Building Technologies Program 1 eere.energy.gov

BUILDING TECHNOLOGIES PROGRAM

Preliminary Analysis Public Meeting 

on Energy Conservation Standards 

for Commercial Refrigeration 

Equipment

Charles Llenza

Department of Energy

Energy Efficiency & Renewable Energy

CRE-2010-STD-0003@ee.doe.gov

April 19, 2011
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• Introductions

• Role of the Facilitator

• Ground Rules (norms)

– Listen as an ally

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– Focus on issues, not personalities

– One person speak at a time (raise hand to be recognized; state your 

name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

Welcome and Introductions
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Request for Comment

Issue Box: DOE welcomes comment regarding the Notice of Public 

Meeting and Availability of the Preliminary Technical Support 

Document. Throughout this presentation, specific issues will be 

raised for discussion in yellow issue boxes. However, comments 

concerning any part of the document or presentation are welcome.
Building Technologies Program 4 eere.energy.gov

Preliminary Manufacturer Impact Analysis; NOPR 

Analyses

Test Procedure

Certification, Compliance & Enforcement

Public Meeting Agenda

4

5

6

Markups Analysis; Energy Use Analysis; Life-Cycle 

Cost and Payback Period Analysis

2

Shipments Analysis; National Impact Analysis

3

1 Introduction and Overview

Market and Technology Assessment; Screening and 

Engineering Analysis

7

8 Closing Remarks
Building Technologies Program 5 eere.energy.gov

Introduction and Overview

Purpose of the Public Meeting

• Present the procedural and analytical approaches to evaluate energy 

conservation standards for commercial refrigeration equipment (CRE).

• Provide a forum for public discussion of rulemaking issues.

• Encourage interested parties to submit data, information, and written 

comments.

• Inform interested parties and facilitate the rulemaking process.
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• EPACT 2005 amended EPCA to prescribe standards for self-contained commercial refrigerators, 

freezers, and refrigerator freezers with doors.

• EPACT 2005 also directed DOE to set standards by January 1, 2009 for remote-condensing 

equipment, open cases, and ice cream freezers. DOE published a final rule on January 9, 2009 (74 

FR 1092); compliance date January 1, 2012. 

• EPACT 2005 also directed DOE to determine whether to amend the standards set both by the 

2009 DOE rulemaking and by EPACT 2005 and, if necessary, perform a rulemaking and publish 

amended standards by January 1, 2013. The preliminary analysis for this rulemaking is the subject 

of today’s public meeting. 

• Any amended standards established by DOE will apply to equipment manufactured no earlier 

than 3 years or more after the publication of such a rule and no later than a maximum of 5 years.

2005 2009 2010 2012 2013 2016

DOE determines 

whether to amend 

standards for all 

CRE equipment 

(EPACT and 2009 

rulemaking)

EPACT 

prescribes 

standards 

for SC 

equipment

with doors

EPCA 

establishes 

energy 

conservation 

program 

1975

DOE sets standards for 

ice-cream freezers, remote 

condensing equipment, 

and self-contained 

equipment without doors

Introduction and Overview

Rulemaking History & Timelines
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Introduction and Overview

Current Rulemakings Timelines

2010

ECS Framework 

Document Public 

Meeting

May 18, 2010

ECS Preliminary 

Analysis

Public Meeting

April 19, 2011

ECS NOPR

Public Meeting

Planned - Spring 2012

2012 2013 2014 2015 2016

Planned ECS Final Rule 

Effective Date 

January 1, 2016

CRE Energy Conservation Standard Rulemaking Timeline

TP NOPR 

Public Meeting

January 6, 2011

2011
Building Technologies Program 8 eere.energy.gov

Introduction and Overview

Preliminary Analysis Rulemaking Stages

Market and 

Technology 

Assessment

Screening

Analysis

Engineering

Analysis

Markups for

Equipment

Price

Determination

Shipments

Analysis

National

Impact

Analysis

Energy Use Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

NOPR Final 

Rule

Framework

Document

Preliminary

Analysis
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Introduction and Overview

Interested Parties’ Opening Statements

At this time DOE welcomes opening remarks on the preliminary analysis 

for commercial refrigeration equipment. 
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Preliminary Manufacturer Impact Analysis; NOPR 

Analyses

Test Procedure

Certification, Compliance & Enforcement

Public Meeting Agenda

4

5

6

Markups Analysis; Energy Use Analysis; Life-Cycle 

Cost and Payback Period Analysis

2

Shipments Analysis; National Impact Analysis

3

1 Introduction and Overview

Market and Technology Assessment; Screening and 

Engineering Analysis

7

8 Closing Remarks
Building Technologies Program 11 eere.energy.gov

Market Assessment

Purpose & Method

• Purpose

– Characterize the CRE market and manufacturers

– Determine scope of coverage

– Determine appropriate equipment classes

• Method

– Identify manufacturers of CRE and their product offerings by 

conducting a study of the CRE market

– Use available shipment data to characterize market trends

– Develop appropriate equipment classes to classify covered equipment

• Detailed description of methodology and results is contained 

in Chapter 3 of the preliminary TSD.
Building Technologies Program 12 eere.energy.gov

Market Assessment

Equipment Classes

• 2009 Final Rule equipment classes

– Consisted of 38 covered classes

– Nomenclature developed allowed for 48 total equipment classes

• 8 equipment families

• 3 rating temperatures (medium, low, and ice cream)

• 2 operating modes (remote-condensing and self-contained)

