMMARY LCC AND PBP RESULTS FOR DISPLAY DOORS

[Per unit, weighted across all sizes] 

TSL 

Energy 

consumption 

kWh/yr 

Life-cycle cost 

2013$ 

Life-cycle cost savings 

2013$ 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

Consumers that 

experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

Medium Temperature Display Door 

1 ............. 572 1,228 62 .8 1,782 460 0 30 69 2.4 

2 ............. 466 1,480 51 .8 1,936 143 41 0 59 7.3 

3 ............. 193 4,270 23 .3 4,476 ¥2,396 100 0 0 39.5 

Low Temperature Display Door 

1 ............. 2142 2,626 235 4,698 976 4 0.00 96 4.2 

2 ............. 1578 3,071 177 4,629 902 10 0.00 90 5.4 

3 ............. 1277 4,331 145 5,611 ¥79 59 0.00 41 9.6 

TABLE V.19—SUMMARY LCC AND PBP RESULTS FOR NON-DISPLAY DOORS

[Per unit, weighted across all sizes] 

TSL 

Energy 

consumption 

kWh/yr 

Life-cycle cost 

2013$ 

Life-cycle cost savings 

2013$ 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

Consumers that 

experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

Medium Temperature Passage Door 

1 ............... 0 868 156 1,827 — 0 100 0 — 

2 ............... 0 868 152 1,803 — 0 100 0 — 

3 ............... 1193 2,299 531 5,315 ¥2000 100 0 0 30.8 

Low Temperature Passage Door 

1 ............... 0 2,053 552 5,449 — 0 100 0 — 


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TABLE V.19—SUMMARY LCC AND PBP RESULTS FOR NON-DISPLAY DOORS—Continued 

[Per unit, weighted across all sizes] 

TSL 

Energy 

consumption 

kWh/yr 

Life-cycle cost 

2013$ 

Life-cycle cost savings 

2013$ 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC Average 

savings 

Consumers that 

experience 

Net cost 

% 

No impact 

% 

Net benefit 

% 

2 ............... 0 2,053 531 5,315 — 0 100 0 — 

3 ............... 4099 4,590 443 7,313 ¥1,998 100 0 0 30.7 

Medium Temperature Freight Door 

1 ............... 0 1,750 230 3,164 — 0 100 0 — 

2 ............... 0 1,750 224 3,126 — 0 100 0 — 

3 ............... 175 4,577 198 5,795 ¥2,668 100 0 0 115.5 

Low Temperature Freight Door 

1 ............... 0 1,945 861 7,239 — 0 100 0 — 

2 ............... 0 1,945 826 7,023 — 0 100 0 — 

3 ............... 6350 4,617 678 8,784 ¥1,761 100 0 0 19.1 

Note: ‘‘—’’ indicates no impact because all purchases are at or above the given TSL in the base case. 

b. Customer Subgroup Analysis 

As described in section IV.I, DOE 

estimated the impact of potential 

amended efficiency standards for walkins for the representative customer 

subgroup: Full-service restaurants. 

Table V.20 and Table V.21 presents 

the comparison of mean LCC savings for 

the subgroup with the values for all 

WICF customers. For all TSLs in all 

equipment classes, the LCC savings for 

this subgroup are not significantly 

different, less than 10 percent higher 

than the national average values. The 

equipment class that shows the most 

substantial change is DD.L, it shows 

decrease in LCC savings, when 

compared to national average values. 

(Chapter 11 of the final rule TSD 

presents the percentage change in LCC 

savings compared to national average 

values.) 

TABLE V.20—SUBGROUP MEAN LIFE-CYCLE COST SAVINGS FOR WICF REFRIGERATION SYSTEMS (2013$) 

Equipment class Group TSL 1 TSL 2 TSL 3 

DC.L.I .............................................................. Full-service Restaurants ................................ 2157 2157 2078 

All Business Types ......................................... 2096 2096 2020 

DC.L.O ............................................................ Full-service Restaurants ................................ 6463 6463 5942 

All Business Types ......................................... 2096 2096 2020 

DC.M.I ............................................................. Full-service Restaurants ................................ 1485 1485 5942 

All Business Types ......................................... 1445 1445 5793 

DC.M.O ........................................................... Full-service Restaurants ................................ 6382 6382 6533 

All Business Types ......................................... 6244 6244 6386 

*Multiplex refrigeration systems are not typically used in small restaurants. 

TABLE V.21—SUBGROUP MEDIAN LIFE-CYCLE COST SAVINGS FOR WICF ENVELOPE COMPONENTS (PANELS AND DOORS) 

(2223$) 

Equipment Class Group TSL1 TSL2 TSL3 

SP.M ............................................................... Full-service Restaurants ................................ — — ¥23 

All Business Types ......................................... — — ¥21 

SP.L ................................................................ Full-service Restaurants ................................ — — ¥20 

All Business Types ......................................... — — ¥18 

FP.L ................................................................. Full-service Restaurants ................................ — — ¥21 

All Business Types ......................................... — — ¥19 

DD.M ............................................................... Full-service Restaurants ................................ 434 107 ¥2612 

All Business Types ......................................... 460 143 ¥2396 

DD.L Full-service Restaurants ................................ 873 761 ¥306 

All Business Types ......................................... 976 902 ¥79 

PD.M Full-service Restaurants ................................ — — — 

All Business Types ......................................... — — — 

PD.L Full-service Restaurants ................................ — — ¥2157 

All Business Types ......................................... — — ¥1998 

FD.M Full-service Restaurants ................................ — l ¥2844 

All Business Types ......................................... — — ¥2668 

FD.L Full-service Restaurants ................................ — — ¥1930 


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TABLE V.21—SUBGROUP MEDIAN LIFE-CYCLE COST SAVINGS FOR WICF ENVELOPE COMPONENTS (PANELS AND DOORS) 

(2223$)—Continued 

Equipment Class Group TSL1 TSL2 TSL3 

All Business Types ......................................... — — ¥1761 

Note: Dashes represent components at baseline efficiency and therefore do not have a payback period. Numbers in parentheses indicate negative values. 

TABLE V.22—SUBGROUP MEDIAN PAYBACK PERIOD FOR WICF REFRIGERATION SYSTEMS (YEARS) 

Equipment class Group TSL1 TSL2 TSL3 

DC.L.I .............................................................. Full-service Restaurants ................................ 1.7 1.7 1.6 

All Business Types ......................................... 1.6 1.6 1.6 

DC.L.O ............................................................ Full-service Restaurants ................................ 1.0 1.0 3.5 

All Business Types ......................................... 1.0 1.0 1.0 

DC.M.I ............................................................. Full-service Restaurants ................................ 2.8 2.8 3.5 

All Business Types ......................................... 2.7 2.7 2.7 

DC.M.O ........................................................... Full-service Restaurants ................................ 1.1 1.1 2.2 

All Business Types ......................................... 1.1 1.1 1.1 

* Multiplex refrigeration systems are not typically used in small restaurants. 

TABLE V.23—SUBGROUP MEDIAN PAYBACK PERIOD FOR WICF ENVELOPE COMPONENTS (PANELS AND DOORS) (YEARS) 

Equipment class Group TSL1 TSL2 TSL3 

SP.M ............................................................... Full-service Restaurants ................................ — — 253.1 

All Business Types ......................................... — — 238.6 

SP,L ................................................................ Full-service Restaurants ................................ — — 62.4 

All Business Types ......................................... — — 58.8 

FP.L ................................................................. Full-service Restaurants ................................ — — 68.7 

All Business Types ......................................... — — 64.7 

DD.M ............................................................... Full-service Restaurants ................................ 2.5 7.3 39.9 

All Business Types ......................................... 2.4 7.3 39.5 

DD.L ................................................................ Full-service Restaurants ................................ 4.3 5.5 9.7 

All Business Types ......................................... 4.2 5.4 9.6 

PD.M ............................................................... Full-service Restaurants ................................ — — — 

All Business Types ......................................... — — — 

PD.L ................................................................ Full-service Restaurants ................................ — — 31.3 

All Business Types ......................................... — — 30.7 

FD.M ............................................................... Full-service Restaurants ................................ — — 117.8 

All Business Types ......................................... — — 115.5 

FD.L ................................................................ Full-service Restaurants ................................ — — 19.5 

All Business Types ......................................... — — 19.1 

Note: Dashes represent components at baseline efficiency and therefore do not have a payback period. 

c. Rebuttable Presumption Payback 

As discussed in section IV.G.12, 

EPCA provides a rebuttable 

presumption that a given standard is 

economically justified if the increased 

purchase cost of equipment that meets 

the standard is less than three times the 

value of the first-year energy savings 

resulting from the standard. However, 

DOE routinely conducts a full economic 

analysis that considers the full range of 

impacts, including those to the 

customer, manufacturer, Nation, and 

environment, as required under 42 

U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 

6316(a). The results of this analysis 

serve as the basis for DOE to evaluate 

definitively the economic justification 

for a potential standard level (thereby 

supporting or rebutting the results of 

any preliminary determination of 

economic justification). Therefore, if the 

rebuttable presumption is not met, DOE 

may justify its standard on another 

basis. Table V.24 shows the rebuttable 

payback periods analysis for each 

equipment class at each TSL. 

TABLE V.24—SUMMARY OF RESULTS

FOR WALK-IN COOLERS AND FREEZERS TSLS: REBUTTABLE PAYBACK

PERIOD

[years] 

Median payback period 

Equipment 

class TSL 1 TSL 2 TSL 3 

DC.L.I ............ 1.7 1.6 1.6 

DC.L.O .......... 1.0 3.4 3.4 

DC.M.I ........... 2.7 3.4 3.4 

DC.M.O ......... 1.1 2.1 2.1 

MC.L ............. 2.7 3.1 3.1 

MC.M ............ 3.1 3.1 3.1 

TABLE V.24—SUMMARY OF RESULTS

FOR WALK-IN COOLERS AND FREEZERS TSLS: REBUTTABLE PAYBACK

PERIOD—Continued 

[years] 

Median payback period 

Equipment 

class TSL 1 TSL 2 TSL 3 

SP.M ............. ............ ............ 234.6 

SP.L .............. ............ ............ 58.4 

FP.L .............. ............ ............ 63.5 

DD.M ............. 2.4 7.5 39.3 

DD.L .............. 4.7 5.4 9.4 

PD.M ............. ............ ............ ................

