1 | Program Name or Ancillary Text eere.energy.gov The Parker Ranch installation in Hawaii 

### BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Program for Appliance Standards: NOPR Public Meeting for Refrigerators, Refrigerator- Freezers, and Freezers 

### October 14, 2010 Department of Energy Energy Efficiency & Renewable Energy2 | Program Name or Ancillary Text eere.energy.gov

2 Building Technologies Program 

# • To present revised methodologies based on stakeholder feedback, and characterize results for analyses
• To discuss specific issues related to each analysis
• To seek input from attendees on methodologies, assumptions and data sources
• To describe remaining steps before issuance of Final Rule Purpose of the Public Meeting Introduction3 | Program Name or Ancillary Text eere.energy.gov

3 Building Technologies Program 

# Issues for Comment Introduction



## Issue Box: DOE welcomes comments, data, and information concerning its analysis on residential refrigeration products. Throughout this presentation, issues that correspond to issues raised in DOE’s published material from this analysis are raised for discussion in boxes like this one. Nonetheless, comments are welcome on any part of DOE’s analysis **.**4 | Program Name or Ancillary Text eere.energy.gov

4 Building Technologies Program 

# Background

• Final Rule published November 17, 1989 set performance standards effective January 1, 1993. (54 FR at 47916)
• Rule correction affecting three product classes published October 24, 1990. (55 FR at 42845)
• Second round final rule published April 28, 1997 for standards effective July 1, 2001. (62 FR at 23102)
• Analyses published in October 2005 to support priority setting for additional refrigerator rulemaking.
• Energy Independence and Security Act 2007 (EISA 2007) requires publication of updated standards by December 31, 2010 to take effect January 1, 2014.5 | Program Name or Ancillary Text eere.energy.gov

5 Building Technologies Program 

# Joint Comments

• Various groups representing manufacturers, energy, environmental, and consumer advocates submitted the Joint Comments August 12, 2010.
• The Joint Comments recommends specific energy conservation standards for refrigeration products that, in the commenters ’ view, would satisfy the requirements under EPCA.
• DOE neither organized nor was a member of the group, but made its contractors available to perform data processing.
• Consistent with its legal obligations when developing an energy conservation standard, DOE is providing the public with the opportunity to comment on the proposed levels that DOE is considering adopting for refrigeration products, which mirror those recommended in the Joint Comments.6 | Program Name or Ancillary Text eere.energy.gov

6 Building Technologies Program 

# Stakeholder Participation in the Rulemaking Process

Federal Register notices Framework Document Preliminary Analysis NOPR Final Rule



# • Public meetings and oral comments 

# • Written comments on Federal Register notices, Technical Support Documents and Analytical Spreadsheets 

# • Data input from manufacturers and other interested parties. Stakeholder participation Today7 | Program Name or Ancillary Text eere.energy.gov

7 Building Technologies Program 

# Comments from Participants

• Participants are invited to provide summary comments or statements

• Participants are invited to raise additional issues for discussion today

• The comment period closes on November 26, 20108 | Program Name or Ancillary Text eere.energy.gov

8 Building Technologies Program 

## Factor Analysis 1. Economic impact on consumers and manufacturers Life - cycle cost analysis Manufacturer impacts analysis 2. Lifetime operating cost savings Life - cycle cost analysis 3. Total projected energy savings National impact analysis 4. Impact on utility or performance Screening analysis Engineering analysis 5. Impact of any lessening of competition Manufacturer impacts analysis 6. Need for national energy conservation National impact analysis 7. Other factors the Secretary considers relevant Environmental assessment Utility impact analysis Employment impact analysis 

## The Energy Policy and Conservation Act (EPCA) directs DOE to consider seven factors when setting energy conservation standards9 | Program Name or Ancillary Text eere.energy.gov

9 Building Technologies Program Framework Document ANOPR NOPR Final Rule 

# NOPR Analyses

NOPR Preliminary

Analysis Final Rule

Proposed Standard

Levels Employment Impact Analysis Utility & Environmen tal Impact Analysis Life - Cycle Cost Subgroup Analysis Manufacturer Impact Analysis Revise Preliminary

Analysis Trial Standard

Levels Regulatory Impact Analysis10 | Program Name or Ancillary Text eere.energy.gov

