After a regulatory action has been completed, Executive Order 12866 requires agencies to 

identify the substantive changes between the draft submitted to Office of Information and 

Regulatory Affairs (OIRA) for review and the action subsequently announced, and to identify 

those changes made at the suggestion or recommendation of OIRA.
[6450-01-P]

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. 

1
DATES: The effective date of this rule is [INSERT DATE 60 DAYS DATE OF 

PUBLICATIONIN THE FEDERAL REGISTER]. Compliance with the amended standards 

established for walk-in coolers and walk-in freezers in today’s final rule is required on

[COMPLIANCE DATE].

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-STD-0003.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: 

2
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. E-mail: 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

3
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

4
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

5
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

6
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

7
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

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 Sub-Group

8
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

9
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, Pub. L. 94-163 (42 U.S.C. 6311-6317, as codified), added by 

Pub. L. 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 

1 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).

2 For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1.

10

 
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 (walkins), refrigeration systems, panels, and doors. The amended standards are in terms of annual 

walk-in energy factor (AWEF) for the walk-in refrigeration systems, R-value for walk-in panels, 

and maximum energy consumption (MEC) for walk-in doors. These standards are shown in 

Table I.1. These amended standards apply to all equipment listed in Table I.1 and manufactured 

in, or imported into, the United States on or after [INSERT DATE].

Table I.1. Energy Conservation Standards for Walk-in Coolers and Walk-in Freezers

(Compliance Required Starting [INSERT DATE])

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 DC.L.I, 3.10

11
Temperature, Indoor System, ≥ 

9,000 Btu/h Capacity

≥ 9,000

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 28

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

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 today’s 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.

12
Table I.2 Impacts of Today’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 

refrigeration3, DOE estimates that the INPV for manufacturers of walk-in coolers and walk-in 

freezers is $1,291 million in 2012$. Under today’s standards, DOE expects the industry net 

present value to change by -4.10 percent to 6.21 percent. Total industry conversion costs are 

3 These 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.

13

 
expected to total $33.61 million. DOE does not expect any plant closings or significant loss of 

employment to result from today’s standards.

C. National Benefits4

DOE’s analyses indicate that today’s 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 today’s 

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 increased equipment costs for 

equipment purchased in 2016–2047.

In addition, today’s 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 

4 All monetary values in this section are expressed in 2013 dollars and are discounted to 2014. 5 A metric ton is equivalent to 1.1 short tons. Results for NOX and Hg are presented in short tons.

14

 
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 

today’s standards for walk-in coolers and walk-in freezers.

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.

7 Technical 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.

15

 
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

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 today’s 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 

16
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 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 today’s 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 

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.

17

 
with the average SCC series that uses a 3-percent discount rate, the cost of the standards in 

today’s 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 today’s 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.

18
Table I.4 Annualized Benefits and Costs of Amended Standards for Walk-in Coolers and 

Walk-in Freezers

Discount 

Rate

Primary 

Estimate*

Low Net 

Benefits 

Estimate*

High Net 

Benefits 

Estimate*

million 2013$/year

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.

19
** 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 today’s final rule represent the 

maximum 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 today’s 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, Pub. L. 94-163 (42 U.S.C. 6311-6317, as codified), added by 

Pub. L. 95-619, Title IV, section 441(a), established the Energy Conservation Program for 

Certain Industrial Equipment, a program covering certain industrial equipment, which includes 

20
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, Pub. L. No. 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 walk-ins 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).

10 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).

11 For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1.

21

 
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))

22
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 performance-related 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 

23
factors DOE deems appropriate. In a rule prescribing such a standard, DOE typically includes an 

explanation of the basis on which such higher or lower level was established. DOE plans to 

follow a similar process in the context of today’s rulemaking.

DOE notes that since the inception of the statutory requirements setting standards for 

walk-ins, Congress has since made one additional amendment to those provisions. That 

amendment provides that the wall, ceiling, and door insulation requirements detailed in 42 

U.S.C. 6313(f)(1)(C) do not apply to the given component if the component’s manufacturer has 

demonstrated to the Secretary’s satisfaction that “the component reduces energy consumption at 

least as much” if those specified requirements were to apply to that manufacturer’s component. 

American Energy Manufacturing Technology Corrections Act, Pub. L. No. 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 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.

24
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.

25
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; less-efficacious 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 

26
three-phase 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-BT-STD-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 double-pane 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).