• EPACT 2005 equipment

– EPACT 2005 set standards for 5 specific groups of equipment

– Using the DOE equipment class nomenclature developed for the 2009 

rulemaking, plus the addition of a “pull-down” equipment family, this 

was classified as 11 additional classes

• For this rulemaking, DOE is considering a total of 49 covered 

classes

– A full listing of the equipment classes is shown in Chapter 3 of the 

preliminary TSD
Building Technologies Program 13 eere.energy.gov

Market Assessment

Equipment Classes

Equipment Family Name Equipment Family 

Abbreviation

Vertical Open VOP

Semivertical Open SVO

Horizontal Open HZO

Vertical Closed Transparent VCT

Horizontal Closed 

Transparent HCT

Vertical Closed Solid VCS

Horizontal Closed Solid HCS

Service Over Counter SOC

Pull-Down PD
Building Technologies Program 14 eere.energy.gov

Market Assessment

Equipment Classes

Rating 

Temperature 

Designation

Rating 

Temperature 

Value

Rating

Temperature 

Abbreviation

Medium 38°F M

Low 0°F L

Ice Cream -15°F I

Operating Mode 

Designation

Operating Mode 

Abbreviation

Remote-Condensing RC

Self-Contained SC
Building Technologies Program 15 eere.energy.gov

Market Assessment

Request for Comment

Item 2-1 DOE seeks comment on the equipment class 

nomenclature and on the appropriateness of the stated equipment 

classes for classifying the commercial refrigeration equipment 

market. 
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Technology Assessment

Purpose & Method

• Purpose

– To develop a preliminary list of technology options that could improve 

the efficiency of commercial refrigeration equipment.

• Method

– DOE identified technology options from:

• Literature review

• Manufacturer brochures and specification sheets for commercially 

available equipment

• Comments and input from stakeholders

• All technology options are described in Chapter 3 of the 

preliminary TSD.
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Technology Assessment

Technologies Identified

All Equipment Classes

Higher Efficiency Lighting Increased Evaporator Surface Area

Higher Efficiency Lighting Ballasts Low Pressure Differential Evaporators

Remote Lighting Ballast Location Case Insulation Increases or Improvements

Higher Efficiency Expansion Valves Defrost Mechanisms

Higher Efficiency Evaporator Fan 

Motors

Defrost Cycle Control

Variable-Speed Evaporator Fan Motors 

and Evaporator Fan Motor Controllers

Vacuum Insulated Panels

Higher Efficiency Evaporator Fan 

Blades

Occupancy Sensors for Lighting Controls
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Technology Assessment

Technologies Identified

Equipment With Doors Only

Anti-Fog Films on Transparent Doors Anti-Sweat Heater Controls

Equipment Without Doors Only

Air Curtain Design Night Curtains

Self-Contained Equipment Only

Higher Efficiency Compressors Liquid Suction Heat Exchangers

Increased Condenser Surface Area Higher Efficiency Condenser Fan Motors

Variable-Speed Condenser Fan Motors 

and Condenser Fan Motors Controllers

Higher Efficiency Condenser Fan Blades
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Technology Assessment

Request for Comment

Item 2-2 DOE asks interested parties to comment on other 

technologies that DOE should consider.
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Screening Analysis

Purpose

• Purpose

– To determine which technology options will be considered in 

downstream analyses.

• Technology options are “screened out” if they

– Are not technologically feasible

– Are not practicable to manufacture, install, and service

– Have adverse impacts on equipment utility or availability to customers

– Have adverse impacts on health or safety

• In this analysis, DOE also removed from consideration 

technologies that do not affect calculated energy 

consumption as measured by the test procedure.

• The methodology and results are presented in detail in 

Chapter 4 of the preliminary TSD.
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Screening Analysis

Technologies Removed from Consideration

• Technologies that do not affect calculated energy 

consumption per the DOE test procedure:

– Higher-efficiency expansion valves

– Variable-speed condenser fans and condenser fan motor controllers

– Anti-sweat heater controllers

– Liquid-suction heat exchangers

• Screened-Out Technology:

– Air curtain design
Building Technologies Program 22 eere.energy.gov

Engineering Analysis

Purpose and Methods

• Purpose

– To characterize the relationship between manufacturer selling 

price and commercial refrigeration equipment energy 

consumption.

• Methods

– DOE selected 24 “primary” equipment classes to analyze directly 

in its engineering analysis.

– DOE chose representative unit sizes from each primary class on 

which to perform the analysis.

– For each unit, DOE determined the baseline configuration.

– DOE also analyzed the technology options for each class.

• The methodology and results are presented in detail in 

Chapter 5 of the preliminary TSD.
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Engineering Analysis

Approach

• DOE used a design-option approach to estimate the effect of 

implementing advanced technologies.

– For a baseline unit, DOE first calculated:

• Daily energy consumption

• Cost

– DOE added advanced technologies to the baseline and calculated:

• Reduction in daily energy consumption

• Incremental cost

– Finally, DOE sorted the technologies in order from most to least costeffective.

• Result: Cost-Efficiency Curves, which describe the 

relationship between energy consumption and manufacturer 

selling price.
Building Technologies Program 24 eere.energy.gov

Engineering Analysis

Design Options Analyzed

Engineering Design Options

Higher Efficiency Lighting and Occupancy 

Sensors for VOP, SVO, and SOC (Horizontal 

Fixtures)

Higher Efficiency Lighting and Occupancy 

Sensors for VCT and PD (Vertical Fixtures)

Increased Evaporator Coil Surface Area Higher Efficiency Evaporator Fan Motors

Improved Case Insulation Improved Doors for VCT: Low and Ice Cream 

Temperatures

Improved Doors for VCT and PD: Medium 

Temperature

Improved Doors for HCT: Low and Ice Cream 

Temperatures

Improved Doors for HCT: Medium 

Temperature

Improved Doors for SOC: Medium 

Temperature

Increased Condenser Surface Area (SC 

Only)

Higher Efficiency Condenser Fan Motors (SC 

Only)

Higher Efficiency Compressors (SC Only) Night Curtains (Equipment Without Doors 

Only)
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Engineering Analysis

Energy Consumption Model

Total Heat 

Load 

[Btu/h]

Component 

Load

[Btu/h]

Non-Electric 

Load

[Btu/h]

Fan Motor 

Heat Load

[Btu/h]

Lighting Heat 

Load

[Btu/h]

Radiation 

Load

[Btu/h]

Conduction 

Load

[Btu/h]

Infiltration 

Load

[Btu/h]

Daily Energy 

Consumption [kWh/day]

Compressor 

Energy 

Consumption 

[kWh/day]

Compressor Model 

(ARI 540)

 

 

Component 

Energy 

Consumption 

[kWh/day]

Fan Motor 

Energy

 Consumption 

[kWh/day]

Lighting 

Energy 

Consumption 

[kWh/day]
Building Technologies Program 26 eere.energy.gov

Engineering Analysis

Request for Comment

Item 2-3 DOE seeks comment on its energy consumption model 

and engineering approach for analyzing commercial refrigeration 

equipment.
Building Technologies Program 27 eere.energy.gov

Engineering Analysis

Cost Model

• Manufacturer selling price is the output of the cost model

– Costs for implementing design options were derived from a review of 

publicly available cost information, as well as discussions with 

manufacturers.