10 Building Technologies Program Framework Document ANOPR NOPR Final Rule NOPR Preliminary Analyses 

# Analyses for Final Rule

Final Review Revise NOPR Analyses Final Rule 

# Statute and Context11 | Program Name or Ancillary Text eere.energy.gov

11 Building Technologies Program 

# NOPR Analyses

Screening Analysis Engineering Analysis

Energy Use Characterization Shipments Analysis National Impact Analysis Markups to Determine Product Price Life - Cycle Cost and Payback Period Analyses Market & Technology Assessment

Preliminary Manufacturer Impact Analysis Proposed Standard

Levels Employment Impact Analysis Utility & Environmen tal Impact Analysis Life - Cycle Cost Subgroup Analysis Manufacturer Impact Analysis Revise Preliminary

Analysis Trial Standard

Levels Regulatory Impact Analysis12 | Program Name or Ancillary Text eere.energy.gov

12 Building Technologies Program 

# Market & Technology Assessment Issues: 

# • Test Procedure 

# • Max
- tech levels 

# • Product Classes 

# • Built

- In products 

# • Automatic Icemakers 

# • Definition for Compact Products Market & Technology Assessment13 | Program Name or Ancillary Text eere.energy.gov

13 Building Technologies Program 

# Schedule • NOPR Published May 27, 2010 • Public Meeting Held June 22, 2010 • DOE is in the process of finalizing the Final Rule Proposed Changes Affecting Measured Energy Use • Compartment Temperature Changes • Volume Measurement Method • Adjustment of Current Standards to account for test procedure changes is discussed in the TSD Market & Technology Assessment: Test Procedure14 | Program Name or Ancillary Text eere.energy.gov

14 Building Technologies Program 

# Issue for Public Comment

Issue 23: Test Procedure Changes: **DOE requests comment on its adjustment of the current**  **energy standards to account for test procedure changes. In particular, DOE requests comment on the approach used to**  **adjust the standard levels to address compartment temperature changes and volume measurement method**  **changes. DOE also requests comment and seeks information on whether**  **any other proposed test procedure changes should be considered in setting the new standard**  **— DOE seeks**  **information quantifying the impact on energy use measurement of these additional test procedure changes.** 15 | Program Name or Ancillary Text eere.energy.gov

15 Building Technologies Program 

# The max

- tech efficiency levels are generally higher than max available efficiency levels. Market & Technology Assessment: Max Tech

Product Class Efficiency Level (Percent Energy Use Reduction) DOE Analysis Max Available 3 36% 30% 5 36% 33% 7 33% 32% 9 44% 27% 10 41% 16% 11 59% 27% 18 42% 23% 3A- BI 28% 31% 5 - BI 27% 27% 7 - BI 22% 21% 9 - BI 27% 27% 

# This reflects consideration of max

- tech designs in the analysis that may not be cost

- effective. Information based on energy use not including icemaking energy use.16 | Program Name or Ancillary Text eere.energy.gov

16 Building Technologies Program 

### Product Class Design OptionBLDC*Fan MotorsHeatExchangerImprovementThickerWallsVacuumInsulationPanels(VIPs)VariableSpeedCompressorAdaptiveDefrostVariableAnti-sweatHeaterControlIsobutaneRefrigerant



### 3      5       7       9       10     11      18     3A - BI     5 - BI      7 - BI       9 - BI      

# Market & Technology Assessment: Max Tech



# The analysis max

- tech levels represent designs using all applicable design options for a given product class.17 | Program Name or Ancillary Text eere.energy.gov

17 Building Technologies Program 

## Issue 2: Max-Tech Levels: **DOE requests comment on the max -**  **tech levels identified, and on the combinations of design options considered applicable**  **to achieve max -**  **tech designs. DOE requests that comments also address as appropriate the differences in applicable**  **design options for different product classes.** 

# Issue for Public Comment18 | Program Name or Ancillary Text eere.energy.gov

18 Building Technologies Program 

# Product Classes DOE is proposing to add are as follows.

• French

- Door Bottom
- Mount refrigerator

- freezers with TTD ice service (product class 5A)
• Chest freezers with automatic defrost (product class 10A)
• All

- refrigerators (product classes 1A, 3A, 11A, 13A)
• Products with automatic icemakers without TTD ice service.
• Built

- in products. Market & Technology Assessment: Product Classes19 | Program Name or Ancillary Text eere.energy.gov