27
2. History of Standards Rulemaking for Walk-in Coolers and Walk-in Freezers

EPCA directs the Secretary to issue performance-based standards for walk-ins 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, 

28
baseline units, and design options to improve efficiency; and (5) life-cycle costs to consumers, 

including installation, maintenance, and repair costs, and any consumer subgroups DOE should 

consider. At the meeting and during the comment period on the framework document, DOE 

received many comments that helped it identify and resolve issues pertaining to walk-ins 

relevant to this rulemaking. 

DOE then gathered additional information and performed preliminary analyses to help 

develop potential energy conservation standards for this equipment. This process culminated in 

DOE’s announcement of another public meeting to discuss and receive comments on the 

following matters: (1) the equipment classes DOE planned to analyze; (2) the analytical 

framework, models, and tools that DOE used to evaluate standards; (3) the results of the 

preliminary analyses performed by DOE; and (4) potential standard levels that DOE could 

consider. 75 FR 17080 (April 5, 2010) (the April 2010 Notice). DOE also invited written 

comments on these subjects and announced the availability on its website 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 

29
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 walkin 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 walkin coolers and walk-in 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 walkin 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 walk30
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 walk-in 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. Today’s final rule responds to the issues raised by 

31
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 website 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 website 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.

32
Table II.1 Energy Conservation Standards Proposed for Walk-in Coolers and Walk-in 

Freezers (for compliance in [INSERT DATE])

Class Descriptor Class Proposed 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 2.63 10 4.53 4 × × + − Q

Dedicated Condensing, 

Medium Temperature, Indoor 

System, ≥ 9,000 Btu/h 

Capacity

DC.M.I, ≥ 

9,000 6.90

Dedicated Condensing, 

Medium Temperature, 

Outdoor System, < 9,000 

Btu/h Capacity

DC.M.O, 

< 9,000

Dedicated Condensing, 

Medium Temperature, 

Outdoor System, ≥ 9,000 

Btu/h Capacity

DC.M.O, 

≥ 9,000 12.21

Dedicated Condensing, Low 

Temperature, Indoor System, 

< 9,000 Btu/h Capacity

DC.L.I, < 

9,000 1.93 10 1.89 4 × × + − Q

Dedicated Condensing, Low 

Temperature, Indoor System, 

≥ 9,000 Btu/h Capacity

DC.L.I, ≥

9,000 3.63

Dedicated Condensing, Low 

Temperature, Outdoor System, 

< 9,000 Btu/h Capacity

DC.L.O, < 

9,000

Dedicated Condensing, Low 

Temperature, Outdoor System, 

≥ 9,000 Btu/h Capacity

DC.L.O, ≥

9,000 6.15

Multiplex Condensing, 

Medium Temperature MC.M 10.74

Multiplex Condensing, Low 

Temperature MC.L 5.53

Panels Maximum R-Value(h-ft2-°F/Btu)**

Structural Panel, Medium 

Temperature SP.M 28

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

Display Doors Maximum Energy Consumption (kWh/day)††

Display Door, Medium 

Temperature DD.M 0.04 × Add + 0.41

1.34 10 0.12 3 × × + − Q

5.70 10 1.02 4 × × + − Q

33
Display Door, Low 

Temperature DD.L 0.15 × Add + 0.29

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 today’s notice.

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

34
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 *

35
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 walk-ins. Nor-Lake, Kysor, and Louisville Cooler agreed with this

approach. (Nor-Lake, 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 

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 

36
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 under-performing 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, 

37
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 

XXXXX (April XX, 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 non-floor panels. A display panel is defined as a panel 

that is entirely or partially comprised of glass, a transparent material, or both, and is used for 

display purposes. Id. It is considered equivalent to a window and the U-factor is determined by 

NFRC 100-2010-E0A1, “Procedure for Determining Fenestration Product U-factors.” 76 FR at 

38
33639. Floor panels are used for walk-in 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 

XX, which proposed certain simplifications to the current procedure. [Reference] Specifically, 

under this approach, manufacturers would no longer need to use the performance-based test 

procedures for WICF floor and non-floor panels, which include ASTM C1363, DIN EN 13164, 

39
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, 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 kilowatt-hours 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 

40
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) NorLake 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. (NorLake, 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 

R-value 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 

41
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 

42
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 WalkIn 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.

43
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, 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 

44
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 

45
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 XXXXX, XXXXX (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 

46
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 

47
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 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 

48
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)

49
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. 

[Add citation to TP rulemaking.] 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 

50
of WICF component parts is often performed by independent heating, ventilation, airconditioning, 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)

51
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 walk-in 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 FR XXXXX. 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 

52
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 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, 

53
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-

54
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 full-fuel-cycle energy savings. 76 FR 51282 (August 18, 

2011), as amended at 77 FR 49701 (August 17, 2012). The full-fuel-cycle (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 

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.