PD.L .............. ............ ............ 31.0 

FD.M ............. ............ ............ 113.4 

FD.L .............. ............ ............ 19.3 


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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.25 through Table V.27 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.K.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.25 through Table V.27 show 

the MIA results for each TSL using the 

markup scenarios described above for 

WICF panel, door and refrigeration 

manufacturers, respectively. 

TABLE V.25—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF PANELS

Units Base case 

Trial standard level 

1 2 3 

INPV ........................................................................................... 2012 $M ...... 381.94 381.94 381.94 97.41 to 670.62. 

Change in INPV ......................................................................... 2012 $M ...... .................... 0 0 ¥284.53 to 288.68. 

% ................. .................... 0 0 ¥74.49 to 75.58. 

Capital Conversion Costs .......................................................... 2012 $M ...... .................... 0 

....................

0 

....................

162.77. 

Product Conversion Costs ......................................................... 2012 $M ...... .................... 0 0 

....................

35.41. 

Total Investment Required ......................................................... 2012 $M ...... .................... 0 

....................

0 

....................

198.18. 

TABLE V.26—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF DOORS

Units Base case 

Trial standard level 

1 2 3 

INPV ................................................... 2012 $M ...... 484.85 475.67 to 506.50 ....... 457.34 to 545.60 ....... 245.50 to 1233.63. 

Change in INPV ................................. 2012 $M ...... ........................ ¥9.19 to 21.64 ......... ¥27.51 to 60.74 ....... (239.35) to 748.48. 

% ................. ........................ ¥1.89 to 4.46 ........... ¥5.67 to 12.53 ......... (49.37) to 154.43. 

Capital Conversion Costs ................... 2012 $M ...... ........................ 0.04 ........................... 0.15 ........................... 85.99. 

Product Conversion Costs ................. 2012 $M ...... ........................ 0.13 ........................... 0.22 ........................... 14.63. 

Total Investment Required ................. 2012 $M ...... ........................ 0.18 ........................... 0.37 ........................... 100.62. 

TABLE V.27—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF REFRIGERATION SYSTEMS

Units Base case 

Trial standard level 

1 2 3 

INPV ................................................. 2012 $M 424.37 404.15 to 434.60 ....... 398.99 to 443.82 ....... 398.99 to 443.82. 

Change in INPV ............................... 2012 $M ........................ ¥20.22 to 10.24 ....... ¥25.38 to 19.46 ....... ¥25.38 to 19.46. 

(%) ........................ ¥4.76 to 2.41 ........... ¥5.98 to 4.59 ........... ¥5.98 to 4.59. 

Capital Conversion Costs ................ 2012 $M ........................ 13.18 ......................... 14.50 ......................... 14.50. 

Product Conversion Costs ............... 2012 $M ........................ 15.55 ......................... 18.74 ......................... 18.74. 

Total Investment Required ............... 2012 $M ........................ 28.73 ......................... 33.23 ......................... 33.23. 


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Walk-In Cooler and Freezer Panel MIA 

Results 

At all TSLs, the evaluated efficiency 

levels for walk-in panel equipment 

classes are at the baseline level. The 

baseline represents the most common, 

least efficient products that can legally 

be purchased on the market today. To 

meet a baseline standard, walk-in panel 

manufacturers should not have to 

integrate any new technologies or 

design options into existing operations. 

As a result, capital conversion costs and 

product conversion costs are expected 

to be zero. At TSL 1 and TSL 2, INPV 

remains the same as in the base case. 

There is no change from the base case 

value of $381.94 million. 

For TSL 3, DOE models the change in 

INPV for panels to range from ¥$284.53 

million to $288.68 million, or a change 

in INPV of ¥74.49 percent to 75.58 

percent. At this standard level, door 

industry free cash flow is estimated to 

decrease by as much as $74.45 million, 

or ¥226.84 percent compared to the 

base case value of $37.49 million in the 

year before the compliance date. 

Walk-In Cooler and Freezer Door MIA 

Results 

For TSL 1, DOE models the change in 

INPV for doors to range from ¥$9.19 

million to $21.64 million, or a change in 

INPV of ¥1.89 percent to 4.46 percent. 

At this standard level, door industry 

free cash flow is estimated to decrease 

by as much as $0.06 million, or ¥0.15 

percent compared to the base case value 

of $37.49 million in the year before the 

compliance date. 

At TSL 2, DOE estimates the impacts 

on door INPV to range from ¥$27.51 

million to $60.74 million, or a change in 

INPV of ¥5.67 percent to 12.53 percent. 

At this level, door industry free cash 

flow is estimated to decrease by $0.13 

million in the year before the 

compliance year, or ¥0.33 percent 

compared to the base case value of 

$37.49 million in the year before the 

compliance date. 

At TSL 3, DOE estimates the impacts 

on door INPV to range from ¥239.95 to 

748.48, or a change in INPV of ¥49.37 

percent to 154.43 percent. At this level, 

door industry free cash flow is 

estimated to decrease by as much as 

38.66 million in the year before the 

compliance year, or ¥103.13 percent 

compared to the base case value of 

$37.49 million in the year before the 

compliance date. 

Walk-in Cooler and Freezer 

Refrigeration MIA Results 

At TSL 1, DOE estimates impacts on 

refrigeration INPV to range from 

¥$20.22 million to $10.24 million, or a 

change in INPV of ¥4.76 percent to 2.41 

percent. At this level, refrigeration 

industry free cash flow is estimated to 

decrease by as much as $9.53 million, 

or ¥26.47 percent compared to the 

base-case value of $36.02 million in 

2016, the year before the compliance 

year. 

At TSL 2 and TSL 3, DOE estimates 

impacts on refrigeration INPV to range 

from ¥$25.38 million to $19.46 million, 

or a change in INPV of ¥5.98 percent 

to 4.59 percent. At this level, 

refrigeration industry free cash flow is 

estimated to decrease by as much as 

$10.93 million, or ¥30.35 percent 

compared to the base-case value of 

$36.02 million in the year before the 

compliance date. 

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 2,878 

domestic production workers for walkin panels, 1,302 domestic production 

workers for walk-in doors, and 415 

domestic production workers for walkin refrigeration systems in 2017. 

Table V.28, Table V.29, and Table 

V.30 show the range of the impacts of 

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.28—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR PANELS

TSL 1 2 3 

Potential Changes in Domestic Production Workers 2017 ...............................................................................

(from a base case employment of 2,878) .........................................................................................................

0 to 0 ... 0 to 0 ... ¥863 to 738 


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TABLE V.29—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR DOORS

TSL 1 2 3 

Potential Changes in Domestic Production Workers 2017 ...............................................................................

(from a base case employment of 1,318) .........................................................................................................

0 to 101 0 to 200 ¥132 to 

1,979 

TABLE V.30—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR

REFRIGERATION SYSTEMS

TSL 1 2 3 

Potential Changes in Domestic Production Workers 2017 ...............................................................................

(from a base case employment of 424) ............................................................................................................

¥64 to 

56.

¥161 

to 88.

¥161 to 88 

The employment impacts shown in 

Table V.28 through Table V.30 represent 

the potential production employment 

changes that could result following the 

compliance date of these 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. Please note that 

DOE does not propose any increase in 

energy conservation standards for Walkin Panels, medium and low temperature 

solid doors, therefore there would likely 

be no significant change in employment 

in these industries. 

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. A standard that 

necessitates 6-inch thick 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. 

Given that the only efficiency level 

considered for panels in this rule is 

baseline, DOE does not anticipate any 

changes in production techniques or 

new capacity constraints resulting from 

this rulemaking. 

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. 

Similar to panels, DOE is only 

considering the baseline efficiency level 

for passage and freight doors. The 

Department does not expect capacity 

challenges for the production of solid 

doors as a result of this rule. 

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 two 

refrigeration system manufacturers, 

forty-two panel manufacturers, and five 

door manufacturers in the WICF 

industry that are small businesses. DOE 

describes the differential impacts on 

these small businesses in this rule at 

section VI.B, Review Under the 

Regulatory Flexibility Act. 

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 


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the same manufacturer can strain profits 

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 final rule 

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 and cannot include the costs 

of this rulemaking in its cumulative 

analysis because the rulemaking is not 

yet complete and no cost estimates are 

available. 

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 equipment 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. Energy Savings 

DOE estimated the NES by calculating 

the difference in annual energy 

consumption for the base-case scenario 

and standards-case scenario at each TSL 

for each equipment class and summing 

up the annual energy savings over the 

lifetime of all equipment purchased in 

2017–2046. 

Table V.31 presents the primary NES 

(taking into account losses in the 

generation and transmission of 

electricity) for all equipment classes and 

the sum total of NES for each TSL. Table 

V.32 presents estimated FFC energy 

savings for each considered TSL. The 

total FFC NES progressively increases 

from 2.506 quads at TSL 1 to 3.883 

quads at TSL 3. 

TABLE V.31—CUMULATIVE NATIONAL

PRIMARY ENERGY SAVINGS IN QUADS

TSL 1 TSL 2 TSL 3 

DC.L.I ............ 0.030 0.035 0.035 

DC.L.O .......... 0.832 1.077 1.077 

DC.M.I ........... 0.069 0.069 0.069 

DC.M.O ......... 1.028 1.279 1.279 

MC.L.N .......... 0.016 0.016 0.016 

MC.M ............ 0.046 0.046 0.046 

SP.M ............. 0.000 0.000 0.044 

SP.L .............. 0.000 0.000 0.064 

FP.L .............. 0.000 0.000 0.017 

DD.M ............. 0.329 0.423 0.643 

DD.L .............. 0.116 0.154 0.174 

PD.M ............. 0.000 0.000 0.076 

PD.L .............. 0.000 0.000 0.245 

FD.M ............. 0.000 0.000 0.009 


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32110 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

38Section 325(m) of EPCA requires DOE to review 

its standards at least once every 6 years, and 

requires, for certain products, a 3-year period after 

any new standard is promulgated before 

compliance is required, except that in no case may 

any new standards be required within 6 years of the 

compliance date of the previous standards. While 

adding a 6-year review to the 3-year compliance 

period adds to 9 years, DOE notes that it may 

undertake reviews at any time within the 6-year 

period, and that the 3 year compliance date may 

yield to the 6-year backstop. A 9-year analysis 

period may not be appropriate given the variability 

that occurs in the timing of standards reviews and 

the fact that, for some consumer products, the 

compliance period is 5 years rather than 3 years. 