19 Building Technologies Program 

# Issues for Public Comment

Issue 3: Product Classes for Automatic Icemakers: **DOE requests comments on establishing product**  **classes for refrigeration products with automatic**  **icemakers and on the proposed approach to**  **account for icemakers in the product class structure.**  Issue 5: Additional Product Classes: **DOE requests comment on whether any additional product classes are required to fully address**  **icemaking and built**  **- in**  **products.**20 | Program Name or Ancillary Text eere.energy.gov

20 Building Technologies Program 

# Product Class Combination

Issue 6: Product Class Combination: **DOE requests comment on the proposal not to combine product class 2 (refrigerator**  **- freezer**  **— partial automatic defrost)**  **with product class 1 (refrigerators and refrigerator -** **freezers with manual defrost) and the proposal not to combine product**  **class 12 (compact refrigerator -** **freezer —**  **partial automatic defrost) with product class 11 (compact refrigerators and**  **refrigerator -**  **freezers with manual defrost).** 

# Clarification: DOE does NOT propose combining product classes 1 and 2 and product classes 11 and 12.21 | Program Name or Ancillary Text eere.energy.gov

21 Building Technologies Program 

# Proposed definition for built

- in products: Built

- in refrigerator/refrigerator

- freezer/freezer means any refrigerator, refrigerator

- freezer or freezer with 7.75 cubic feet or greater total volume and 24 inches or less depth not including handles and not including custom front panels; is designed to be encased on the sides and rear by cabinetry; is designed to be securely fastened to adjacent cabinetry, walls or floor; and has sides which are not fully finished and are not designed to be visible after installation. 

# Market & Technology Assessment: Product Classes

Issue 4: Separate Product Classes for Built - In Refrigeration Equipment: **DOE requests comment on the proposal to establish separate product classes for built**  **- in refrigeration products. DOE also**  **requests comment on the proposed definition for built -** **in products, including what**  **changes, if any, are needed to**  **strengthen it while not disqualifying any true built**  **- in products,**  **and whether the proposed 24** **- inch**  **dimension specified in the proposed definition should be**  **adjusted.** 

## Issue for Public Comment:22 | Program Name or Ancillary Text eere.energy.gov

22 Building Technologies Program 

# DOE proposes to eliminate the 36

- inch height restriction for compact products. Market & Technology Assessment: Product Classes

Issue 7: Elimination of 36 - inch height limitation for compact products: **DOE requests comment on the proposal to eliminate the current 36** **- inch height limitation for compact products.**  

## Issue for Public Comment:23 | Program Name or Ancillary Text eere.energy.gov

23 Building Technologies Program 

# Screening Analysis Issues: 

# • Compressors 

# • Vacuum
- Insulated Panels 

# • Isobutane Refrigerant Screening Analysis24 | Program Name or Ancillary Text eere.energy.gov

24 Building Technologies Program 

# DOE considered the potential for insufficient supply of high

- efficiency single

- speed and of variable

- speed compressors and has tentatively concluded that the supply base will be capable of ramping up to meet demand. Screening Analysis: Compressors

Issue for Public Comment: Issue 8: Supply of high -efficiency and variable - speed compressors: **DOE requests comment on DOE’s findings regarding projections**  **of supply of high**  **- efficiency and variable** **- speed**  **compressors. In particular, DOE seeks information that would confirm or cast doubt on DOE’s conclusions regarding**  **compressor supply.**25 | Program Name or Ancillary Text eere.energy.gov

25 Building Technologies Program 

# DOE studied supply issues associated with Vacuum

Insulated Panels (VIPs) and tentatively concluded that suppliers will be able to ramp up production levels as needed to address potential demand. Screening Analysis: Vacuum - Insulated Panels

Issue for Public Comment: Issue 10: Suitability of VIP technology as a design option: **DOE requests comment and information on aspects of VIP technology that affect its suitability for consideration as a**  **design option. DOE in particular seeks any new information not already discussed or considered in the rulemaking.** 26 | Program Name or Ancillary Text eere.energy.gov

26 Building Technologies Program 

# DOE concluded that expected limitations on allowed quantities of isobutane refrigerant make conversion to this refrigerant viable only for compact refrigerators. Screening Analysis: Isobutane Refrigerant

Issue for Public Comment: Issue 9: Use of isobutane refrigerant as a design option: **DOE requests comment on the potential**  **use of isobutane**  **refrigerant as a design option only for compact refrigerators.**27 | Program Name or Ancillary Text eere.energy.gov