55

 
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 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 today’s 

13 “Review of Site (Point-of-Use) and Full-Fuel-Cycle 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.

56

 
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 period14). 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 

14 DOE also presents a sensitivity analysis that considers impacts for equipment shipped in a 9-year period. 

57

 
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, 

58
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 today’s final rule would reduce the utility or performance of the equipment 

59
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 today's 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 the Nation’s energy system. Reductions in the demand for electricity 

60
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 today’s 

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 

61
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 

62
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 

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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 

64
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 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. (ebm-papst, 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 

65
today’s rule. For details regarding the separate analysis and certification of refrigeration system 

components, see [add citation to the TP final rule, when it’s available.]

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 

66
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. (Thermo-Kool, 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, 

67
the Department expected that setting an R-value 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 walk-in that are built 

inside another walk-in. American Panel noted that for cooler-freezer 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, 

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NEEA, et al., Hussmann, ACEEE, American Panel, the California IOU’s, Heatcraft, Bally, 

Hillphoenix, Lennox, AHRI and Nor-Lake 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 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 walk-in, 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 

69
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 

today’s 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 low-profile unit coolers. (ebm-papst, No. 92 at p. 4)

NCC and KeepRite commented that two-way or low-velocity coolers were designed as foodprocessing 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 

70
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 

71
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 walk-in 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 

72
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 performancerelated 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.

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. 

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Structural panels are further divided into two more classes based on temperature -- i.e., 

cooler versus freezer panels. Cooler structural panels are rated with their internal faces exposed 

to a temperature of 35°F, as required in the test procedure. Freezer structural panels are used in 

walk-in freezers and rated with its internal face exposed to a temperature of -10°F, also a test 

procedure requirement. See 76 FR at 21606 (codified at 10 CFR 431.303). 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 non-display doors. DOE proposed separate classes for display doors and non-display 

doors to retain consistency with the dual approach laid out by EPCA for these walk-in 

components. (42 U.S.C. 6313(f)(1)(C) and (3)) 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. 

74
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.

(Nor-Lake, 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 non-hinged 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

75
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

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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)

77
DOE takes note of manufacturer comments that the representative sizes in DOE’s 

analysis do not fully 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 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.

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 

78
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 

79
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 today’s notice, 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

80
≥ 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

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 

81
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 

82
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 walk-in 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 was feasible. 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 its market analyses relied, 

at least in part, on a number of products models utilizing the increased foam wall thicknesses 

depicted in its modeling. Since manufacturers are already employing these wall thicknesses in

currently-available models, DOE believes that fact demonstrates that the changes in insulation 

thickness would be a viable means to increase efficiency performance, and therefore the 

83
Department has applied that technique as an option for manufacturers to use when we 

determined the appropriate standards to set in today’s rule.

In the NOPR, DOE proposed to screen in the following technologies for non-display 

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 high-efficiency 

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 Califorina 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 

84
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 today’s 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 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.

85
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. 

86
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 S C S 8 1.5

M 8 4

87
Members 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 nondisplay 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

F

S 8 5

M 9 7

L 12 7

88
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 walk-in 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 

15 Scroll compressors are compressors that operate using two interlocking, rotating scrolls that compress the 

refrigerant. Hermetic and semi-hermetic 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.

89

 
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. AHRI commented that future changes in 

90
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 low-GWP 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 

91
be needed for standard-setting 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 phasedown 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. 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 

Comment [mk1]: Change made at OMB’s 

request.

92
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 

93
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 websites 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. 

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 

94
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 

95
$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 NonFloor panels 

$/ft2

Material/Labor Cost for 

Floor Panels 

$/ft2

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 characterized 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 NonFloor panels 

$/ft2

Material/Labor Cost for 

Floor Panels 

$/ft2

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 

96
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 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

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 

97
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 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 commented and accounted for a square footage limit in the shipping costs. 

98
4. 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 walk-in 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-STD-0015

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.

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a. Panels and Doors

In 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 nondisplay doors. This thermal resistance accounted for the aging of insulation when measuring 

walk-in panel performance. See 76 FR at 21612. DOE proposed in the a separate rulemaking to 

eliminate the long term thermal aging test procedure and therefore modeled the R-value of 

insulation as 8 ft-h-°F/Btu-in. DOE also received a comment on the thermal resistance used in 

the non-display 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 a 

impact on the door’s performance. In the final rule analysis, DOE modeled 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 nondisplay 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 

100
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 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 

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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 

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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 temperature-terminated 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 

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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 low-temperature 

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.