TABLE V.31—CUMULATIVE NATIONAL

PRIMARY ENERGY SAVINGS IN

QUADS—Continued 

TSL 1 TSL 2 TSL 3 

FD.L .............. 0.000 0.000 0.027 

Total .......... 2.466 3.099 3.821 

* For DC refrigeration systems, results include all capacity ranges. 

TABLE V.32—CUMULATIVE NATIONAL

FULL-FUEL CYCLE ENERGY SAVINGS

IN QUADS

TSL 1 TSL 2 TSL 3 

DC.L.I ............ 0.031 0.036 0.036 

DC.L.O .......... 0.846 1.094 1.094 

DC.M.I ........... 0.070 0.070 0.070 

DC.M.O ......... 1.045 1.300 1.300 

MC.L.N .......... 0.016 0.017 0.017 

MC.M ............ 0.046 0.046 0.046 

SP.M ............. 0.000 0.000 0.045 

SP.L .............. 0.000 0.000 0.065 

FP.L .............. 0.000 0.000 0.018 

DD.M ............. 0.334 0.429 0.653 

DD.L .............. 0.118 0.157 0.177 

PD.M ............. 0.000 0.000 0.077 

PD.L .............. 0.000 0.000 0.249 

FD.M ............. 0.000 0.000 0.009 

FD.L .............. 0.000 0.000 0.027 

Total .......... 2.506 3.149 3.883 

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 equipment 

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.38 The review 

timeframe established in EPCA is 

generally not synchronized with the 

equipment lifetime, equipment 

manufacturing cycles or other factors 

specific to walk-in coolers and walk-in 

freezers. Thus, this information is 

presented for informational purposes 

only and is not indicative of any change 

in DOE’s analytical methodology. The 

primary and full-fuel cycle NES results 

based on a 9-year analysis period are 

presented in Table V.33 and Table V.34, 

respectively. The impacts are counted 

over the lifetime of equipment 

purchased in 2017–2025. 

TABLE V.33—CUMULATIVE NATIONAL

PRIMARY ENERGY SAVINGS FOR 9- 

YEAR ANALYSIS PERIOD

[Equipment purchased in 2017–2025] 

TSL 1 TSL 2 TSL 3 

DC.L.I ............ 0.0 0.0 0.0 

DC.L.O .......... 0.2 0.3 0.3 

DC.M.I ........... 0.0 0.0 0.0 

DC.M.O ......... 0.3 0.3 0.3 

MC.L.N .......... 0.0 0.0 0.0 

MC.M ............ 0.0 0.0 0.0 

SP.M ............. 0.0 0.0 0.0 

SP.L .............. 0.0 0.0 0.0 

FP.L .............. 0.0 0.0 0.0 

DD.M ............. 0.1 0.1 0.2 

DD.L .............. 0.0 0.0 0.1 

PD.M ............. 0.0 0.0 0.0 

PD.L .............. 0.0 0.0 0.1 

FD.M ............. 0.0 0.0 0.0 

FD.L .............. 0.0 0.0 0.0 

Total .......... 0.6 0.8 1.1 

TABLE V.34—CUMULATIVE FULL FUEL

CYCLE NATIONAL ENERGY SAVINGS

FOR 9-YEAR ANALYSIS PERIOD

[Equipment purchased in 2017–2025] 

TSL 1 TSL 2 TSL 3 

DC.L.I ............ 0.0 0.0 0.0 

DC.L.O .......... 0.2 0.3 0.3 

DC.M.I ........... 0.0 0.0 0.0 

DC.M.O ......... 0.3 0.3 0.3 

MC.L.N .......... 0.0 0.0 0.0 

MC.M ............ 0.0 0.0 0.0 

SP.M ............. 0.0 0.0 0.0 

SP.L .............. 0.0 0.0 0.0 

FP.L .............. 0.0 0.0 0.0 

DD.M ............. 0.1 0.1 0.2 

DD.L .............. 0.0 0.0 0.1 

PD.M ............. 0.0 0.0 0.0 

PD.L .............. 0.0 0.0 0.1 

FD.M ............. 0.0 0.0 0.0 

FD.L .............. 0.0 0.0 0.0 

Total .......... 0.7 0.8 1.1 

b. Net Present Value of Customer Costs 

and Benefits 

DOE estimated the cumulative NPV to 

the Nation of the net savings for WICF 

customers that would result from 

potential standards at each TSL. In 

accordance with OMB guidelines on 

regulatory analysis (OMB Circular A–4, 

section E, September 17, 2003), DOE 

calculated NPV using both a 7-percent 

and a 3-percent real discount rate. 

Table V.35 and Table V.36 show the 

customer NPV results for each of the 

TSLs DOE considered for walk-in 

coolers and walk-in freezers at 7-percent 

and 3-percent discount rates, 

respectively. The impacts cover the 

expected lifetime of equipment 

purchased in 2017–2046. 

Efficiency levels for TSL 3 were 

chosen to represent the maximum 

technology for both refrigeration 

equipment, and envelope components, 

as such the NPV results at a 7-percent 

discount rate are mixed, they are 

negative for all envelope component 

equipment classes, while positive for 

refrigeration systems. TSL 2 was chosen 

to correspond to the highest efficiency 

level with a positive NPV at a 7-percent 

discount rate for each equipment class. 

The criterion for TSL 1 was to select 

efficiency levels with the highest NPV at 

a 7-percent discount rate. Consequently, 

the total NPV is highest for TSL 1. TSL 

2 shows the second highest total NPV at 

a 7-percent discount rate. 

TABLE V.35—NET PRESENT VALUE IN

BILLIONS (2013$) AT A 7-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN

2017–2046 

TSL 1 TSL 2 TSL 3 

DC.L.I ............ 0.1 0.1 0.1 

DC.L.O .......... 2.2 1.0 1.0 

DC.M.I ........... 0.1 0.1 0.1 

DC.M.O ......... 2.8 2.5 2.5 

MC.L.N .......... 0.0 0.0 0.0 

MC.M ............ 0.1 0.1 0.1 

SP.M ............. 0.0 0.0 ¥18.9 

SP.L .............. 0.0 0.0 ¥6.6 

FP.L .............. 0.0 0.0 ¥2.0 

DD.M ............. 0.7 0.0 ¥10.0 

DD.L .............. 0.1 0.1 ¥0.2 

PD.M ............. 0.0 0.0 ¥5.1 

PD.L .............. 0.0 0.0 ¥4.1 

FD.M ............. 0.0 0.0 ¥0.6 

FD.L .............. 0.0 0.0 ¥0.2 

Total .......... 6.24 3.98 ¥43.92 

* For DC refrigeration systems, results include all capacity ranges. 

TABLE V.36—NET PRESENT VALUE IN

BILLIONS (2013$) AT A 3-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN

2017–2046 

TSL 1 TSL 2 TSL 3 

DC.L.I ............ 0.2 0.1 0.1 

DC.L.O .......... 4.8 2.8 2.8 

DC.M.I ........... 0.3 0.3 0.3 

DC.M.O ......... 5.9 5.5 5.5 

MC.L.N .......... 0.1 0.1 0.1 

MC.M ............ 0.2 0.2 0.2 

SP.M ............. 0.0 0.0 ¥33.2 

SP.L .............. 0.0 0.0 ¥11.6 


tkelley on DSK3SPTVN1PROD with RULES2
Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 32111 

TABLE V.36—NET PRESENT VALUE IN

BILLIONS (2013$) AT A 3-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN

2017–2046—Continued 

TSL 1 TSL 2 TSL 3 

FP.L .............. 0.0 0.0 ¥3.5 

DD.M ............. 1.6 0.5 ¥17.1 

DD.L .............. 0.3 0.3 ¥0.2 

PD.M ............. 0.0 0.0 ¥8.9 

PD.L .............. 0.0 0.0 ¥7.0 

FD.M ............. 0.0 0.0 ¥1.1 

FD.L .............. 0.0 0.0 ¥0.4 

Total .......... 13.38 9.90 ¥73.93 

* For DC refrigeration systems, results include all capacity ranges. 

The NPV results based on the 

aforementioned 9-year analysis period 

are presented in Table V.37 and Table 

V.38. The impacts are counted over the 

lifetime of equipment 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.37 —NET PRESENT VALUE IN

MILLIONS (2013$) AT A 7-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN

2017–2025 

TSL 1 TSL 2 TSL 3 

DC.L.I ................ 0.0 0.0 0.0 

DC.L.O .............. 1.0 0.4 0.4 

DC.M.I ............... 0.1 0.1 0.1 

DC.M.O ............. 1.3 1.1 1.1 

MC.L.N .............. 0.0 0.0 0.0 

MC.M ................ 0.0 0.0 0.0 

SP.M ................. 0.0 0.0 ¥9.1 

SP.L .................. 0.0 0.0 ¥3.2 

FP.L .................. 0.0 0.0 ¥1.0 

DD.M ................. 0.2 ¥0.1 ¥5.1 

DD.L .................. 0.0 0.0 ¥0.2 

PD.M ................. 0.0 0.0 ¥2.5 

PD.L .................. 0.0 0.0 ¥2.0 

FD.M ................. 0.0 0.0 ¥0.3 

FD.L .................. 0.0 0.0 ¥0.1 

Total .............. 2.7 1.6 ¥21.7 

TABLE V.38—NET PRESENT VALUE IN

MILLIONS (2013$) AT A 3-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN

2017–2025 

TSL 1 TSL 2 TSL 3 

DC.L.I ............ 0.0 0.0 0.0 

DC.L.O .......... 1.5 0.8 0.8 

DC.M.I ........... 0.1 0.1 0.1 

DC.M.O ......... 2.0 1.8 1.8 

MC.L.N .......... 0.0 0.0 0.0 

MC.M ............ 0.1 0.1 0.1 

SP.M ............. 0.0 0.0 ¥11.7 

SP.L .............. 0.0 0.0 ¥4.0 

FP.L .............. 0.0 0.0 ¥1.2 

TABLE V.38—NET PRESENT VALUE IN

MILLIONS (2013$) AT A 3-PERCENT

DISCOUNT RATE FOR UNITS SOLD IN

2017–2025—Continued 

TSL 1 TSL 2 TSL 3 

DD.M ............. 0.5 0.1 ¥6.2 

DD.L .............. 0.1 0.1 ¥0.1 

PD.M ............. 0.0 0.0 ¥3.1 

PD.L .............. 0.0 0.0 ¥2.5 

FD.M ............. 0.0 0.0 ¥0.4 

FD.L .............. 0.0 0.0 ¥0.2 

Total .......... 4.4 3.0 ¥26.5 

c. Indirect Employment Impacts 

In addition to the direct impacts on 

manufacturing employment discussed 

in section V.B.2, DOE develops general 

estimates of the indirect employment 

impacts of amended standards on the 

economy. As discussed above, DOE 

expects energy amended conservation 

standards for walk-in coolers and walkin freezers to reduce energy bills for 

commercial customers, and the resulting 

net savings to be redirected to other 

forms of economic activity. DOE also 

realizes that these shifts in spending 

and economic activity by walk-in 

owners could affect the demand for 

labor. Thus, indirect employment 

impacts may result from expenditures 

shifting between goods (the substitution 

effect) and changes in income and 

overall expenditure levels (the income 

effect) that occur due to the imposition 

of amended standards. These impacts 

may affect a variety of businesses not 

directly involved in the decision to 

make, operate, or pay the utility bills for 

walk-in coolers and walk-in freezers. To 

estimate these indirect economic effects, 

DOE used an input/output model of the 

U.S. economy as described in section 

IV.K of this notice. 