– Core case costs for each equipment class were derived from a 

manufacturing cost model prepared for the 2009 rulemaking.

– Manufacturer markups and outbound freight costs were applied to 

arrive at manufacturer selling price.

• Direct material

• Direct labor

• Factory overhead

• Depreciation

• Sales & marketing

• Research & 

development

• Interest

• Profit

Shipping from 

manufacturer to 

distributor

Manufacturer 

Production 

Cost

Manufacturer

Markup 

Outbound 

Freight Cost = Manufacturer + Selling Price
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Engineering Analysis

Request for Comment

Item 2-4 DOE seeks comment on its costs, markup, and outbound 

freight methodologies.
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• Each point on a cost-efficiency curve is called an Efficiency Level.

• DOE conducted downstream analyses at each efficiency level for 

the representative units modeled

Engineering Analysis

Example Cost-Efficiency Curve

$3,000 

$3,500 

$4,000 

$4,500 

$5,000 

$5,500 

10 15 20 25 30 35

Manufacturer Selling Price [$]

Daily Energy Consumption [kWh/day]

VCT.SC.L

Vertical Self-Contained Freezer with Transparent Doors

Max Tech

Baseline
Building Technologies Program 30 eere.energy.gov

Preliminary Manufacturer Impact Analysis; NOPR 

Analyses

Test Procedure

Certification, Compliance & Enforcement

Public Meeting Agenda

4

5

6

Markups Analysis; Energy Use Analysis; Life-Cycle 

Cost and Payback Period Analysis

2

Shipments Analysis; National Impact Analysis

3

1 Introduction and Overview

Market and Technology Assessment; Screening and 

Engineering Analysis

7

8 Closing Remarks
Building Technologies Program 31 eere.energy.gov

Markups Analysis

Overview

Purpose

• Determine the market share-based weighting factor of each distribution 

channel.

• Determine the baseline and incremental price markups for each distribution 

channel and overall markup values.

Manufacturer

Customer Customer

Manufacturer

Customer

Manufacturer

Wholesaler (Distributor) Wholesaler (Distributor)

Contractor Channel Wholesaler Channel National Account Channel

Mechanical Contractor

Distribution Channels
Building Technologies Program 32 eere.energy.gov

Markups Analysis 

Distribution Channel Weighting Factors

Item 3-1 DOE seeks comment on the weighting factors for the 

three distribution channels.

Remote-Condensing Equipment

National Account 

Channel 

70%

Contractor 

Channel 

15%

Wholesaler 

Channel 

15%

Self-Contained Equipment

National Account 

Channel 

30%

Contractor 

Channel 

10%

Wholesaler 

Channel 

60%
Building Technologies Program 33 eere.energy.gov

Markups Analysis

Inputs and Methodology

Inputs

• Industry balance sheets from HARDI for wholesalers profit data.

• U.S. Census Bureau data for mechanical contractor profit data.

Methodology

• Contractor and wholesaler expenses and markups:

– Cost of goods sold

– Labor expenses (salaries and benefits)

– Occupancy expenses (rent, maintenance, utilities)

– Other operating expenses (depreciation, advertising, insurance)

– Profit

• Express expenses and profit in terms of per dollar cost of goods sold and sum 

up the resulting numbers to obtain a baseline markup.

• Assumption for incremental markups: labor and operating expenses are 

fixed, and other operating expenses and profit scale with manufacturer 

selling price (cost of goods sold).

• National account markup is assumed to be half of the wholesaler markup. 
Building Technologies Program 34 eere.energy.gov

Markups Analysis

Preliminary Weighted-Average Markups

Markups (Baseline / Incremental)

Wholesaler

Mechanical 

Contractor

(Includes 

Wholesaler)

National 

Account 

Overall Weighted Average 

Markup

Self 

Contained

Remote 

Condensing

Distribution 

Channel

Markup

1.36/1.09 2.00/1.30 1.18/1.05 1.37/1.10 1.33/1.25

Markup

(Incl. Sales Tax) 1.46/1.17 2.15/1.39 1.27/1.12 1.47/1.18 1.43/1.34

Sales Tax 

Multiplier 1.07

Item 3-2 DOE seeks comment on the methodology and 

assumptions used for the markups analysis.
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Energy Use Analysis

Overview

Description/Background

• Generally, the purpose of this analysis is to translate equipment efficiency as 

determined in the engineering analysis into real-world energy use.

• During the 2009 rulemaking process, the engineering energy consumption 

model (Engineering Analysis) was validated by means of whole-building 

simulations; this validation was not repeated for the preliminary analysis.

• In the preliminary analysis, DOE evaluated the incremental effect of improved 

efficiency of self-contained equipment on restaurant building heating and 

cooling loads.

Findings and Conclusions

• DOE concluded that efficiency improvements in self-contained equipment do 

not have a noticeable impact on building heating and cooling loads. 