5. 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 

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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)

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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 for walk-in panels. 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 cost of a panel. However, for non-display 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 walk-in market. (Arctic, Public Meeting 

Transcript, No. 88 at p. 126) US Cooler also commented that a sizeable number 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. DOE continues to use one type of 

insulation material (i.e. poured-in-place polyurethane) in its analysis in order to more accurately 

evaluate the energy consumption of walk-in panel. DOE notes that manufacturers can use any 

insulation or other features so long as they meet the energy conservation standard levels required 

by today’s notice of final rule. 

106
In today’s final rule, a baseline cooler structural panel was 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’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-in-place 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. (Nor-Lake, 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. 

Comment [mk2]: Change made per OMB 

request.

107
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 nondisplay 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 

continues to model walk-in cooler doors with windows. 

At the public meeting Bally noted that sometimes, consumers chose 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 non-display 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. 

108
Nor-Lake expressed concern that DOE misinterpreted EPCA’s requirements for windows 

in non-display doors, but offer specific details as to why 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 antisweat heater wire. From an engineering perspective, DOE does not see why windows in nondisplay doors would be significantly different from the glass packets used in display doors. DOE 

received no other comments stating that windows in freezer non-displays would lose all gas fill 

due to anti-sweat heater wire and therefore continues to use both design features in its 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. 

109
Thermo-Kool commented that the Department’s baseline for panel and doors was 

accurate. (Thermo-Kool, No. 97 at p.2) US Cooler noted that DOE considered heater wire in 

doors that was 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. 

b. Refrigeration

DOE determined baseline characteristics for refrigeration systems based on typical lowcost, low-efficiency 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.

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. 

110
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 temperature16 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

Evaporator

Application Temperature of Air 

Entering the Evaporator 

Coil (°F)

Saturated Evaporating 

Temperature (SET) (°F)

Temperature Difference 

(TD) Between Entering 

Air and SET (°F)

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

16 For a refrigerant for which the temperature increases as more of it boils, increasing the proportion of vapor, the 

dew point is the temperature in this boiling process associated with nearly 100% vapor, just before the last liquid 

droplets boils off.

111

 
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):

Table IV.11 Saturation Temperatures Observed During Testing

Evaporator

Unit Tested Temperature of Air 

Entering the Evaporator 

Coil (°F)

Saturated Evaporating 

Temperature (SET) (°F)

Temperature Difference 

(TD) Between Entering 

Air and SET (°F)

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

Condenser

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

112
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.

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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

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• 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 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 4 inches to 5 inches and 6 inches. NorLake 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 4inch 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. (Nor-lake, No. 115 at p. 1; Manitowoc, No. 

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 continue 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). Nor-Lake commented that vacuuminsulated 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 

115
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 today’s notice.

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 

116
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 low-emissivity 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.

117
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.

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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 demand-defrost systems may vary widely 

depending on the control mechanism; however, given the range of stakeholder comments it has 

119
received on the issue, believes an 80 percent reduction is too aggressive. DOE notes that its 

recently adopted approach with respect to the measurement of refrigeration system performance

[cite final rule when ready], 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 

120
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, Regal-Beloit noted that three-phase motors and multihorsepower ECMs could greatly improve unit efficiency. ebm-papst also commented that 

evaporator fans for WICFs did not necessarily have to be axial fans and that other types of airmoving devices, such as backward curved motorized impellers, may be a more efficient choice 

for certain refrigeration systems due to their aerodynamic characteristics. (ebm-papst, 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 

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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 

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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 

123
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. 

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 

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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 

125
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 highload 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. 

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For today’s 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. 

127
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 highload 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 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. 

128
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 walk-in coolers and 18 hours for walk-in freezers (Manitowoc, No. 

108; at p. 3).

129
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, non-display 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 

130
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.

131
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 today’s final rule. 

132
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.

• Includes a factor for 

estimating equipment 

price trends due to 

manufacturer experience.

• 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.

Installation 

Costs

Based on RS Means Mechanical 

Cost Data 2012. Assumed no 

change with efficiency level.

No change

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.

• Refrigerant recharge cost 

set at $0.

Increased refrigerant recharge cost to 

$500, to reflect industry practice,

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.

Comment [mk3]: Change made per OMB 

request.

133
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 

17 Bureau of Labor Statistics, Producer Price Index Industry Data, Series: PCU3334153334153

134

 
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 201218. Refrigeration 

system installation costs included separate installation costs for the condensing unit and unit 

18 Reed Construction Data, RSMeans Mechanical Cost Data 2012 Book, 2012

135

 
cooler. DOE continued with this approach for refrigeration systems in preparing today’s 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 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 Code19 (IBC) 

requires sprinkler systems and other fire safety criteria regardless of panel thickness.20 Therefore, 

19 International Code Council, Inc., International Building Code, 2012, ISBN: 978-1-60983-040-3

136

 
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, 201322. 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

20 Section 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. 21 Section 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 .