Customers who purchase moreefficient equipment pay lower amounts 

towards utility bills, which results in 

job losses in the electric utilities sector. 

However, in the input/output model, 

the dollars saved on utility bills are reinvested in economic sectors that create 

more jobs than are lost in the electric 

utilities sector. Thus, the amended 

energy conservation standards for walkin coolers and walk-in freezers are likely 

to slightly increase the net demand for 

labor in the economy. As shown in 

chapter 16 of the final rule TSD, DOE 

estimates that net indirect employment 

impacts from amended walk-in 

standards are very small relative to the 

national economy. 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 includes the 

quality of jobs. 

4. Impact on Utility or Performance of 

Equipment 

In performing the engineering 

analysis, DOE considers design options 

that would not lessen the utility or 

performance of the individual classes of 

equipment. (42 U.S.C. 

6295(o)(2)(B)(i)(IV) and 6316(a)) As 

presented in the screening analysis 

(chapter 4 of the final rule TSD), DOE 

eliminates from consideration any 

design options that reduce the utility of 

the equipment. For this final rule, DOE 

concluded that none of the efficiency 

levels considered for walk-in coolers 

and walk-in freezers would reduce the 

utility or performance of the equipment. 

5. Impact of Any Lessening of 

Competition 

EPCA directs DOE to consider any 

lessening of competition that is likely to 

result from standards. It also directs the 

Attorney General of the United States 

(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 direct final 

rule and simultaneously published 

proposed rule, together with an analysis 

of the nature and extent of the impact. 

(42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) 

To assist the Attorney General in 

making a determination for WICF 

standards, DOE provided the 

Department of Justice (DOJ) with copies 

of the NOPR and the TSD for review. On 

behalf of the Attorney General, the 

DOJ’s Antitrust Division concluded that 

the standard levels proposed by DOE 

(which are the same ones being adopted 

in this final rule) would not be likely to 

have an adverse impact on competition. 

6. Need of the Nation To Conserve 

Energy 

An improvement in the energy 

efficiency of the equipment subject to 

this final 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 final rule TSD. 

Energy savings from amended 

standards for walk-in coolers and walkin freezers could also produce 

environmental benefits in the form of 

reduced emissions of air pollutants and 

GHGs associated with electricity 

production. 


tkelley on DSK3SPTVN1PROD with RULES2
32112 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

Table V.72 provides DOE’s estimate of 

cumulative emissions reductions 

projected to result from the TSLs 

considered in this rule. The table 

includes both power sector emissions 

and upstream emissions. DOE reports 

annual emissions reductions for each 

TSL in chapter 13 of the final rule TSD. 

TABLE V.39—CUMULATIVE EMISSIONS REDUCTION ESTIMATED FOR WALK-IN COOLERS AND WALK-IN FREEZERS TSLS

FOR EQUIPMENT PURCHASED IN 2017–2046 

TSL 

1 2 3 

Power Sector Emissions 

CO2 (million metric tons) ......................................................................................................................... 118.9 149.5 184.0 

SO2 (thousand tons) ................................................................................................................................ 180.7 227.1 279.8 

NOX (thousand tons) ............................................................................................................................... 95.9 120.5 149.3 

Hg (tons) .................................................................................................................................................. 0.2 0.3 0.3 

N2O (thousand tons) ................................................................................................................................ 2.7 3.4 4.2 

CH4 (thousand tons) ................................................................................................................................ 16.1 20.3 25.0 

Upstream Emissions 

CO2 (million metric tons) ......................................................................................................................... 7.7 9.7 12.0 

SO2 (thousand tons) ................................................................................................................................ 1.7 2.1 2.6 

NOX (thousand tons) ............................................................................................................................... 106.6 133.9 165.1 

Hg (tons) .................................................................................................................................................. 0.0 0.0 0.0 

N2O (thousand tons) ................................................................................................................................ 0.1 0.1 0.1 

CH4 (thousand tons) ................................................................................................................................ 646.7 812.8 1001.8 

Total FFC Emissions 

CO2 (million metric tons) ......................................................................................................................... 126.7 159.2 196.0 

SO2 (thousand tons) ................................................................................................................................ 182.4 229.2 282.4 

NOX (thousand tons) ............................................................................................................................... 202.5 254.4 314.4 

Hg (tons) .................................................................................................................................................. 0.2 0.3 0.3 

N2O (thousand tons) ................................................................................................................................ 2.8 3.5 4.4 

CH4 (thousand tons) ................................................................................................................................ 662.9 833.0 1026.8 

As part of the analysis for this final 

rule, DOE estimated monetary benefits 

likely to result from the reduced 

emissions of CO2 and NOX that were 

estimated for each of the TSLs 

considered. As discussed in section 

IV.M, for CO2, DOE used values for the 

SCC developed by a Federal 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 

estimate across all three models at a 3- 

percent discount rate, is included to 

represent higher-than-expected impacts 

from temperature change further out in 

the tails of the SCC distribution. The 

four SCC values for CO2 emissions 

reductions in 2015, expressed in 2013$, 

are $12.0, $40.5, $62.4, and $119 per 

metric ton of CO2. The values for later 

years are higher due to increasing 

emissions-related costs as the 

magnitude of projected climate change 

increases. 

Table V.40 presents the global value 

of CO2 emissions reductions at each 

TSL. DOE calculated domestic values as 

a range from 7 percent to 23 percent of 

the global values, and these results are 

presented in chapter 14 of the final rule 

TSD. 

TABLE V.40—GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION FOR WALK-IN COOLERS AND FREEZERS TSLS

TSL 

SCC Scenario 

5% discount 

rate, average 

3% discount 

rate, average 

2.5% discount 

rate, average 

3% discount 

rate, 95th 

percentile 

million 2013$ 

Power Sector Emissions 

1 ....................................................................................................................... 894 3965 6255 12221 

2 ....................................................................................................................... 1124 4983 7861 15358 

3 ....................................................................................................................... 1379 6119 9655 18856 

Upstream Emissions 

1 ....................................................................................................................... 56 252 399 778 

2 ....................................................................................................................... 70 316 501 977 

3 ....................................................................................................................... 86 389 616 1201 


tkelley on DSK3SPTVN1PROD with RULES2
Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 32113 

TABLE V.40—GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION FOR WALK-IN COOLERS AND FREEZERS TSLS— 

Continued 

TSL 

SCC Scenario 

5% discount 

rate, average 

3% discount 

rate, average 

2.5% discount 

rate, average 

3% discount 

rate, 95th 

percentile 

Total FFC Emissions 

1 ....................................................................................................................... 950 4217 6654 12999 

2 ....................................................................................................................... 1194 5299 8362 16336 

3 ....................................................................................................................... 1464 6507 10271 20057 

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 final rule 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, including HFCs. This 

ongoing review will consider the 

comments on this subject that are part 

of the public record for this final rule 

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 final rule the most recent values 

and analyses resulting from the ongoing 

interagency review process. 

DOE also estimated a range for the 

cumulative monetary value of the 

economic benefits associated with NOX

emission reductions anticipated to 

result from amended walk-in standards. 

Table V.42 shows the present value of 

cumulative NOX emissions reductions 

for each TSL calculated using the 

average dollar-per-ton values and 7- 

percent and 3-percent discount rates. 

TABLE V.41—CUMULATIVE PRESENT

VALUE OF NOX EMISSIONS REDUCTION FOR WALK-IN COOLERS AND

FREEZERS TSLS

TSL 3% discount 

rate 

7% discount 

rate 

Million 2013$ 

Power Sector Emissions 

1 ........................ 138.1 70.0 

2 ........................ 173.5 88.0 

3 ........................ 213.6 108.3 

Upstream Emissions 

1 ........................ 153.3 76.0 

2 ........................ 192.6 95.5 

3 ........................ 236.3 117.2 

Total FFC Emissions 

1 ........................ 291.3 146.0 

TABLE V.41—CUMULATIVE PRESENT

VALUE OF NOX EMISSIONS REDUCTION FOR WALK-IN COOLERS AND

FREEZERS TSLS—Continued 

TSL 3% discount 

rate 

7% discount 

rate 

2 ........................ 366.1 183.5 

3 ........................ 450.0 225.5 

7. Summary of National Economic 

Impact 

The NPV of the monetized benefits 

associated with emission reductions can 

be viewed as a complement to the NPV 

of the customer savings calculated for 

each TSL considered in this final rule. 

Table V.42 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 customer savings calculated 

for each TSL, at both a 7-percent and a 

3-percent discount rate. The CO2 values 

used in the table correspond to the four 

scenarios for the valuation of CO2

emission reductions discussed above. 