27 Building Technologies Program 

## NOPR Analyses

Screening Analysis Engineering Analysis

Energy Use Characterization Shipments Analysis National Impact Analysis Markups to Determine Product Price Life - Cycle Cost and Payback Period Analyses Market & Technology Assessment

Preliminary Manufacturer Impact Analysis Proposed Standard

Levels Employment Impact Analysis Utility & Environmen tal Impact Analysis Life - Cycle Cost Subgroup Analysis Manufacturer Impact Analysis Revise Preliminary

Analysis Trial Standard

Levels Regulatory Impact Analysis28 | Program Name or Ancillary Text eere.energy.gov

28 Building Technologies Program 

# DOE developed baseline energy use equations for all product classes based on data illustrating the impact of the key test procedure changes affecting measured energy use: compartment temperature changes and volume calculation method changes. Engineering Analysis Baseline Energy Use for New Test Procedure



# AHAM Data ESAF and VCAF factors New Baseline Energy Use

Equations ESAF: Energy use ratio VCAF: Adj. Vol. ratio Energy = A AV + B A new 

# = A old 

# ESAF VCAF B new 

# = Bold 

# ESAF29 | Program Name or Ancillary Text eere.energy.gov

29 Building Technologies Program 

# DOE raised the slopes of the baseline energy use equations for product classes 4, 5, and 5A. The intercepts were lowered to maintain equal average energy use. Engineering Analysis Slope Change

0 100 200 300 400 500 600 700 800 900

20 25 30 35 40Annual Energy Usage (kWh/year)



### Adjusted Volume (cubic feet) Current Standard Preliminary Analysis New Test Baseline New Test With Adjusted Slope Slope 4.91 Slope 11.3 Slope 5.51 

# • PC4 slope equal to PC7 slope. • PC5 slope equal to the average of PC3 and PC7 slopes. • PC5A energy use equal to PC5 plus the difference between PC6 and PC3 (the same approach used to set current PC5A energy levels established through exception relief) 

# Adjustment for product class 430 | Program Name or Ancillary Text eere.energy.gov

30 Building Technologies Program 

# Issue for Public Comment
Issue 11: Slope adjustments for baseline energy use equations: **DOE requests comment on the approach used to develop Proposed Procedure Reduced Baseline Energy Use equations**  **with adjusted slopes for product classes 4 (refrigerator****** **freezers —**  **automatic defrost with side -** **mounted freezer without through**  **- the** **- door ice service), 5 (refrigerator**  **- freezers** **— automatic defrost with bottom**  **- mounted freezer without**  **through -**  **the -** **door ice service), and 5A (refrigerator -** **freezers —**  **automatic defrost with bottom -** **mounted freezer with through**   ** the****- door ice service) . DOE also seeks relevant data that would**  **allow adjustment of the curve intercept so that the shipment****** **weighted average impact of the slope change would be neutral (** 

**i.e. , zero change) with respect to energy use. DOE also seeks**  **any additional information that would support similar development of adjusted**  **- slope baseline energy curves for**  **other product classes.**31 | Program Name or Ancillary Text eere.energy.gov

31 Building Technologies Program 

# Engineering Analysis NOPR Modifications

Parameter(s) Prelim. Analysis Changes for the Proposed Rule VIP Surface Coverage Full product coverage, except for chest freezer walls. Full coverage of doors, 50% coverage of cabinet, preference for coverage of freezer compartments, no change to exception for chest freezer walls. VIP Effectiveness Full effectiveness as determined by the ERA energy model. 50% of ERA energy model effectiveness. Cost Increase for Higher- Efficiency Components Initial Analysis based on Preliminary Information Adjusted based on additional information. Conversion Costs for Increase of Insulation Thickness Based on Manufacturing Cost Model Increased due to Manufacturing Model Updates. Greater cost allocated to doors. Heat Exchanger (Condenser and Evaporator) Size Increase 20 % increase in the heat exchangers surface area. Consider only where analyzed models have space. Direct modeling of heat exchanger performance based on geometry changes. Fan power increase for heat exchanger depth increases. Standby Power for Variable Speed Controls Not included. Addition of 1.5W load outside the cabinet for products not already having electronic control. 