22 Reed Construction Data, RSMeans Facilities Maintenance & Repair 2013 Cost Data Book, 2013.

137

 
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 today’s 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 nondisplay 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; NorLake, 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.

23 Reed Construction Data, RSMeans Facilities Maintenance & Repair 2013 Cost Data Book, 2013

138

 
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 

24 U.S. Energy Information Administration. EIA-826 Sales and Revenue Spreadsheets. (Last accessed May 16, 

2012). www.eia.doe.gov/cneaf/electricity/page/eia826.html

139

 
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)

25 The 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.

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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 (Nor-Lake, 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 end-of-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. 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) 

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Based on the stakeholder comments, DOE revised its lifetime estimates for today’s 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 (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. 

26 The 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. 

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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 basecase efficiency distribution. 

27 Harris, R.S. Applying the Capital Asset Pricing Model. UVA-F-1456. Available at SSRN: 

http://ssrn.com/abstract=909893.

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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 higher-efficiency (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 

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on DOE’s estimate of base-case 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 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 

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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 

more-efficient, 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).

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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 

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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. 

28 North American Association of Food Equipment Manufacturers. 2012 Size and Shape of Industry. Chicago, IL.

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DOE received no comments on the above estimates, and for today’s 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 

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 today’s rule.

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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 

(Thermo-Kool, 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 today’s 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 base-case projections 

with standards-case projections. The base-case projections characterize energy use and customer 

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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. 

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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 shipment-weighted 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 

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estimated energy savings. DOE did not incorporate a rebound factor for walk-ins 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-to-primary energy conversion factor, and a full fuel cycle factor.

The annual unit energy consumption is the site energy consumed by a walk-in component

in a given year. Because the equipment classes analyzed in today’s 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 WICF. (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.

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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 today’s 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 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 Full-Fuel-Cycle Measurement 

Approaches to Energy Efficiency Standards” appointed by the National Academy of Science, 

DOE announced its intention to use full-fuel-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 today’s 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.

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3. Net Present Value of Customer Benefit

The inputs for determining the NPV of the total costs and benefits experienced by walkin 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.

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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 

156
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 top-down 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, more-stringent 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. 

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In Phase 3 of the MIA, DOE conducted structured, detailed interviews with a 

representative cross-section of manufacturers. During these interviews, DOE discussed 

engineering, manufacturing, procurement, and financial topics to validate assumptions used in 

the GRIM and to identify key issues or concerns. 

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 121. The Small Business 

Administration (SBA) defines a small business for North American Industry Classification 

System (NAICS) 333415 “Air-Conditioning 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 

158
entities. The small business subgroup is discussed in sections V.B.2.d and VI.B of today’s notice 

and in Chapter 12 of the 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.

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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 cost-efficiency 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 

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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 

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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.

b. Government Regulatory Impact Model Scenarios

Markup Scenarios

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As discussed above, MSPs include direct manufacturing production costs (i.e., labor, 

material, and overhead estimated in DOE’s MPCs) and all non-production 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 walk-in manufacturers, submitted

comments, and information obtained during manufacturer interviews, DOE assumed the nonproduction 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 

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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) 

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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 

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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-in-place 

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).

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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. 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. 

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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.

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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 walk-in 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 walk-in 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 

169
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 cap-and-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 (D.C.). SO2 emissions from 28 eastern States and D.C. 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

29 See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 

2008).

30 See EME Homer City Generation, LP v. EPA, 696 F.3d 7, 38 (D.C. Cir. 2012).

170

 
emissions factors used for today’s 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 

cap-and-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 non-HAP acid gas) as an alternative 

equivalent surrogate standard for acid gas HAP. The same controls are used to reduce HAP and 

non-HAP acid gas; thus, SO2 emissions will be reduced as a result of the control technologies 

installed on coal-fired power plants to comply with the MATS requirements for acid gas. 

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 

171
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 today’s 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 

172
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 today’s 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 

Comment [mk4]: Various changes made in this 

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173
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 

Council31 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 

31 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use. 

2009. National Academies Press: Washington, DC.

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request.

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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 existing literature 

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request. 

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175
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 

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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

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. 33 Social 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-for-RIA.pdf.

177

 
2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

The SCC values used for today’s notice were generated using the most recent versions of 

the three integrated assessment models that have been published in the peer-reviewed 

literature.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)

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

34 Technical 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 

178

 
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.