TABLE V.42—NET PRESENT VALUE OF CUSTOMER SAVINGS COMBINED WITH NET PRESENT VALUE OF MONETIZED

BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS

TSL 

SCC Value of 

$12.0/metric 

ton CO2 * and 

medium value 

for NOX

SCC Value of 

$40.5/metric 

ton CO2 * and 

medium value 

for NOX

SCC Value of 

$62.4/metric 

ton CO2 * and 

medium value 

for NOX

SCC Value of 

$119/metric 

ton CO2 * and 

medium value 

for NOX

Customer NPV at 3% Discount Rate added with Value of Emissions Based on: 

billion 2013$ 

1 ....................................................................................................................... 14.7 18.2 20.8 27.6 

2 ....................................................................................................................... 11.5 15.9 19.3 27.8 

3 ....................................................................................................................... ¥71.9 ¥66.5 ¥62.4 ¥51.9 

Customer NPV at 7% Discount Rate added with Value of Emissions Based on: 

billion 2013$ 

1 ....................................................................................................................... 7.4 10.9 13.5 20.3 

2 ....................................................................................................................... 5.4 9.8 13.2 21.7 

3 ....................................................................................................................... ¥42.1 ¥36.7 ¥32.6 ¥22.1 

* These label values represent the global SCC in 2015, in 2013$. The present values have been calculated with scenario-consistent discount 

rates. 


tkelley on DSK3SPTVN1PROD with RULES2
32114 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

Although adding the value of 

customer savings to the values of 

emission reductions provides a valuable 

perspective, two issues should be 

considered. First, the national operating 

cost savings are domestic U.S. customer 

monetary savings that occur as a result 

of market transactions, while the value 

of CO2 reductions is based on a global 

value. Second, the assessments of 

operating cost savings and the SCC are 

performed with different methods that 

use quite different time frames for 

analysis. The national operating cost 

savings is measured for the lifetime of 

equipment shipped in 2017–2046. The 

SCC values, on the other hand, reflect 

the present value of future climaterelated impacts resulting from the 

emission of one metric ton of CO2 in 

each year. These impacts continue well 

beyond 2100. 

8. 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. (42 U.S.C. 

6295(o)(2)(B)(i)(VII) and 6316(a)) DOE 

has not considered other factors in 

development of the standards in this 

final rule. 

C. Conclusions 

Any new or amended energy 

conservation standard for any type (or 

class) of covered product must be 

designed to achieve the maximum 

improvement in energy efficiency that 

the Secretary determines is 

technologically feasible and 

economically justified. (42 U.S.C. 

6295(o)(2)(A) and 6316(a)) In 

determining 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 a significant 

conservation of energy. (42 U.S.C. 

6295(o)(3)(B) and 6316(a)) 

For this rulemaking, DOE considered 

the impacts of potential 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. 

To aid the reader in understanding 

the benefits and/or burdens of each TSL, 

tables in this section summarize the 

quantitative analytical results for each 

TSL, based on the assumptions and 

methodology discussed herein. The 

efficiency levels contained in each TSL 

are described in section V.A. In addition 

to the quantitative results presented in 

the tables below, DOE also considers 

other burdens and benefits that affect 

economic justification. These include 

the impacts on identifiable subgroups of 

consumers who may be 

disproportionately affected by a national 

standard, and impacts on employment. 

Section V.B.1.b presents the estimated 

impacts of each TSL for the considered 

subgroups. DOE discusses the impacts 

on employment in WICF manufacturing 

in section V.B.2.b and discusses the 

indirect employment impacts in section 

IV.O. 

1. Benefits and Burdens of Trial 

Standard Levels Considered for Walk-in 

Coolers and Walk-In Freezers 

Table V.43 through Table V.46 

summarize the quantitative impacts 

estimated for each TSL for WICFs. 

TABLE V.43—SUMMARY OF RESULTS FOR WALK-IN COOLERS AND FREEZERS

Category TSL 1 TSL 2 TSL 3 

Cumulative National Energy Savings 

quads 

Primary ..................................................................................................... 2.466 ......................... 3.099 ......................... 3.821 

Full-fuel cycle ........................................................................................... 2.506 ......................... 3.149 ......................... 3.883 

Cumulative NPV of Customer Benefits 

2013$ billion 

3% discount rate ...................................................................................... 13.38 ......................... 9.90 ........................... ¥73.93 

7% discount rate ...................................................................................... 6.24 ........................... 3.98 ........................... ¥43.92 

Industry Impacts 

Change in Industry NPV (2013$ million) ................................................. ¥29.41 to 31.88 ....... ¥52.89 to 80.20 ....... ¥549.26 to 1056.92 

Change in Industry NPV (%) ................................................................... ¥2.28 to 2.47 ........... ¥4.1 to 6.21 ............. ¥42.54 to 81.86 

Cumulative Emissions Reductions ** 

CO2 (Mt) ................................................................................................... 126.7 ......................... 159.2 ......................... 196.0 

SO2 (kt) .................................................................................................... 182.4 ......................... 229.2 ......................... 282.4 

NOX (kt) ................................................................................................... 202.5 ......................... 254.4 ......................... 314.4 

Hg (t) ........................................................................................................ 0.22 ........................... 0.27 ........................... 0.34 

N2O (kt) .................................................................................................... 2.8 ............................. 3.5 ............................. 4.4 

N2O (kt CO2eq) ........................................................................................ 662.9 ......................... 833.0 ......................... 1026.8 

CH4 (kt) .................................................................................................... 126.7 ......................... 159.2 ......................... 196.0 

CH4 (kt CO2eq) ........................................................................................ 182.4 ......................... 229.2 ......................... 282.4 

Monetary Value of Cumulative Emissions Reductions 

2013$ million † 

CO2 .......................................................................................................... 949.7 to 12,999 ......... 1,193.5 to 16336 ....... 1,464.4 to 20,0576 

NOX—3% discount rate ........................................................................... 291.3 ......................... 366.1 ......................... 450.0 


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TABLE V.43—SUMMARY OF RESULTS FOR WALK-IN COOLERS AND FREEZERS—Continued 

Category TSL 1 TSL 2 TSL 3 

NOX—7% discount rate ........................................................................... 146.0 ......................... 183.5 ......................... 225.5 

** ‘‘Mt’’ stands for million metric tons; ‘‘kt’’ stands for kilotons; ‘‘t’’ stands for tons. CO2eq is the quantity of CO2 that would have the same global 

warming potential (GWP). 

† Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. 

TABLE V.44—SUMMARY OF RESULTS FOR WALK-IN COOLERS AND FREEZERS TSLS: MEAN LCC SAVINGS

Mean LCC Savings * 

2013$ 

Equipment class TSL 1 TSL 2 TSL 3 

DC.L.I ....................................................................................................................................................... 2157 2078 2078 

DC.L.O ..................................................................................................................................................... 6463 5942 5942 

DC.M.I ...................................................................................................................................................... 1485 5942 5942 

DC.M.O .................................................................................................................................................... 6382 6533 6533 

MC.L ........................................................................................................................................................ 598 547 547 

MC.M ....................................................................................................................................................... 362 362 362 

SP.M ........................................................................................................................................................ — — ¥21 

SP.L ......................................................................................................................................................... — — ¥18 

FP.L ......................................................................................................................................................... — — ¥19 

DD.M ........................................................................................................................................................ 460 143 ¥2396 

DD.L ......................................................................................................................................................... 976 902 ¥79 

PD.M ........................................................................................................................................................ — — ¥2000 

PD.L ......................................................................................................................................................... — — ¥1998 

FD.M ........................................................................................................................................................ — — ¥2668 

FD.L ......................................................................................................................................................... — — ¥1761 

* ‘‘—’’ indicates no impact because there is no change in the standards. 

TABLE V.45—SUMMARY OF RESULTS

FOR WALK-IN COOLERS AND FREEZERS TSLS: MEDIAN PAYBACK PERIOD

Median payback period * 

(in years) 

Equipment 

class TSL 1 TSL 2 TSL 3 

DC.L.I ............ 1.7 1.6 1.6 

DC.L.O .......... 1.0 3.5 3.5 

DC.M.I ........... 2.8 3.5 3.5 

DC.M.O ......... 1.1 2.2 2.2 

MC.L ............. 2.7 3.1 3.1 

MC.M ............ 3.1 3.1 3.1 

TABLE V.45—SUMMARY OF RESULTS

FOR WALK-IN COOLERS AND FREEZERS TSLS: MEDIAN PAYBACK PERIOD—Continued 

Median payback period * 

(in years) 

Equipment 

class TSL 1 TSL 2 TSL 3 

SP.M ............. — — 238.6 

SP.L .............. — — 58.8 

FP.L .............. — — 64.7 

DD.M ............. 2.4 7.3 39.5 

DD.L .............. 4.2 5.4 9.6 

PD.M ............. — — 30.8 

TABLE V.45—SUMMARY OF RESULTS

FOR WALK-IN COOLERS AND FREEZERS TSLS: MEDIAN PAYBACK PERIOD—Continued 

Median payback period * 

(in years) 

Equipment 

class TSL 1 TSL 2 TSL 3 

PD.L .............. — — 30.7 

FD.M ............. — — 115.5 

FD.L .............. — — 19.1 

* ‘‘—’’ indicates no impact because there is 

no change in the standards. 

TABLE V.46—SUMMARY OF RESULTS FOR WALK-IN COOLERS AND FREEZERS TSLS: DISTRIBUTION OF CUSTOMER LCC 

IMPACTS

Equipment class TSL 1 * TSL 2 * TSL 3 * 

DC.L.I: 

Net Cost (%) ..................................................................................................................................... 0 0 0 

No Impact (%) .................................................................................................................................. 0 0 0 

Net Benefit (%) ................................................................................................................................. 100 100 100 

DC.L.O: 

Net Cost (%) ..................................................................................................................................... 0 2 2 

No Impact (%) .................................................................................................................................. 0 0 0 

Net Benefit (%) ................................................................................................................................. 100 98 98 

DC.M.I: 

Net Cost (%) ..................................................................................................................................... 0 2 2 

No Impact (%) .................................................................................................................................. 0 0 0 

Net Benefit (%) ................................................................................................................................. 100 98 98 

DC.M.O: 

Net Cost (%) ..................................................................................................................................... 0 0 0 

No Impact (%) .................................................................................................................................. 0 0 0 

Net Benefit (%) ................................................................................................................................. 100 100 100 

MC.L: 

Net Cost (%) ..................................................................................................................................... 0 0 0 


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32116 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

TABLE V.46—SUMMARY OF RESULTS FOR WALK-IN COOLERS AND FREEZERS TSLS: DISTRIBUTION OF CUSTOMER LCC 

IMPACTS—Continued 

Equipment class TSL 1 * TSL 2 * TSL 3 * 

No Impact (%) .................................................................................................................................. 0 0 0 

Net Benefit (%) ................................................................................................................................. 100 100 100 

MC.M: 