• DOE does not intend to further investigate the impact of improved efficiency 

on building heating and cooling loads.
Building Technologies Program 36 eere.energy.gov

LCC and PBP Analysis

Purpose & Methodology

Purpose

• Estimate financial impacts on individual (commercial) customers by 

calculating 

– Life-cycle cost savings

– Payback period

Methodology

• Life Cycle Cost: Equipment-installed price + operating costs over the 

equipment lifetime

– LCC savings: Base-case LCC minus standards-case LCC

• Payback Period: Equipment-installed price / first-year operating costs

• LCC is discounted; PBP is not discounted (“simple” PBP)
Building Technologies Program 37 eere.energy.gov

LCC and PBP Analysis

Analysis Flowchart
Building Technologies Program 38 eere.energy.gov

• Standards set in the 2009 CRE final rule go into effect on January 1, 2012.

• The baseline efficiency level will be altered in 2012 and will be different 

from the current (2010) market baseline efficiency level.

• In cases where current market baseline (obtained from the engineering 

analysis) was less efficient than the 2009 final rule standards or EPACT 

2005 standards, the corresponding standard was used as the market 

baseline – such a baseline level will be referred to as Standards Baseline.

• Consequently, engineering design option levels that are less efficient than 

standards baseline efficiency level were not considered for LCC and PBP 

analysis and NIA.

LCC and PBP Analysis 

Efficiency Levels – Effect of Current Standards

Item 4-1 DOE seeks comments on the methodology used to 

determine baseline efficiency levels for the preliminary analysis. 
Building Technologies Program 39 eere.energy.gov

• Current electricity prices based on EIA form 826 data

– Specific to state and sector

• Growth rates based on EIA’s Annual Energy Outlook (AEO) 

– Specific to sector and region of the country

• Both will be updated for the NOPR analysis

• Energy prices extended to building type using CBECs data

– Time-of-use pricing or marginal pricing were not used

LCC and PBP Analysis 

Electricity Prices 
Building Technologies Program 40 eere.energy.gov

• Installation costs

– Average: $2,106 for remote condensing and $790 for self contained

– Varied by state based on a state-level index developed using RS Means data

• Annualized repair costs based on replacement of major components. Inputs: 

– Probabilities of replacing components during product lifetime

– Original equipment manufacturer costs and equipment replacement 

markups (including labor) – repair costs vary with efficiency level.

• Annual maintenance costs

– Lighting maintenance costs

• Lights replaced based on rated lifetimes of the component (preventative)

• Combined with original equipment manufacturer costs, applied markups and 

annualized

– Preventative maintenance: assumed fixed values (RS Means data)

• $220 per year for remote condensing; $35 per year for self contained

LCC and PBP Analysis 

Installation, Maintenance and Repair Costs
Building Technologies Program 41 eere.energy.gov

LCC and PBP Analysis

Request for Comment

Item 4-2 DOE seeks comment on whether the maintenance and 

repair costs assumptions are reasonable and how maintenance and 

repair costs may vary with efficiency level. 

Item 4-3 DOE seeks comments on any additional sources that could 

be considered for maintenance, repair, and installation costs. 
Building Technologies Program 42 eere.energy.gov

• Discount Rates

– Real rates based on weighted average cost of capital (WACC) 

– Different rates by establishment type 

• Large Grocery and Multi-Line Retail Stores 

• Convenience Stores with Gas

• Convenience Stores and Small Food Sales

• Full Service and Limed Service Restaurants

• Other Food Service

• Lifetimes

– Average lifetime of 10 years was used for majority of the equipment

– Average lifetime of 15 years was used for equipment used in 

convenience and small food sales building types

LCC and PBP Analysis 

Discount Rates and Equipment Lifetimes
Building Technologies Program 43 eere.energy.gov

• Used Crystal Ball analyses to vary key inputs

– State, which changes

• Installation costs

• Markups (due to tax rates)

• Electricity Costs

– Building type, which changes

• Discount Rate

• Electricity Cost

– Equipment lifetimes (Weibull survival functions)

– Base-case efficiency level distribution

LCC and PBP Analysis 

Uncertainties in Input Values

Item 4-4 DOE seeks comments on inputs to the Crystal Ball 

simulations. 
Building Technologies Program 44 eere.energy.gov

LCC and PBP Analysis

Sample Results: VCT.SC.L Equipment Class

Efficiency 

Level

Energy 

Consumption

kWh/yr

2010$ Life-Cycle Cost Savings Payback 

Period years

Installed 

Cost

Total 

Discounted

Operating 

Cost

LCC Affected 

Customers’ 

Average 

Savings

2010$

% of Customers that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

1 11,936 5,832 13,657 19,489 NA NA NA NA NA 

2 11,441 5,845 13,200 19,045 445 0 87 13 0.28 

3 10,335 5,888 12,185 18,072 1,195 0 74 26 0.38 

4 7,314 6,117 9,362 15,480 3,369 0 60 40 0.66 

5 5,645 6,400 7,707 14,107 3,802 0 45 55 0.94 

6 5,042 6,593 7,155 13,748 3,357 0 30 70 1.15 

7 4,773 6,760 6,910 13,670 2,904 2 17 81 1.35 

8 4,550 7,459 6,701 14,159 2,064 34 5 61 2.30 

Summary of LCC and PBP analysis results for all the efficiency levels for the equipment class VCT.SC.L
Building Technologies Program 45 eere.energy.gov

Preliminary Manufacturer Impact Analysis; NOPR 

Analyses

Test Procedure

Certification, Compliance & Enforcement

Public Meeting Agenda

4

5

6

Markups Analysis; Energy Use Analysis; Life-Cycle 

Cost and Payback Period Analysis

2

Shipments Analysis; National Impact Analysis

3

1 Introduction and Overview

Market and Technology Assessment; Screening and 

Engineering Analysis

7

8 Closing Remarks
Building Technologies Program 46 eere.energy.gov

Shipments Analysis

Overview

Purpose

• Estimate future stock and shipments of commercial refrigeration equipment 

by equipment class

• Estimate efficiency mix of stock over time

Methodology

• Future shipments are based on historical shipments and growth rates 

based on commercial floor space construction forecast (from AEO 2010). 