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179
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 policy-making; 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 

35 Available at: 

http://www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_update.pdf 36 Available at: 

http://www.cio.noaa.gov/services_programs/pdfs/OMB_Peer_Review_Bulletin_m05-03.pdf

180

 
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. Comment [mk12]: Changes made per OMB 

request. 

181
In November 2013, OMB announced minor technical corrections to the 2013 SCC values 

and a new opportunity for 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. 

Comment [mk13]: Changes made per OMB 

request. 

182
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 today’s 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. 

37 The 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/). 

183

 
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 today’s rule, the estimated 

impacts of standards are the differences between values forecasted by NEMS-BT and the values 

in the AEO2013 Reference Case. For more details on the utility impact analysis, see chapter 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 

184
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 today’s 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 Input-Output” (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 

185
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 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 

186
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 

187
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 today's 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.

188
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, non-display 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.

Table V.2 Mapping Between TSLs and Analytical Point ELs

Equipment 

Class

Nominal 

Size Baseline TSL 1 TSL 2 TSL 3

(Btu/h) Compressor 

Technology EL Compressor Technology EL Compressor Technology EL Compressor Technology EL

189
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. 4000 6FIN 0 6FIN 3 6FIN 3 6FIN 3

MC.M.N. 9000 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 today’s 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 today’s final rule, for to a total of six NOPR TSLs. The 

criteria for selecting TSL in the NOPR and today’s 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. Comment [mk14]: Paragraph added per OMB 

request.

190
Table V.3 Comparison of NOPR to Final Rule TSL Criteria

NOPR TSL Criteria Final Rule TSL Criteria

TSL System

Requirement

Component

Requirement TSL SystemRequirement

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

today’s final rule, the three TSLs considered by DOE are inclusive of all compressor types. 

Subsequently, the “All Compressors" TSLs are redundant in today’s 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 today’s final 

rule under conditions where all components are held at the baseline except for the equipment 

classes covering display doors. Hence, for today’s 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 walkComment [mk15]: Paragraph added per OMB 

request.

Comment [mk16]: Paragraph added per OMB 

request.

191
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 energy-consuming components of the door scale directly with surface area.) The surface 

area is defined in the walk-in cooler and freezer test procedure final rule. 

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 

192
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 standards equations for structural cooler panels, structural freezer panels, freezer floor panels, 

display doors, non-display passage doors, non-display freight doors, and refrigeration systems, 

respectively. Note 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 Equations 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

193
Table V.5 Equations 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 Equations 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

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

194
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 today’s 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.

195
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

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$

Customers 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 DedicatedCondensing Refrigeration Systems – Outdoor Condenser

TSL Energy 

Consumption 

Mean Values 2013$ Life-Cycle Cost Savings Median 

Installed Annual LCC Average Customers That Payback 

196
kWh/yr Cost Operating 

Cost

Savings 

2013$

Experience Period 

Net years

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 DedicatedCondensing 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$

Customers 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$

Customers 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$

Customers 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

197
198
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

199
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 

Installed years

Cost

Discounted 

Operating 

Cost

Installed 

Cost

Average 

Savings

Installed Cost

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% ---

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 walk-ins 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 

200
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) (2013$) 

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 --- --- -2844

All Business Types --- --- -2668

201
FD.L

Full-service Restaurants --- --- -1930

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

202
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. 

203
Table V.24 Summary of Results for Walk-in Coolers and Freezers TSLs: Rebuttable 

Payback Period

Median Payback Period

years

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

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

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). 

204
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 

standards-compliant equipment, operating profit does not change in absolute dollars and 

decreases as a percentage of revenue. 

205
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 381.94 381.94 381.94 381.94 

Change in INPV 2012 $M - 0 0 0 

% - 0 0 0 

Capital Conversion 

Costs 2012 $M -

0 

- 

0 

- 

0 

- 

Product Conversion 

Costs 2012 $M -

0 0 

- 

0 

- 

Total Investment 

Required 2012 $M -

0

- 

0 

- 

0 

- 

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 

403.13 to 

1061.78

Change in INPV 2012 $M - -9.19- to 21.64 -27.51 to 60.74 -81.73 to 

576.92

% - -1.89 to 4.46 -5.67 to 12.53 -16.86 to 118.9

Capital Conversion 

Costs 2012 $M - 0.04 0.15 2.39 

Product Conversion 2012 $M - 0.13 0.22 0.40 

206
Costs

Total Investment 

Required 2012 $M - 0.18 0.37 2.79 

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

Walk-in Cooler and Freezer Panel MIA Results

At all TSLs, the evaluated efficiency levels for walk-in panel equipment classes are at 

baseline. Baseline represents the 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 through TSL 3, 

INPV remains the same as in the base case. There is no change from the base case value of 

$381.94 million.