Net Cost (%) ..................................................................................................................................... 0 0 0 

No Impact (%) .................................................................................................................................. 0 0 0 

Net Benefit (%) ................................................................................................................................. 100 100 100 

SP.M: 

Net Cost (%) ..................................................................................................................................... 0 0 100 

No Impact (%) .................................................................................................................................. 100 100 0 

Net Benefit (%) ................................................................................................................................. 0 0 0 

SP.L: 

Net Cost (%) ..................................................................................................................................... 0 0 100 

No Impact (%) .................................................................................................................................. 100 100 0 

Net Benefit (%) ................................................................................................................................. 0 0 0 

FP.L: 

Net Cost (%) ..................................................................................................................................... 0 0 100 

No Impact (%) .................................................................................................................................. 100 100 0 

Net Benefit (%) ................................................................................................................................. 0 0 0 

DD.M: 

Net Cost (%) ..................................................................................................................................... 0 41 100 

No Impact (%) .................................................................................................................................. 30 0 0 

Net Benefit (%) ................................................................................................................................. 69 59 0 

DD.L: 

Net Cost (%) ..................................................................................................................................... 4 10 59 

No Impact (%) .................................................................................................................................. 0 0 0 

Net Benefit (%) ................................................................................................................................. 96 90 41 

PD.M: 

Net Cost (%) ..................................................................................................................................... 0 0 100 

No Impact (%) .................................................................................................................................. 100 100 0 

Net Benefit (%) ................................................................................................................................. 0 0 0 

PD.L: 

Net Cost (%) ..................................................................................................................................... 0 0 100 

No Impact (%) .................................................................................................................................. 100 100 0 

Net Benefit (%) ................................................................................................................................. 0 0 0 

FD.M: 

Net Cost (%) ..................................................................................................................................... 0 0 100 

No Impact (%) .................................................................................................................................. 100 100 0 

Net Benefit (%) ................................................................................................................................. 0 0 0 

FD.L: 

Net Cost (%) ..................................................................................................................................... 0 0 100 

No Impact (%) .................................................................................................................................. 100 100 0 

Net Benefit (%) ................................................................................................................................. 0 0 0 

* In some cases the percentages may not sum to 100 percent due to rounding. 

TSL 3 corresponds to the max-tech 

level for all the equipment classes and 

offers the potential for the highest 

cumulative energy savings. The 

estimated energy savings from TSL 3 is 

3.883 quads, an amount DOE deems 

significant. TSL 3 shows a net negative 

NPV for customers with estimated 

increased costs valued at $¥43.92 

billion at a 7-percent discount rate. 

Estimated emissions reductions are 

196.0 Mt of CO2, 314.4 thousand tons of 

NOX, 282.4 thousand tons of SO2, 

1026.8 thousand tons of methane, and 

0.34 tons of Hg. The CO2 emissions have 

an estimated value of $1.5 billion to 

$20.1 billion and the NOX emissions 

have an estimated value of $225.5 

million at a 7-percent discount rate. 

For TSL 3 the mean LCC savings for 

all equipment classes are positive for 

refrigeration systems, and negative for 

all refrigeration components, implying 

an increase in LCC in all component 

cases. The median PBP is longer than 

the lifetime of the equipment for all 

refrigeration component equipment 

classes. Similarly, the mean LCC savings 

for panels, which require the use of 

vacuum insulated panels at TSL 3, are 

negative with median PBP as high as 

nearly 240 years. As a result, DOE’s 

analysis does not project that there 

would be any benefits from setting a 

standard at TSL 3 for any of the affected 

components. 

At TSL 3, manufacturers may expect 

diminished profitability due to large 

increases in equipment costs, capital 

investments in equipment and tooling, 

and expenditures related to engineering 

and testing. The projected change in 

INPV ranges from a decrease of $549.3 

million to an increase of $1056.9 

million based on DOE’s manufacturer 

markup scenarios. The upper bound 

gain of $1056.9 million in INPV is 

considered an optimistic scenario for 

manufacturers because it assumes 

manufacturers can fully pass on 

substantial increases in equipment costs 

and upfront investments. DOE 

recognizes the risk of large negative 

impacts on industry if manufacturers’ 

expectations concerning reduced profit 

margins are realized. TSL 3 could 

reduce walk-in INPV by up to 42.5 

percent if impacts reach the lower 

bound of the range. 

After carefully considering the 

analytical results and weighing the 

benefits and burdens of TSL 3, DOE 

finds that the benefits to the Nation 

from TSL 3, in the form of energy 

savings and emissions reductions, 

including environmental and monetary 


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Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 32117 

benefits, are small compared to the 

burdens, in the form of a decrease in 

customer NPV. DOE concludes that the 

burdens of TSL 3 outweigh the benefits 

and, therefore, does not find TSL 3 to 

be economically justifiable. 

TSL 2 corresponds to the highest 

efficiency level, in each equipment 

class, which maximized energy savings, 

while maintaining a positive NPV at a 

7-percent discount rate for each 

equipment class. The estimated energy 

savings from TSL 2 is 3.149 quads, an 

amount DOE deems significant. TSL 2 

shows a net positive NPV for all 

customers with estimated at $9.90 

billion at a 7-percent discount rate. 

Estimated emissions reductions are 

159.2 Mt of CO2, 254.4 thousand tons of 

NOX, 229.2 thousand tons of SO2, 833.0 

thousand tons of methane, and 0.27 tons 

of Hg. The CO2 emissions have an 

estimated value of $1.2 billion to $16.3 

billion and the NOX emissions have an 

estimated value of $183.5 million at a 7- 

percent discount rate. 

At TSL 2, the projected change in 

INPV ranges from a decrease of $52.9 

million to an increase of $80.2 million. 

At TSL 2, DOE recognizes the risk of 

negative impacts if manufacturers’ 

expectations concerning reduced profit 

margins are realized. If the lower bound 

of the range of impacts is reached, as 

DOE expects, TSL 2 could result in a net 

loss of 4.10 percent in total INPV for 

manufacturers of walk-in refrigeration 

systems, panels, and doors. 

For TSL 2 the mean LCC savings for 

all equipment classes are positive for 

refrigeration systems, and l refrigeration 

components, implying an reduction in 

LCC in all cases. The median PBP is 

shorter than the lifetime of the 

equipment for all equipment classes. 

After careful consideration of the 

analytical results, weighing the benefits 

and burdens of TSL 3, and comparing 

them to those of TSL 2, the Secretary 

concludes that TSL 2 will offer the 

maximum improvement in efficiency 

that is technologically feasible and 

economically justified and will result in 

the significant conservation of energy. 

Therefore, DOE today is adopting 

standards at TSL 2 for walk-in coolers 

and walk-in freezers. The energy 

conservation standards for walk-in 

coolers and walk-in freezers are shown 

in Table V.47. DOE notes that instead of 

adopting the baseline R-value 

represented in TSL 2 for panels, the 

Agency is adopting the current Federal 

standard levels. DOE is not amending 

the standards for panels at this time but 

is continuing to require that these 

components satisfy the current panel 

energy conservation standards that 

Congress enacted. DOE has decided to 

retain the current panel energy 

conservation levels because it 

determined from its analysis that there 

is no TSL level that shows that higher 

panel standards are economically 

justified. While DOE’s analysis reveals 

that a portion of the market has already 

surpassed the current Federal energy 

conservation standards for certain types 

of panels at the representative thickness 

and material analyzed, DOE’s analysis 

does not provide the economic 

justification needed to amend the 

Federal standards for all types of WICF 

panels. Thus, DOE is retaining the 

current Federal standards, which 

establish a single R-value level that is 

independent of material properties or 

thickness and is continuing to allow 

manufacturers to have the flexibility to 

optimize both material properties and 

thickness at their discretion to meet the 

Federal standards. 

TABLE V.47—ENERGY CONSERVATION STANDARDS FOR WALK-IN COOLERS AND WALK-IN FREEZERS

Class descriptor 

Class 

Standard level 

Refrigeration systems Minimum AWEF (Btu/W-h) * 

Dedicated Condensing, Medium, Temperature, Indoor System, <9,000 

Btu/h Capacity.

DC.M.I, <9,000 ...................................... 5.61 

Dedicated Condensing, Medium Temperature, Indoor System, ≥9,000 

Btu/h Capacity.

DC.M.I, ≥9,000 ...................................... 5.61 

Dedicated Condensing, Medium Temperature, Outdoor System, 

<9,000 Btu/h Capacity.

DC.M.O, <9,000 .................................... 7.60 

Dedicated Condensing, Medium Temperature, Outdoor System, 

≥9,000 Btu/h Capacity.

DC.M.O, ≥9,000 .................................... 7.60 

Dedicated Condensing, Low Temperature, Indoor System, <9,000 

Btu/h Capacity.

DC.L.I, <9,000 ....................................... 5.93 × 10¥5 × Q + 2.33 

Dedicated Condensing, Low Temperature, Indoor System, ≥9,000 

Btu/h Capacity.

DC.L.I, ≥9,000 ....................................... 3.10 

Dedicated Condensing, Low Temperature, Outdoor System, <9,000 

Btu/h Capacity.

DC.L.O, <9,000 ..................................... 2.30 × 10¥4 × Q + 2.73 

Dedicated Condensing, Low Temperature, Outdoor System, ≥9,000 

Btu/h Capacity.

DC.L.O, ≥9,000 ..................................... 4.79 

Multiplex Condensing, Medium Temperature ........................................ MC.M ..................................................... 10.89 

Multiplex Condensing, Low Temperature .............................................. MC.L ...................................................... 6.57 

Panels Minimum R-value (h-ft2-°/Btu) 

Structural Panel, Medium Temperature ................................................. SP.M ...................................................... 25 

Structural Panel, Low Temperature ....................................................... SP.L ....................................................... 32 

Floor Panel, Low Temperature .............................................................. FP.L ....................................................... 28 

Non-Display Doors Maximum Energy Consumption (kWh/day) ** 

Passage Door, Medium Temperature .................................................... PD.M ..................................................... 0.05 × And + 1.7 

Passage Door, Low Temperature .......................................................... PD.L ...................................................... 0.14 × And + 4.8 

Freight Door, Medium Temperature ....................................................... FD.M ...................................................... 0.04 × And + 1.9 

Freight Door, Low Temperature ............................................................. FD.L ....................................................... 0.12 × And + 5.6 


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32118 Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Rules and Regulations 

39 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 2014, 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 (2017 through 2046) 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. 