• DOE estimated historical shipments data for the year 2009 using:

– Shipments for the year 2005 submitted by AHRI in prior rulemaking

– Freedonia Group, Inc. historical data

– North American Association of Food Equipment Manufacturers’ (NAFEM) 2008 

report

• Equipment stock was estimated based on the 2009 shipments data

• Projected stock and shipments were based on commercial floor space 

construction estimate data.
Building Technologies Program 47 eere.energy.gov

Shipments Analysis 

Results

• Shipments split between equipment classes using ratios from 2009 

shipments estimates

Equipment 

Class

Percentage of Linear 

Feet Shipped

Equipment 

Class

Percentage of Linear 

Feet Shipped

VOP.RC.M 10.81% SVO.SC.M 1.28%

VOP.RC.L 1.91% SOC.RC.M 2.45%

VOP.SC.M 0.86% HZO.RC.M 1.49%

VCT.RC.M 0.91% HZO.RC.L 4.69%

VCT.RC.L 12.64% HZO.SC.M 0.11%

VCT.SC.M 5.77% HZO.SC.L 0.23%

VCT.SC.L 2.93% HCT.SC.M 0.07%

VCT.SC.I 2.27% HCT.SC.L 0.00%

VCS.SC.M 17.30% HCT.SC.I 1.01%

VCS.SC.L 8.80% HCS.SC.M 5.22%

VCS.SC.I 0.08% HCS.SC.L 0.67%

SVO.RC.M 9.70% PD.SC.M 7.16%
Building Technologies Program 48 eere.energy.gov

Shipments Analysis 

Results

• Total estimated shipments displayed on the table below

– Shipments expressed and analyzed in terms of linear feet

Building Type Thousands of Linear Feet Shipped by Year and Equipment Class

2016 2020 2025 2030 2035 2040 2045 Total

Large Grocery

– New 291 338 360 384 406 435 467 11,564

– Replacement 1,042 1,169 1,224 1,395 1,502 1,685 1,833 42,279

Small Grocery

– New 86 100 106 113 120 128 138 3,414

– Replacement 301 294 323 338 352 385 411 10,276

Foodservice

– New 303 351 373 399 423 452 485 12,026

– Replacement 699 848 920 1,114 1,240 1,444 1,613 33,869

Total 2,722 3,099 3,307 3,742 4,043 4,530 4,947 113,429
Building Technologies Program 49 eere.energy.gov

Shipments Analysis 

Request for Comment

Item 5-1 DOE seeks comment on the sources and methodology for 

estimating historical shipments.
Building Technologies Program 50 eere.energy.gov

National Impact Analysis

Overview

Purpose

• To assess the impacts at the national level at each efficiency level as 

measured by

– National Energy Savings (NES)

– Net Present Value (NPV) of total customer economic impacts

Method

• For each year, for both the base case and standards cases, DOE calculates:

– National energy consumption (energy use per unit multiplied by total 

stock)

– Total consumer expenditures on commercial refrigeration equipment:

• National equipment expenditures

• National operation and maintenance costs

• Difference between base case and standards cases in each year gives NES and 

NPV of consumer economic impacts.

• Dollar values are discounted.
Building Technologies Program 51 eere.energy.gov

• Key inputs from upstream analyses 

– Stock and shipments (Shipments Analysis)

• NIA includes a module based on the EIA’s National Energy Modeling 

System (NEMS) to imitate consumer choices

• Module disaggregates total shipments into shipments by efficiency level

– Additional cost/energy use inputs (LCC and PBP Analysis)

• Annual electricity costs per refrigeration unit

• Installed cost per unit

• Annual operating costs other than energy costs per unit

National Impact Analysis 

Inputs from Upstream Analyses
Building Technologies Program 52 eere.energy.gov

• Discount Factor

– Used 7 percent and 3 percent real discount rates from the Office of 

Management and Budget’s Regulatory Analysis Guideline A-4

– Future expenses are discounted to present year (2011)

• Electricity Site-to-Source Conversion Factors

– Used to convert on-site energy consumption to primary (or source) 

energy generation

– Depend on variables such as:

• Time-varying generation mix

• Distribution and transmission losses

– For pre-analysis, used a factor developed for the 2009 CRE Rulemaking

– For NOPR, a new analysis will be performed using NEMS

National Impact Analysis 

Other Inputs
Building Technologies Program 53 eere.energy.gov

National Impact Analysis 

Results: National Energy Savings

Equipment 

Class

National Energy Savings (quads) by Standard Level

Level 2 Level 3 Level 4 Level 5 Level 6 Level 7 Level 8

VOP.RC.M 0.008 0.012 0.067 0.271 0.285 NA NA 

VOP.RC.L 0.005 0.023 0.031 NA NA NA NA 

VOP.SC.M 0.003 0.003 0.019 0.020 NA NA NA 

VCT.RC.M 0.001 0.001 0.013 0.013 0.014 NA NA 

VCT.RC.L 0.101 0.108 0.153 NA NA NA NA 

VCT.SC.M 0.004 0.067 0.072 0.092 0.100 0.101 0.113

VCT.SC.L 0.004 0.022 0.096 0.152 0.178 0.192 0.205

VCT.SC.I 0.004 0.014 0.016 0.017 0.025 0.027 0.040

VCS.SC.M 0.014 0.049 0.061 0.074 0.103 0.145 0.218

VCS.SC.L 0.011 0.038 0.054 0.071 0.092 0.135 0.207

VCS.SC.I 0.000 0.000 0.000 0.000 0.001 NA NA 

SVO.RC.M 0.005 0.030 0.034 0.161 0.170 NA NA 

SVO.SC.M 0.004 0.004 0.021 0.022 NA NA NA 

SOC.RC.M 0.000 0.002 0.002 0.029 0.029 0.031 NA 

HZO.RC.M 0.000 NA NA NA NA NA NA 

HZO.RC.L 0.001 0.015 NA NA NA NA NA 

HZO.SC.M 0.000 NA NA NA NA NA NA 

HZO.SC.L 0.001 NA NA NA NA NA NA 

HCT.SC.M 0.000 0.000 0.000 0.000 0.000 0.001 NA 

HCT.SC.L 0.000 0.000 0.000 0.000 0.000 0.000 NA 

HCT.SC.I 0.000 0.001 0.002 0.009 NA NA NA 

HCS.SC.M 0.001 0.003 0.003 0.004 0.013 NA NA 

HCS.SC.L 0.000 0.001 0.001 0.002 0.006 NA NA 

PD.SC.M 0.041 0.096 0.098 0.111 0.127 0.152 0.180
Building Technologies Program 54 eere.energy.gov