# DOE modified its analyses in the NOPR phase based on comments and additional information.32 | Program Name or Ancillary Text eere.energy.gov

32 Building Technologies Program 

### Parameter(s) Preliminary Changes for the Proposed Rule Variable Speed Compressor System Fan Control Inconsistent selection of fan speed. Fan operation at reduced speed, 50 % power input consistent with cubic fan law. Variable Speed Compressor Performance for Compact Products Performance according to compressor vendor data and ERA model. Degradation of compressor capacity in ERA energy modeling based on performance data obtained from a manufacturer. Isobutane Refrigerant Not considered Consideration of isobutane refrigerant for compact refrigerators, with 5% energy use reduction. Variable Anti - Sweat Heater Control Considered for product class 5* Also considered for product class 7** Baseline Anti - Sweat Heater Operation (Product Class 5* only) Antisweat heaters considered French doors. Baseline average wattage reduced for both directly analyzed products. Variable Defrost Compressor Run time between defrosts 38 hours 24 hours; Adjustment also made in this value when converting to variable speed compressors. * Refrigerator- freezers
—automatic defrost with bottom - mounted freezer without through - the - door ice service ** Refrigerator- freezers
—automatic defrost with side - mounted freezer with through - the - door ice service. 

# Engineering Analysis NOPR Modifications, continued33 | Program Name or Ancillary Text eere.energy.gov

33 Building Technologies Program 

# Issue for Public Comment

Issue 12: Treatment of design options in engineering analysis: **DOE requests comment on its treatment of design options in the engineering analysis.** 34 | Program Name or Ancillary Text eere.energy.gov

34 Building Technologies Program 

# Issue for Public Comment

Issue 13: ERA energy modeling: **DOE requests comments, information, and data that would permit the adjustment of**  **energy modeling inputs**  **and/or results that would allow more accurate representation of the energy**  **use impacts of design options using the ERA energy model.**35 | Program Name or Ancillary Text eere.energy.gov

35 Building Technologies Program Market & Technology Screening Analysis Engineering Analysis
Energy Use & End Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis 

# NOPR Analyses

Proposed Standard

Levels Employment Impact Analysis Utility & Environmen tal Impact Analysis Life - Cycle Cost Subgroup Analysis Manufacturer Impact Analysis Revise Preliminary

Analysis Trial Standard

Levels Regulatory Impact Analysis36 | Program Name or Ancillary Text eere.energy.gov

36 Building Technologies Program 

# Markups to Determine Equipment Price Resulting Markup Multipliers
Refrigerators and Freezers Markup Baseline Incremental Manufacturer 1.26 Retailer 1.45 1.17* Sales Tax 1.073 Overall 1.96 1.58 *Updated from 1.15 used in preliminary analysis, using U.S. Census 2002 Business Expenditure Survey (BES) 

## Issue 12: Incremental markups: **DOE requests information regarding likely retailer responses**  **to incremental changes**  **in the CGS of appliances associated with**  **the proposed energy conservation standards.** 37 | Program Name or Ancillary Text eere.energy.gov

37 Building Technologies Program Market & Technology Screening Analysis Engineering Analysis
Energy Use & End Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis 

# NOPR Analyses

Proposed Standard

Levels Employment Impact Analysis Utility & Environmen tal Impact Analysis Life - Cycle Cost Subgroup Analysis Manufacturer Impact Analysis Revise Preliminary

Analysis Trial Standard

Levels Regulatory Impact Analysis38 | Program Name or Ancillary Text eere.energy.gov

38 Building Technologies Program 

##  In order to distinguish top

- and bottom

- mount units that were not reported separately in RECS, DOE used AHAM data relationships between refrigerator

- freezer product class and income to weight RECS households differently for these two product classes (PC 3 and 5).  Similarly, AHAM data on relationships between built

- in refrigerator ownership and income were used to weight RECS household data for these product classes.  The average raw volume from RECS and sales data from NPD Group, Inc . differed for product classes 5 (bottom

- mount ref/fzrs ) and 7 (side

- mount ref/fzrs ) by 16% and 18% respectively. As a result, size distributions for these product classes were scaled upward. 

# Scaling of RECS data Energy Use Determination

Issue 15: Income relationships and volume scaling of RECS data: **DOE requests comment on the weighting of the 2005 RECS sample using income relationships and volume scaling.** 39 | Program Name or Ancillary Text eere.energy.gov

39 Building Technologies Program 

# Usage Adjustment Factors Energy Use Determination

 DOE responded to stakeholder feedback by developing a new energy use determination approach based on field metered data

 DOE used 1,652 data points from 7 metering studies obtained between 1994 - 2004 to develop regressions from which usage adjustment factor (UAF) functions were obtained for standard - sized products.