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.

207
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 -81.73 to 576.92, or a 

change in INPV of -16.86 percent to 118.99percent. At this level, door industry free cash flow is 

estimated to decrease by $1.07 million in the year before the compliance year, or 2.86 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.

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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 

209
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 walk-in panels, 1,302 domestic 

production workers for walk-in doors, and 415 domestic production workers for walk-in 

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 0 to 0

210
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

1,304

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 

today’s 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 Walk-in Panels, medium and low temperature solid doors, therefore there would 

likely be no significant change in employment in these industries.

211
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 today’s notice is baseline, DOE does not anticipate any changes in 

production techniques or new capacity constraints resulting from today’s 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. 

212
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 

today’s 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 Sub-Group

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 

sub-groups. 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 

213
exhibiting similar characteristics. Consequently, DOE analyzes small manufacturers as a subgroup. 

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 today’s notice 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 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.

214
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.

215
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 phase-out 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 

216
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 door-closers 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. 

217
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

FD.L 0.000 0.000 0.027

Total 2.466 3.099 3.821

*For DC refrigeration systems, results include all capacity ranges.

218
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 

38 Section 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 

Comment [mk17]: Footnote modified to reflect 

changes made by OMB.

219

 
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

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.

220

 
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. 

221
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 were 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

222
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

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

223
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

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 walk-in 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 

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

224
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 more-efficient 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 re-invested in economic sectors that create more jobs 

than are lost in the electric utilities sector. Thus, the amended energy conservation standards for 

walk-in 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 

225
equipment. For today’s 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 today’s 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 today’s 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. 

226
Energy savings from amended standards for walk-in coolers and walk-in freezers could 

also produce environmental benefits in the form of reduced emissions of air pollutants and GHGs 

associated with electricity production.

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.

227
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 

228
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

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 

229
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

2 366.1 183.5

3 450.0 225.5

230
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

Customer NPV at 3% Discount Rate added with Value of Emissions Based on:

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

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

TSL

Customer NPV at 7% Discount Rate added with Value of Emissions Based on:

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

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. 

231
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 climate-related 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. 

232
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 today’s 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.

233
1. Benefits and Burdens of Trial Standard Levels Considered for Walk-in Coolers and Walkin 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) -29.41to 31.88 -52.89to 80.20

107.10to 

596.38

Change in Industry NPV (%) -2.28to 2.47 -4.1to 6.21 -8.30to 46.19

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

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.

234
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.

235
Table V.45 Summary of Results for Walk-in Coolers and Freezers TSLs: Median Payback 

Period

Median Payback Period*

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

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

PD.L --- --- 30.7

FD.M --- --- 115.5

FD.L --- --- 19.1

* "---" indicates no impact because there is no change in the standards.

236
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

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

237
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. Comment [mk18]: Sentence added per OMB.

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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 $107.1

million to an increase of $596.4 million based on DOE’s manufacturer markup scenarios. The 

upper bound gain of $596.4 million in INPV is considered an optimistic scenario for 

manufacturers because it assumes manufacturers can fully pass on substantial increases in 

equipment costs. 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 8.30 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 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

239
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, 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 analyses 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.

Table V.47 Energy Conservation Standards for Walk-in Coolers and Walk-in Freezers

(Compliance Required Starting [INSERT DATE])

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

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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 28

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

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.

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2. Summary of Benefits and Costs (Annualized) of the Standards

The benefits and costs of today’s 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 today’s 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 

today’s 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 today’s rule is $528 million per year in increased equipment costs, 

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.

242

 
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.

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Table V.48 Annualized Benefits and Costs of New and Amended Standards for Walk-in 

Coolers and Walk-in 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

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 

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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 

today’s 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 today’s regulatory action is an “economically 

significant regulatory action” under section 3(f)(1) of Executive Order 12866. Accordingly, 

section 6(a)(3) of the Executive Order requires that DOE prepare a regulatory impact analysis 

(RIA) on today’s rule and that the Office of Information and Regulatory Affairs (OIRA) in the 

245
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 

246
available techniques to quantify anticipated present and future benefits and costs as accurately as 

possible. In its guidance, the Office of Information and Regulatory Affairs has emphasized that 

such techniques may include identifying changing future compliance costs that might result from 

technological innovation or anticipated behavioral changes. For the reasons stated in the 

preamble, DOE believes that today’s 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 website (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 

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30836, 30848 (May 15, 2000), as amended at 65 FR 53533, 53544 (Sept. 5, 2000) and codified 

at 13 CFR part 121. The size standards are listed by North American Industry Classification 

System (NAICS) code and industry description and are available at 

http://www.sba.gov/content/small-business-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 Directory40, and NAFEM41), public databases (e.g. the SBA Database42), 

individual company websites, and market research tools (e.g., Dunn and Bradstreet reports43 and 

Hoovers reports44) 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 

40 See www.ahridirectory.org/ahriDirectory/pages/home.aspx. 41 See http://www.nafem.org/find-members/MemberDirectory.aspx 42 See http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm. 43 See www.dnb.com/. 44 See www.hoovers.com/. 