Preliminary Manufacturer Impact Analysis; NOPR 

Analyses

Test Procedure

Certification, Compliance & Enforcement

Public Meeting Agenda

4

5

6

Markups Analysis; Energy Use Analysis; Life-Cycle 

Cost and Payback Period Analysis

2

Shipments Analysis; National Impact Analysis

3

1 Introduction and Overview

Market and Technology Assessment; Screening and 

Engineering Analysis

7

8 Closing Remarks
Building Technologies Program 55 eere.energy.gov

Manufacturer Impact Analysis

Overview

Purpose

• To identify the impacts of amended energy conservation standards on 

manufacturers.

• Key output of MIA is the change in industry net present value (INPV) due to 

amended standards.

• The MIA consists of three phases:

Industry 

profile

Develop 

straw-man 

GRIM

Develop 

interview 

guide

Interviews

& 

industrywide / 

subgroup

analyses

Assess direct 

employment, 

competition, & 

cumulative 

burden

Phase 1 Phase 2 Phase 3
Building Technologies Program 56 eere.energy.gov

Manufacturer Impact Analysis

Overview

Phase 1

• DOE creates an industry profile to characterize the industry and identify important 

issues that require consideration.

Phase 2

• DOE prepares an industry cash-flow model and an interview questionnaire to guide 

subsequent discussions.

Phase 3

• DOE interviews manufacturers and assesses the impacts of amended standards both 

quantitatively (using the Government Regulatory Impact Model) and qualitatively 

(impacts on competition, manufacturing capacity, employment, and regulatory 

burden).

Industry 

profile

Develop 

straw-man 

GRIM

Develop 

interview 

guide

Interviews

& 

industrywide / 

subgroup

analyses

Assess direct 

employment, 

competition, & 

cumulative 

burden 

Phase 1 Phase 2 Phase 3
Building Technologies Program 57 eere.energy.gov

Preliminary Manufacturer Impact Analysis

Key Issues

• Testing Burden

– Testing costs may lead industry to trim product lines and limit customization

• Potential changes in refrigerant 

– Potential regulation impacting the availability and cost of HFC refrigerants could 

dramatically increase the cost of complying with an energy conservation standard

• Conflicts with other certification testing parameters 

– Lack of harmonization between food safety standard testing and DOE energy 

standard testing leads to additional costs

• Impacts on small manufacturers

– Small manufacturers may not necessarily offer fewer models than larger 

manufacturers but do have fewer resources for testing
Building Technologies Program 58 eere.energy.gov

Preliminary Manufacturer Impact Analysis

Request for Comment

Item 7-1 DOE requests comment on its identification of key issues 

and requests data and information from interested parties that can 

assist in evaluating the potential impact on manufacturers.

Item 7-2 DOE invites comment on regulations applicable to 

commercial refrigeration manufacturers that contribute to their 

cumulative regulatory burden. 
Building Technologies Program 59 eere.energy.gov

NOPR Analyses

Environmental 

Assessment

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Regulatory

Impact 

Analysis

Revise

Preliminary

Analysis

NOPR Final 

Rule

Framework

Document

Preliminary 

Analysis
Building Technologies Program 60 eere.energy.gov

NOPR Analyses

Overview

• LCC Subgroup Analysis

– Effects on various national consumer subgroups

• Manufacturer Impact Analysis

– Continue work begun in the preliminary MIA

• Utility Impact Analysis

– Effects on generation capacity of utilities

• Employment Impact Analysis

– Indirect effects on national employment

• Environmental Assessment

– Effects on airborne pollutant emissions

• Regulatory Impact Analysis

– Potential for non-regulatory approaches
Building Technologies Program 61 eere.energy.gov

Preliminary Manufacturer Impact Analysis; NOPR 

Analyses

Test Procedure

Certification, Compliance & Enforcement

Public Meeting Agenda

4

5

6

Markups Analysis; Energy Use Analysis; Life-Cycle 

Cost and Payback Period Analysis

2

Shipments Analysis; National Impact Analysis

3

1 Introduction and Overview

Market and Technology Assessment; Screening and 

Engineering Analysis

7

8 Closing Remarks
Building Technologies Program 62 eere.energy.gov

Test Procedure

Current CRE Test Procedure

• On December 8, 2006, DOE established 

the current test procedure for 

commercial refrigeration equipment, 

which references the Air-Conditioning 

and Refrigeration Institute (ARI) 

Standard 1200-2006.

– ARI 1200-2006 references ASHRAE 

Standard 72-2005 as the method 

of test.

• DOE adopted AHAM Standard HRF-1-

2004 for measuring refrigerated 

compartment volume. 71 FR 71370 

(Dec. 8, 2006). 
Building Technologies Program 63 eere.energy.gov

Test Procedure

Current CRE Test Procedure

• The current DOE test procedure contains the following rating temperatures:

• The current test procedures for commercial refrigeration equipment appear 

under Title 10 of the Code of Federal Regulations part 431, subpart C.

Equipment Rating Temperature

Commercial refrigerators and 

refrigerator compartments 38 °F (±2 °F)

Commercial freezers and 

freezer compartments 0 °F (±2 °F)

Commercial ice-cream 

freezers -15 °F (±2 °F)
Building Technologies Program 64 eere.energy.gov

DOE is amending the test procedure for commercial refrigeration equipment 

in a separate rulemaking (EERE-2010-BT-TP-0034) that proposes to:

1) Update referenced industry test procedures to the most current 

versions:

– AHRI Standard 1200-2010

– AHAM Standard HRF-1-2008

2) Incorporate provisions to address certain energy conservation 

features that are currently not accounted for in the DOE test 

procedure:

– Night curtains

– Lighting occupancy sensors and scheduled controls

3) Allow commercial refrigeration equipment that cannot be tested at 

the 38 °F rating temperature to be tested at its lowest application 

product temperature.