TABLE V.47—ENERGY CONSERVATION STANDARDS FOR WALK-IN COOLERS AND WALK-IN FREEZERS—Continued 

Class descriptor 

Class 

Standard level 

Refrigeration systems Minimum AWEF (Btu/W-h) * 

Display Doors Maximum Energy Consumption (kWh/day)† 

Display Door, Medium Temperature ...................................................... DD.M ..................................................... 0.04 × Add + 0.41 

Display Door, Low Temperature ............................................................ DD.L ...................................................... 0.15 × Add + 0.29 

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

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

† Add represents the surface area of the display door. 

2. Summary of Benefits and Costs 

(Annualized) of the Standards 

The benefits and costs of these 

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 operating the 

equipment (consisting primarily of 

operating cost savings from using less 

energy, minus increases in equipment 

purchase and installation costs, which 

is another way of representing consumer 

NPV), plus (2) the annualized monetary 

value of the benefits of emission 

reductions, including CO2 emission 

reductions.39

Estimates of annualized benefits and 

costs of these standards are shown in 

Table V.48. 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 in this rule is $511 

million per year in increased equipment 

costs, while the benefits are $879 

million per year in reduced equipment 

operating costs, $287 million in CO2

reductions, and $16.93 million in 

reduced NOX emissions. In this case, the 

net benefit amounts to $671 million per 

year. Using a 3-percent discount rate for 

all benefits and costs and the average 

SCC series, the cost of the standards in 

this rule is $528 million per year in 

increased equipment costs, while the 

benefits are $1,064 million per year in 

reduced operating costs, $287 million in 

CO2 reductions, and $19.82 million in 

reduced NOX emissions. In this case, the 

net benefit amounts to $842 million per 

year. 

TABLE V.48—ANNUALIZED BENEFITS AND COSTS OF NEW AND AMENDED STANDARDS FOR WALK-IN COOLERS AND WALKIN FREEZERS

Discount rate Primary estimate * Low net benefits estimate * 

High net benefits 

estimate * 

million 2013$/year 

Benefits: 

Operating Cost Savings ........................................... 7% .......................... 879 ......................... 854 ......................... 1901 

3% .......................... 1064 ....................... 1027 ....................... 1115 

CO2 Reduction at ($12.0/t case)** ........................... 5% .......................... 86 ........................... 86 ........................... 86 

CO2 Reduction at ($40.5/t case)** ........................... 3% .......................... 287 ......................... 287 ......................... 287 

CO2 Reduction at ($62.4/t case)** ........................... 2.5% ....................... 420 ......................... 420 ......................... 420 

CO2 Reduction at ($117/t case)** ............................ 3% .......................... 884 ......................... 884 ......................... 884 

NOX Reduction at ($2,684/ton)** ............................. 7% .......................... 16.93 ...................... 16.93 ...................... 16.93 

3% .......................... 19.82 ...................... 19.82 ...................... 19.82 

Total Benefits † ......................................................... 7% plus CO2 range 981 to 1,780 ........... 957 to 1,755 ........... 1,020 to 1,818 

7% .......................... 1,183 ...................... 1,158 ...................... 1,221 

3% plus CO2 range 1,169 to 1,968 ........ 1,133 to 1,931 ........ 1,221 to 2,019 

3% .......................... 1,371 ...................... 1,334 ...................... 1,422 

Costs: 

Incremental Equipment Costs .................................. 7% .......................... 511 ......................... 501 ......................... 522 

3% .......................... 528 ......................... 515 ......................... 541 

Net Benefits: 

Total † .............................................................................. 7% plus CO2 range 470 to 1,269 ........... 456 to 1,255 ........... 498 to 1,296 

7% .......................... 671 ......................... 657 ......................... 699 

3% plus CO2 range 641 to 1,440 ........... 617 to 1,416 ........... 680 to 1,478 


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TABLE V.48—ANNUALIZED BENEFITS AND COSTS OF NEW AND AMENDED STANDARDS FOR WALK-IN COOLERS AND WALKIN FREEZERS—Continued 

Discount rate Primary estimate * Low net benefits estimate * 

High net benefits 

estimate * 

3% .......................... 842 ......................... 818 ......................... 881 

* This table presents the annualized costs and benefits associated with walk-in coolers and walk-in freezers shipped in 2017–2046. These results include benefits to customers which accrue after 2046 from the equipment purchased in 2017–2046. The results account for the incremental variable and fixed costs incurred by manufacturers due to the amended standard, some of which may be incurred in preparation for the 

final rule. The primary, low, and high estimates utilize projections of energy prices from the AEO 2013 Reference case, Low Estimate, and High 

Estimate, respectively. In addition, incremental equipment costs reflect a medium decline rate for projected equipment price trends in the Primary 

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

price trends in the High Benefits Estimate. 

** The CO2 values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the updated SCC values. The 

first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE 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, which is the $40.5/t CO2 reduction case. 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. 

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 these 

standards address are as follows: 

(1) There are external benefits resulting 

from improved energy efficiency of 

commercial refrigeration equipment that are 

not captured by the users of such equipment. 

These benefits include externalities related to 

environmental protection and energy security 

that are not reflected in energy prices, such 

as reduced emissions of greenhouse gases. 

DOE attempts to quantify some of the 

external benefits through use of Social Cost 

of Carbon values. 

In addition, DOE has determined that 

this 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 this 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 draft 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 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 this final rule 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 a final regulatory flexibility analysis 

(FRFA) 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). 

For manufacturers of walk-in coolers 

and walk-in 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 


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40See www.ahridirectory.org/ahriDirectory/

pages/home.aspx. 

41See http://www.nafem.org/find-members/

MemberDirectory.aspx. 

42See http://dsbs.sba.gov/dsbs/search/dsp_

dsbs.cfm. 

43See www.dnb.com/. 

44See www.hoovers.com/. 

http://www.sba.gov/content/smallbusiness-size-standards. Walk-in 

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 less 

for an entity to be considered as a small 

business for this category. Based on this 

threshold, DOE present the following 

FRFA analysis: 

1. Description and Estimated Number of 

Small Entities Regulated 

During its market survey, DOE used 

available public information to identify 

potential small manufacturers. DOE’s 

research involved industry trade 

association membership directories 

(including AHRI Directory,40 and 

NAFEM 41), public databases (e.g. the 

SBA Database,42) individual company 

Web sites, and market research 

tools (e.g.,, Dunn and Bradstreet 

reports 43 and Hoovers reports 44) to 

create a list of companies that 

manufacture or sell equipment covered 

by this rulemaking. DOE also asked 

stakeholders and industry 

representatives if they were aware of 

any other small manufacturers during 

manufacturer interviews and at DOE 

public meetings. DOE reviewed publicly 

available data and contacted select 

companies on its list, as necessary, to 

determine whether they met the SBA’s 

definition of a small business 

manufacturer of covered walk-in coolers 

and walk-in freezers. DOE screened out 

companies that do not offer equipment 

covered by this rulemaking, do not meet 

the definition of a ‘‘small business,’’ or 

are foreign owned. 

Based on this information, DOE 

identified forty-seven panel 

manufacturers and found forty-two 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. 

This rule sets the energy conservation 

standard for walk-in panels at the 

baseline efficiency level. Based on 

manufacturer comments in the NOPR 

public meeting, DOE expects that all 

manufacturers will be able to meet the 

baseline efficiency level without 

product changes, implementation of 

new design options, or investments in 

capital equipment. As a result, DOE 

certifies that the standard would not 

have a significant impact on small 

businesses with respect to the walk-ins 

panel industry. 

DOE identified forty-nine walk-in 

door manufacturers. Forty-five of those 

produce solid doors and four produce 

display doors. Of the forty-five solid 

door manufacturers, forty-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 

businesses. As part of the MIA 

interviews, the Department interviewed 

six door manufacturers, including four 

small business operations. Based on an 

analysis of the anticipated conversion 

costs relative to the size of the small 

businesses in the door market, DOE 

certifies that the proposed standards 

would not have a significant impact on 

a large number of small businesses with 

respect to the door industry. The 

complete analysis of small door 

manufacturer is presented below in 

section VI.B.2. 

DOE identified nine refrigeration 

system manufacturers in the WICF 

industry. Two of those companies are 

foreign-owned. Based on publicly 

available information, two of the 

remaining seven domestic 

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. 

2. Description and Estimate of 

Compliance Requirements 

Given the significant role of small 

businesses in the walk-ins door 

industries, DOE provides a detailed 

analysis of the impacts of the standard 

on the industry. For the walk-in door 

industry, DOE identified seven small 

manufacturers that produce doors as 

their primary product, as described in 

section VI.B.1. Three companies 

produce solid doors and four companies 

produce display doors. 

All three manufacturers of customized 

passage doors and freight doors are 

small. This rule sets the energy 

conservation standard for the passage 

and freight door equipment classes at 

the baseline efficiency level. DOE 

expects that manufacturers will not 

need to make capital equipment 

investments or product conversion 

investments as result of this standard. 

As a result, DOE certifies that the 

standards set for passage and freight 

doors would not have a significant 

impact on small businesses 

manufacturers. 

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 necessary 

capital and product conversion costs, 

which do not necessarily scale with size 

or sales volume. However, as illustrated 

in Table VI.1, conversion costs for 

display door manufacturers are 

negligible for most TSLs. This is 

because the considered design options 

primarily consist of component swaps 

and relatively straight-forward 


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component additions. Also, 

manufacturers will have between three 

and five years from the publication date 

of the final rule to make the necessary 

equipment and production line changes. 

TABLE VI.1—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 ............................................................... 4 10 0 2 

TSL 2 ............................................................... 52 17 1 4 

TSL 3 ............................................................... 817 30 4 33 

TABLE VI.2—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 ............................................................... 1 2 0 0 

TSL 2 ............................................................... 9 3 0 1 

TSL 3 ............................................................... 144 5 1 6 

At the standard set in this rule (TSL 

2), the engineering analysis suggests that 

manufacturers would need to purchase 

more efficient components, such as LED 

lights; incorporate anti-sweat heater 

controllers; and include lighting 

controls. Furthermore, for lowtemperature applications, manufacturers 

may need to incorporate special 

coatings and krypton gas fills to reduce 

energy loss through display doors. 