 UAF functions were applied to RECS household variables to estimate energy use for each refrigeration unit.

 Variables included heating and cooling degree days, location (heated space and/or basement), number of occupants, and unit age.40 | Program Name or Ancillary Text eere.energy.gov

40 Building Technologies Program 

# Energy Use Determination

P re li minary Samp le C u rrent Ana lysis Ana lysis Product Class Size Mean UAF Mean UAF Top-mount refrig e rator-fre eze r 2 , 303 0.93 (0.82 to 1.04)* 1.23 (PC 3) Bottom-mount r efr igerator- 2 , 303 0.92 (0.81 to 1.02) * 1.09 fr eeze r (PC 5) Side

- b y - s ide ref rigerator- 1 , 026 0.94 (0.84 to 1.0 3)* 1.44 free ze r wi th TTD (PC 7) Upright fr eeze r (PC 9) 248 0. 85 1.3 7 Chest freezer (pC 10) 369 0.89 1.48 Top-mount built-in refrigerator- 2,303 0.94 (0.83 to 1.0 7)* 

### N /

A free ze r (PC 3A-Bl) Bo ttom-mount built-in 2 , 303 0.96 (0.85 to 1.07)* 

### N /

A re frig e rator- fr eeze r (pC 5-B I) Side-by-side built

- in 1 , 026 0.94 (0.84 to 1.03) * 

### N /

A refrigerator

- freezer (PC 7-BI) Upright built

- in fre eze r (PC 9- 24 8 0. 85 

### N /

A BI) * Averages are ba se d on lif e tim e di strib uti o n and includ e conversion to 2n d refrigerators. Ran ge indicat es ave ra ge UAF in year I ( minimum) and yea r 2 0 (max imum) .41 | Program Name or Ancillary Text eere.energy.gov

41 Building Technologies Program 

# Issue for Public Comment

Issue 16: UAF equations based on field - metered data: **DOE requests comments on its approach for developing UAFs using field**  **- metered data.** 42 | Program Name or Ancillary Text eere.energy.gov

42 Building Technologies Program Market & Technology Screening Analysis Engineering Analysis
Energy Use & End Use Load Characterization Shipments Analysis National Impact Analysis Markups for Equipment Price Determination Life - Cycle Cost and Payback Period Analysis Preliminary Manufacturer Impact Analysis 

# NOPR Analyses

Proposed Standard

Levels Employment Impact Analysis Utility & Environmen tal Impact Analysis Life - Cycle Cost Subgroup Analysis Manufacturer Impact Analysis Revise Preliminary

Analysis Trial Standard

Levels Regulatory Impact Analysis43 | Program Name or Ancillary Text eere.energy.gov

43 Building Technologies Program 

# Life - Cycle Cost and Payback Period Analysis

LCC and PBP Analysis Inputs

Baseline Manufacturer Cost Std-Level Manufacturer Cost

Sales Tax Installation Cost Total Installed Cost

Energy Prices Energy Use Equipment Price

Lifetime Operating Expense Annual Energy Expense Lifetime Repair Cost Discount Rate Maintenance Cost Energy Price Trends Annual Operating Expense Payback Period Life-Cycle Cost Manufacturer Markup From Engineering

Analysis (Price is a function of Efficiency)

From Markups for Equipment Price Determination

From Energy Use Determination (Use is a function of Efficiency) Consumer Retail Price

Markup44 | Program Name or Ancillary Text eere.energy.gov

44 Building Technologies Program 

## Repair and Maintenance Costs 

# Life - Cycle Cost and Payback Period Analysis

Issue 17: Repair cost estimates: **DOE requests comment on the approach used for estimating repair costs.**  Approach Estimated from component - level estimates of repair rate and unit repair cost Sources Engineering Analysis, Commercial Refrigeration Equipment 2009 Final Rule, Consumer Reports 2009 Annual User Survey, Best Buy Co. (2010), RSMeans 2010 Results Baseline annual repair costs vary with product class, from $1.43 to $21.90 per year Incremental annual repair costs vary with product class, from $0.67 to $2.58 per year45 | Program Name or Ancillary Text eere.energy.gov

45 Building Technologies Program 

## • Base Case is used to project market share of higher efficiency products in the absence of standards
• Base Case Efficiency Distributions were determined using 2007 and 2008 data supplied by AHAM.