Test Procedure

Proposed TP Amendments
Building Technologies Program 65 eere.energy.gov

Test Procedure

Night Curtains

• DOE proposes to use the following test method, adapted from section 7.2 in 

ASHRAE Standard 72-2005, “Door-Opening Requirements”:

Night Curtain Requirements. For open display cases sold with night 

curtains installed, the night curtain shall be employed according to 

manufacturer instructions for a total of 6 hours, 3 hours after the start of 

a defrost period. Upon the completion of the 6-hour period, the night 

curtain shall be raised until the completion of the 24-hour test period.

Night Curtain Proposed Test Method
Building Technologies Program 66 eere.energy.gov

Test Procedure

Lighting Occupancy Sensors and Scheduled Controls

The proposed lighting occupancy sensor consists of 3 primary calculations: 

1. Calculate direct energy use of lighting with occupancy sensors or scheduled 

controls installed. 

– Requires default specifications for the time lighting is off or dimmed due to 

lighting occupancy sensors or scheduled controls.

2. Calculate reduced refrigeration load when energy use of lights within the 

refrigerated volume is decreased. 

– Requires default specifications for the EER of the compressor and to account for 

the fact that not all of the heat produced from the lights will impact the 

compressor load.

3. Calculate the adjusted daily energy consumption based on the decreased 

lighting energy use and decreased compressor energy use.

Lighting Occupancy Sensor and Scheduled Controls 

Proposed Test Method
Building Technologies Program 67 eere.energy.gov

Test Procedure

Lighting Occupancy Sensors and Scheduled Controls

• The time off period for scheduled controls was chosen to approximate the 

typical usage of lighting control products based on comments received during 

previous DOE rulemakings for this equipment.

• The time off period for lighting occupancy sensors was derived based on the 

previously cited demonstration project conducted through the DOE GATEWAY 

program.

Case has...

Only scheduled 

lighting controls 

installed

Only lighting 

occupancy sensors

installed

Both lighting 

occupancy sensors 

and scheduled 

controls installed

Times are... toff,controls + tdim,controls= 

8 hours

toff,sensors + 

tdim,sensors= 10.8 hours

toff,controls + 

tdim,controls= 8 hours

AND

toff,sensors + 

tdim,sensors= 2.8 hours

Determination of toff and tdim
Building Technologies Program 68 eere.energy.gov

• Note: The CECA includes a multiplication factor of 0.75 to account for the fact that not all of the heat 

produced from the lights will impact the compressor load. 

li l

sc

A

(P t

1000 3.4121 (LEC

)

CEC 0.75

EER

× ) × −

= × Eq. 4

Operating Temperature 

Class

EER1,2

Btu/W

Medium 11.26

Low 7.14

Ice Cream 4.80

Note:

1. EER values for operating temperature classes are calculated 

based on the average EER value of all equipment in that class 

which was analyzed as part of the previous (2009) rulemaking. 

2. These values only represent compressor EER and do not include 

condenser fan energy use. 

• EER for Self-Contained Commercial Refrigerated Display Merchandisers and Storage 

Cabinets

Calculation of Alternate Compressor Energy Consumption

• EER for Remote Condensing Commercial Refrigerated Display Merchandisers and 

Storage Cabinets

= Table 1. in AHRI 1200-2010

Test Procedure

Lighting Occupancy Sensors and Scheduled Controls
Building Technologies Program 69 eere.energy.gov

Preliminary Manufacturer Impact Analysis; NOPR 

Analyses

Test Procedure

Certification, Compliance & Enforcement

Public Meeting Agenda

4

5

6

Markups Analysis; Energy Use Analysis; Life-Cycle 

Cost and Payback Period Analysis

2

Shipments Analysis; National Impact Analysis

3

1 Introduction and Overview

Market and Technology Assessment; Screening and 

Engineering Analysis

7

8 Closing Remarks
Building Technologies Program 70 eere.energy.gov

Certification, Compliance & Enforcement

Basic Model Explanation

A Basic Model

• May contain multiple models/model numbers.

• Is manufactured by a single manufacturer, although it may 

be distributed under different brand names.

• Is made up of models that contain the same primary 

energy source (i.e., electric, gas).

• Is made up of models that have essentially identical 

electrical, physical and functional characteristics that affect 

energy consumption and/or efficiency.

• May not contain models from multiple product classes.

• Can be made up of only one model. There is no 

requirement for multiple models within a basic model.

• Must contain individual certified ratings that are identical 

and must be based on the least efficient model.
Building Technologies Program 71 eere.energy.gov

Certification, Compliance & Enforcement

How To Get Certified Ratings

Generate Certified Rating

Determine Minimum and Maximum Rating Values

The Certified Rating Must be < The Mean or the UCL, Whichever is Lower

Calculate the Product Specific Certification Statistics, 429.42

CRE Sample Mean (x) Upper Confidence Limit (UCL)

Determine which Federal Conservation Standards Apply to the Product

Commercial Refrigeration Equipment: 431.66

Test At Least Two Units of a Basic Model Using the DOE Test Procedure

(Maximum Number of Units is at the Discretion of the Manufacturer)
Building Technologies Program 72 eere.energy.gov

Certification, Compliance & Enforcement

Certification Requirements

• Current effective date for compliance with certification provisions is July 5, 

2011.

• Only electronic submission accepted. Submit online at 

https://www.regulations.doe.gov/ccms.

• Use product-specific, Excel templates provided by DOE.

• Submit certification report before distribution in commerce for all new 

models.

• Annual submittal of carry-over products on or before the 1st of the month 

specified in the annual certification table (429.12(d)).