248

 
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. Today’s notice 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. 

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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 

250
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. Today’s 

notice 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 today’s 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 component additions. Also, 

251
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 today’s notice (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 today’s standards would not 

have a significant impact on a substantial number of small display door manufacturers.

252
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 

253
has established regulations for the certification and recordkeeping requirements for all covered 

consumer products and commercial equipment, including walk-in coolers and walk-in freezers. 

(76 FR 12422 (March 7, 2011)). The collection-of-information requirement for the certification 

and recordkeeping is subject to review and approval by OMB under the Paperwork Reduction 

Act (PRA). This requirement has been approved by OMB under OMB control number 1910-

1400. Public reporting burden for the certification is estimated to average 20 hours per response, 

including the time for reviewing instructions, searching existing data sources, gathering and 

maintaining the data needed, and completing and reviewing the collection of information. 

Notwithstanding any other provision of the law, no person is required to respond to, nor 

shall any person be subject to a penalty for failure to comply with, a collection of information 

subject to the requirements of the PRA, unless that collection of information displays a currently 

valid OMB Control Number.

D. Review Under the National Environmental Policy Act of 1969

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 

254
need to prepare an Environmental Assessment or Environmental Impact Statement for 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 today’s 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 

255
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. Pub. L. 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 

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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. 

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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), today’s final rule would establish energy conservation standards for walk-in coolers and 

walk-in freezers that are designed to achieve the maximum improvement in energy efficiency 

that DOE has determined to be both technologically feasible and economically justified. A full 

discussion of the alternatives considered by DOE is presented in the “Regulatory Impact 

Analysis” section of the TSD for today’s 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 

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this regulation would not result in any takings that might require compensation under the Fifth 

Amendment to the U.S. Constitution.

J. Review Under the Treasury and General Government Appropriations Act, 2001

Section 515 of the Treasury and General Government Appropriations Act, 2001 (44 

U.S.C. 3516, note) provides for Federal agencies to review most disseminations of information 

to the public under guidelines established by each agency pursuant to general guidelines issued 

by OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 2002), and DOE’s 

guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has reviewed today’s 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 

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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 today’s regulatory action, which sets forth energy conservation 

standards for walk-in 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 

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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 today’s 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. 

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Issued in Washington, DC, on

________________________________

David T. Danielson

Assistant Secretary

Energy Efficiency and Renewable Energy

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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.

* * * * *

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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 walkin coolers and walk-in freezers.

(a) Scope. This section provides test procedures for measuring, pursuant to EPCA, 

the energy consumption of walk-in coolers and walk-in freezers.

* * * * *

4. In §431.306, revise paragraph (a)(3), and add paragraphs (c), (d), (e), and (f) to read as 

follows:

§431.306 Energy conservation standards and their effective dates.

(a) * * *

(3) Contain wall, ceiling, and door insulation of at least R-25 for coolers and R-32 for 

freezers, except that this paragraph shall not apply to:

(i) Glazed portions of doors not to structural members and 

(ii) A walk-in cooler or walk-in freezer component if the component manufacturer 

has demonstrated to the satisfaction of the Secretary in a manner consistent with 

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applicable requirements that the component reduces energy consumption at least as much 

as if such insulation requirements of subparagraph (a)(3) were to apply.

(b) * * * * *

(c) Walk-in cooler and freezer panels.

Class Descriptor Class Minimum R-Value

(h-ft2-°F/Btu)*

Structural Panel, Medium 

Temperature** SP.M 28

Structural Panel, Low 

Temperature SP.L 32

Floor Panel, Low Temperature FP.L 28

(d) Walk-in cooler and freezer display doors.

Class Descriptor Class Equations for Maximum Energy Consumption 

(kWh/day)*

Display Door, Medium 

Temperature DD.M 0.04 × Add + 0.41

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

*Add represents the surface area of the display door.

(e) Walk-in cooler and freezer non-display doors.

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.

(f) Walk-in cooler and freezer refrigeration systems.

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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.

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