Manufacturers noted in interviews they 

would likely purchase glass packs that 

already have the appropriate glass layers 

and coatings to meet the standard. Most 

manufacturers are able to apply gas 

fillings to their products today, though 

they may need to invest in additional 

stations for krypton gas. Based on DOE’s 

analysis, the capital conversion costs 

and product conversion costs appear to 

be manageable for both small and large 

display door manufacturers. As a result, 

DOE certifies that these standards 

would not have a significant impact on 

a substantial number of small display 

door manufacturers. 

3. Duplication, Overlap, and Conflict 

With Other Rules and Regulations 

DOE is not aware of any rules or 

regulations that duplicate, overlap, or 

conflict with the rule being adopted 

today. 

4. Significant Alternatives to the Rule 

The discussion above analyzes 

impacts on small businesses that would 

result from DOE’s amended standards. 

In addition to the other TSLs being 

considered, the rulemaking TSD 

includes a regulatory impact analysis 

(RIA). For walk-in coolers and walk-in 

freezers, the RIA discusses the following 

policy alternatives: (1) No change in 

standard; (2) consumer rebates; (3) 

consumer tax credits; and (4) 

manufacturer tax credits; (5) voluntary 

energy efficiency targets; and (6) bulk 

government purchases. While these 

alternatives may mitigate to some 

varying extent the economic impacts on 

small entities compared to the 

standards, DOE determined that the 

energy savings of these alternatives are 

significantly smaller than those that 

would be expected to result from 

adoption of the amended standard 

levels. (See chapter 17 of the final rule 

TSD for the analysis supporting this 

determination.) Accordingly, DOE is 

declining to adopt any of these 

alternatives and is adopting the 

standards set forth in this rulemaking. 

C. Review Under the Paperwork 

Reduction Act 

Manufacturers of walk-in coolers and 

walk-in freezers must certify to DOE 

that their equipment comply with any 

applicable energy conservation 

standards. In certifying compliance, 

manufacturers must test their 

equipment according to the DOE test 

procedures for walk-in coolers and 

walk-in 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 walkin coolers and walk-in freezers. (76 FR 

12422 (March 7, 2011)). The collectionof-information requirement for the 

certification and recordkeeping is 

subject to review and approval by OMB 

under the Paperwork Reduction Act 

(PRA). This requirement has been 

approved by OMB under OMB control 

number 1910–1400. Public reporting 

burden for the certification is estimated 

to average 20 hours per response, 

including the time for reviewing 

instructions, searching existing data 

sources, gathering and maintaining the 

data needed, and completing and 

reviewing the collection of information. 

Notwithstanding any other provision 

of the law, no person is required to 

respond to, nor shall any person be 

subject to a penalty for failure to comply 

with, a collection of information subject 

to the requirements of the PRA, unless 

that collection of information displays a 

currently valid OMB Control Number. 

D. Review Under the National 

Environmental Policy Act of 1969 

Pursuant to the National 

Environmental Policy Act (NEPA) of 

1969, DOE has determined that the rule 

fits within the category of actions 

included in Categorical Exclusion (CX) 

B5.1 and otherwise meets the 

requirements for application of a CX. 

See 10 CFR Part 1021, App. B, B5.1(b); 

1021.410(b) and Appendix B, B(1)–(5). 

The rule fits within the category of 

actions because it is a rulemaking that 

establishes energy conservation 

standards for consumer products or 

industrial equipment, and for which 

none of the exceptions identified in CX 

B5.1(b) apply. Therefore, DOE has made 

a CX determination for this rulemaking, 

and DOE does not need to prepare an 

Environmental Assessment or 

Environmental Impact Statement for 


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this rule. DOE’s CX determination for 

this rule is available at http://

cxnepa.energy.gov/. 

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 equipment 

that are the subject of this final rule. 

States can petition DOE for exemption 

from such preemption to the extent, and 

based on criteria, set forth in EPCA. (42 

U.S.C. 6297) No further action is 

required by Executive Order 13132. 

F. Review Under Executive Order 12988 

With respect to the review of existing 

regulations and the promulgation of 

new regulations, section 3(a) of 

Executive Order 12988, ‘‘Civil Justice 

Reform,’’ imposes on Federal agencies 

the general duty to adhere to the 

following requirements: (1) Eliminate 

drafting errors and ambiguity; (2) write 

regulations to minimize litigation; and 

(3) provide a clear legal standard for 

affected conduct rather than a general 

standard and promote simplification 

and burden reduction. 61 FR 4729 (Feb. 

7, 1996). Section 3(b) of Executive Order 

12988 specifically requires that 

Executive agencies make every 

reasonable effort to ensure that the 

regulation: (1) Clearly specifies the 

preemptive effect, if any; (2) clearly 

specifies any effect on existing Federal 

law or regulation; (3) provides a clear 

legal standard for affected conduct 

while promoting simplification and 

burden reduction; (4) specifies the 

retroactive effect, if any; (5) adequately 

defines key terms; and (6) addresses 

other important issues affecting clarity 

and general draftsmanship under any 

guidelines issued by the Attorney 

General. Section 3(c) of Executive Order 

12988 requires Executive agencies to 

review regulations in light of applicable 

standards in section 3(a) and section 

3(b) to determine whether they are met 

or it is unreasonable to meet one or 

more of them. DOE has completed the 

required review and determined that, to 

the extent permitted by law, this final 

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 an 

amended 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 ‘‘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. 

DOE has concluded that this final rule 

would likely require expenditures of 

$100 million or more on the private 

sector. Such expenditures may include: 

(1) Investment in research and 

development and in capital 

expenditures by walk-in coolers and 

walk-in freezers manufacturers in the 

years between the final rule and the 

compliance date for the new standards, 

and (2) incremental additional 

expenditures by consumers to purchase 

higher-efficiency walk-in coolers and 

walk-in 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 final 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 notice of final rulemaking and the 

‘‘Regulatory Impact Analysis’’ section of 

the TSD for this final 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 rule unless DOE publishes an 

explanation for doing otherwise, or the 

selection of such an alternative is 

inconsistent with law. As required by 42 

U.S.C. 6295(d), (f), and (o), 6313(e), and 

6316(a), this final 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 this 

final 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 

(March 18, 1988), that this regulation 

would not result in any takings that 

might require compensation under the 

Fifth Amendment to the U.S. 

Constitution. 


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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 

this final rule 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 

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 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 concluded that this 

regulatory action, which sets forth 

energy conservation standards for walkin coolers and walk-in freezers, is not a 

significant energy action because the 

amended 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 final 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 

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 and/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. 

M. Congressional Notification 

As required by 5 U.S.C. 801, DOE will 

report to Congress on the promulgation 

of this rule prior to its effective date. 

The report will state that it has been 

determined that the rule is a ‘‘major 

rule’’ as defined by 5 U.S.C. 804(2). 

VII. Approval of the Office of the 

Secretary 

The Secretary of Energy has approved 

publication of this final rule. 

List of Subjects in 10 CFR Part 431 

Administrative practice and 

procedure, Confidential business 

information, Energy conservation, 

Household appliances, Imports, 

Intergovernmental relations, Reporting 

and recordkeeping requirements, and 

Small businesses. 

Issued in Washington, DC, on May 8, 2014. 

David T. Danielson, 

Assistant Secretary, Energy Efficiency and 

Renewable Energy. 

For the reasons stated in the 

preamble, DOE amends part 431 of 

chapter II, subchapter D, of title 10 of 

the Code of Federal Regulations, to read 

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), and 

(e) 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 


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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. 

* * * * * 

(c) Walk-in cooler and freezer display 

doors. All walk-in cooler and walk-in 

freezer display doors manufactured 

starting June 5, 2017, must satisfy the 

following standards: 

Class descriptor Class 

Equations for 

maximum energy 

consumption 

(kWh/day) * 

Display Door, Medium Temperature ........................................................................................................ DD.M ................. 0.04 × Add + 0.41. 

Display Door, Low Temperature .............................................................................................................. DD.L .................. 0.15 × Add + 0.29. 

*Add represents the surface area of the display door. 

(d) Walk-in cooler and freezer nondisplay doors. All walk-in cooler and 

walk-in freezer non-display doors 

manufactured starting on June 5, 2017, 

must satisfy the following standards: 

Class descriptor Class 

Equations for 

maximum energy 

consumption 

(kWh/day) * 

Passage door, Medium Temperature ....................................................................................................... PD.M ................. 0.05 × And + 1.7. 

Passage Door, Low Temperature ............................................................................................................ PD.L .................. 0.14 × And + 4.8. 

Freight Door, Medium Temperature ......................................................................................................... FD.M ................. 0.04 × And + 1.9. 

Freight Door, Low Temperature ............................................................................................................... FD.L .................. 0.12 × And + 5.6. 

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

(e) Walk-in cooler and freezer 

refrigeration systems. All walk-in cooler 

and walk-in freezer refrigeration 

systems manufactured starting on June 

5, 2017, must satisfy the following 

standards: 

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 .......................... 5.61 

Dedicated Condensing, Medium Temperature, Indoor System, ≥9,000 Btu/h Capacity.DC.M.I, ≥9,000 .......................... 5.61 

Dedicated Condensing, Medium Temperature, Outdoor System, <9,000 Btu/h 

Capacity.

DC.M.O, <9,000 ........................ 7.60 

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

Capacity.

DC.M.O, ≥9,000 ........................ 7.60 

Dedicated Condensing, Low Temperature, Indoor System, <9,000 Btu/h Capacity.DC.L.I, <9,000 ........................... 5.93 × 10¥5 × Q + 2.33 

Dedicated Condensing, Low Temperature, Indoor System, ≥9,000 Btu/h Capacity.DC.L.I, ≥9,000 ........................... 3.10 

Dedicated Condensing, Low Temperature, Outdoor System, <9,000 Btu/h Capacity.DC.L.O, <9,000 ......................... 2.30 × 10¥4 × Q + 2.73 

Dedicated Condensing, Low Temperature, Outdoor System, ≥9,000 Btu/h Capacity.DC.L.O, ≥9,000 ......................... 4.79 

Multiplex Condensing, Medium Temperature ......................................................... MC.M ......................................... 10.89 

Multiplex Condensing, Low Temperature ............................................................... MC.L .......................................... 6.57 

* Q represents the system gross capacity as calculated by the procedures set forth in AHRI 1250. 

[FR Doc. 2014–11489 Filed 6–2–14; 8:45 am] 

BILLING CODE 6450–01–P 


tkelley on DSK3SPTVN1PROD with RULES2