• No additional certification testing required for annual submission.

• Recertify if the redesign of an existing model increases energy 

consumption resulting in re-rating.
Building Technologies Program 73 eere.energy.gov

Certification, Compliance & Enforcement

New Initiatives

Request for 

Information on 

Alternative Methods of 

Determining Efficiency 

Issued April 8, 2011

DOE seeks comment and data:

• Current procedures used by industry to rate lowvolume, custom built commercial equipment;

• Current applications of DOE’s AEDM/ARM 

procedures;

• Products to which AEDM/ARM should apply;

• Data to demonstrate ability of AEDM/ARM to 

estimate energy efficiency/consumption; and

• Procedures governing substantiation and 

verification of AEDMs and ARMs.
Building Technologies Program 74 eere.energy.gov

Certification, Compliance & Enforcement

New Initiatives (cont.)

Notice of Proposed 

Rulemaking on the 

Compliance Date for 

Certification Provisions 

Applicable to Certain 

Types of Commercial 

Equipment Issued April 

12, 2011

DOE seeks comment and data:

• Proposed a tentative 18-month compliance date 

extension for the certification provisions for 

commercial refrigeration equipment; commercial 

heating, ventilating, air-conditioning (HVAC) 

equipment; commercial water-heating equipment; 

walk-in coolers; walk-in freezers; and automatic 

commercial ice-making equipment;

• Considering extending the compliance date for 

other commercial equipment based on comments 

and data; and

• Considering longer/shorter date extension based 

on comments and data.
Building Technologies Program 75 eere.energy.gov

Certification, Compliance & Enforcement

Questions / Information

Submit a Question: • DOE Test Procedure Website:

http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1

• Ashley Armstrong: Ashley.Armstrong@EE.Doe.Gov

Request a Test 

Procedure Waiver:

• DOE’s regulations allow manufacturers to apply for a waiver when 

a manufacturer determines that a given basic model contains one 

or more design features that prevent testing in accordance with 

DOE’s test procedure. 

• Email: AS_Waiver_Requests@ee.doe.gov 

File a Complaint: Email: energyefficiencyenforcement@hq.doe.gov.

The Office of Enforcement will protect the identity of complainants to 

the maximum extent permitted by law. 

DOE’s Certification, 

Compliance, and 

Enforcement Website: 

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

on_enforcement.html

DOE’s Online 

Certification System:

https://www.regulations.doe.gov/ccms/ 

Enforcement Information: http://gc.doe.gov/energy_efficiency_enforcement.htm 
Building Technologies Program 76 eere.energy.gov

Preliminary Manufacturer Impact Analysis; NOPR 

Analyses

Test Procedure

Certification, Compliance & Enforcement

Public Meeting Agenda

4

5

6

Markups Analysis; Energy Use Analysis; Life-Cycle 

Cost and Payback Period Analysis

2

Shipments Analysis; National Impact Analysis

3

1 Introduction and Overview

Market and Technology Assessment; Screening and 

Engineering Analysis

7

8 Closing Remarks
Building Technologies Program 77 eere.energy.gov

Closing Remarks

DOE welcomes any closing remarks from interested parties.
Building Technologies Program 78 eere.energy.gov

Contact Information for Feedback

In all correspondence, please refer to the Commercial Refrigeration Equipment Energy 

Conservation Standards rulemaking by:

– Commercial Refrigeration Equipment Rulemaking,

– Docket Number EERE-2010-BT-STD-0003, and

– Regulatory Identification Number (RIN) 1904-AC19

Email: CRE-2010-STD-0003@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Mailstop: EE-2J, Room 1J-018

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 6th Floor

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202-586-2945

Comment period ends May 16, 2011
Building Technologies Program 79 eere.energy.gov

Relevant Webpages

• DOE Appliance Standards

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

• Commercial Refrigeration Equipment Rule

– http://www2.eere.energy.gov/buildings/appliance_standards/commercial/refrig

eration_equipment.html

• Contact Charles Llenza, Project Manager, from the Appliance Standards Program 

for additional information: 

– Charles.Llenza@ee.doe.gov

– 202.586.2192

• Contact John Cymbalsky, Supervisor, from the Appliance Standards Program for 

additional information: 

– John.Cymbalsky@ee.doe.gov

– 202.287.1692
Building Technologies Program 80 eere.energy.gov

Backup Slides
Building Technologies Program 81 eere.energy.gov

List of Requests for Comment

Item 2-1 DOE seeks comment on the equipment class nomenclature and on the appropriateness of 

the stated equipment classes for classifying the commercial refrigeration equipment 

market. 

Item 2-2 DOE asks interested parties to comment on other technologies that DOE should consider.

Item 2-3 DOE seeks comment on its energy consumption model and engineering approach for 

analyzing commercial refrigeration equipment.

Item 2-4 DOE seeks comment on its costs, markup, and outbound freight methodologies.

Item 3-1 DOE seeks comment on the weighting factors for the three distribution channels.

Item 3-2 DOE seeks comment on the methodology and assumptions used for the markups analysis.

Item 4-1 DOE seeks comments on the methodology used to determine baseline efficiency levels for 

the preliminary analysis. 

Item 4-2 DOE seeks comment on whether the maintenance and repair costs assumptions are 

reasonable and how maintenance and repair costs may vary with efficiency level. 

Item 4-3 DOE seeks comments on any additional sources that could be considered for maintenance, 

repair, and installation costs. 

Item 4-4 DOE seeks comments on inputs to the Crystal Ball simulations. 

Item 5-1 DOE seeks comment on the sources and methodology for estimating historical shipments.
Building Technologies Program 82 eere.energy.gov

List of Requests for Comment (Cont.)

Item 7-1 DOE requests comment on its identification of key issues and requests data and information 

from interested parties that can assist in evaluating the potential impact on manufacturers.

Item 7-2 DOE invites comment on regulations applicable to commercial refrigeration manufacturers 

that contribute to their cumulative regulatory burden.