– The change in the ENERGY STAR criterion for standard - sized refrigerator- freezers in 2008 was taken into account, allowing the ENERGY STAR market share for these products to return to pre - 2008 levels over time.

– ENERGY STAR levels in 2014 were assumed to be determined using a 5 - year payback period criterion. 

## • Standards Case Efficiency Distributions applied a “roll - up” approach used in the preliminary analysis, but assigned ENERGY STAR levels using the 5 - year payback period criterion.

– For all product classes, the ENERGY STAR level vanishes for efficiency levels higher than 15% over the current baseline. 

# Base and Standards Case Efficiency Distributions46 | Program Name or Ancillary Text eere.energy.gov

46 Building Technologies Program 

# Issue for Public Comment

Issue 18: Base case efficiency distributions: **DOE requests comments on its approach for estimating base****** **case efficiency distributions.**

Issue 19: Forecasting base and standards case efficiency distributions: **DOE requests comments on its approach for forecasting base****** **case and standards -** **case efficiency distributions.**47 | Program Name or Ancillary Text eere.energy.gov

47 Building Technologies Program Framework Document ANOPR NOPR Final Rule 

# NOPR Analyses

NOPR Preliminary

Analysis Final Rule

Proposed Standard

Levels Employment Impact Analysis Utility & Environmen tal Impact Analysis Life - Cycle Cost Subgroup Analysis Manufacturer Impact Analysis Revise Preliminary

Analysis Trial Standard

Levels Regulatory Impact Analysis 

## DOE has no specific requests for comments on the following analyses: • Life
- Cycle Cost Subgroup Analysis •Trial Standard Levels • Manufacturer Impact Analysis • Employment Impact Analysis
• Regulatory Impact Analysis48 | Program Name or Ancillary Text eere.energy.gov

48 Building Technologies Program 

# Baseline treatment of regulatory emissions

• The emissions baseline is based on the 2010 Annual Energy Outlook. It accounts for regulatory emissions reductions through 2008, including CAIR but not CAMR. Subsequent regulations, including the currently proposed CAIR replacement rule, the Clean Air Transport Rule, do not appear in the baseline.
• NOx emissions reductions are calculated using BT- NEMS for the 22 states that do not participate in CAIR.

Issue 1: Regulatory emissions reductions: **DOE requests comment on its baseline treatment of regulatory emissions**  **reductions for NOx**  **.**49 | Program Name or Ancillary Text eere.energy.gov

49 Building Technologies Program Framework Document ANOPR NOPR Final Rule 

# NOPR Analyses

NOPR Preliminary

Analysis Final Rule

Proposed Standard

Levels Employment Impact Analysis Utility & Environmen tal Impact Analysis Life - Cycle Cost Subgroup Analysis Manufacturer Impact Analysis Revise Preliminary

Analysis Trial Standard

Levels Regulatory Impact Analysis50 | Program Name or Ancillary Text eere.energy.gov

50 Building Technologies Program 

# Proposed Standards 

# The proposed standards, expressed as equations in terms of adjusted volume, are presented on pages 59471 and 59472 of the NOPR. Note that the equation for product class 5A

- BI should read “9.72 AV + 595.5” for AV expressed in cubic feet.51 | Program Name or Ancillary Text eere.energy.gov

51 Building Technologies Program 

# Proposed Standards

Standard

- Sized Refrigera torFreezers Standard

- Sized Freezers Compact Products Built - in Products Proposed standard level 3 2 2 3 National Energy Savings (quads) 3.05 1.01 0.37 0.05
Net Present Value (2009$ billion ) 3% discount rate 10.40 7.78 0.86 (0.46) 7% discount rate 0.41 2.12 0.25 (0.34) Industry Net Present Value 2009$ million (287.5) to (662.1) (110.6) to (186.0) (30.8) to (66.7) (65.8) to (80.5) % change (9.1) to (20.9) (27.5) to (46.2) (15.4) to (33.4) (10.0) to (12.2)52 | Program Name or Ancillary Text eere.energy.gov

52 Building Technologies Program 

# Issue for Public Comment

Issue 20: Proposed standards for built - in products: **DOE requests comment on its considerations**  **leading to the proposed standards for built**  **- in refrigeration products,**  **particularly regarding the projected negative net**  **consumer impacts of the proposed standards.** 53 | Program Name or Ancillary Text eere.energy.gov

53 Building Technologies Program 

# Issue for Public Comment

Issue 21: Round off of energy standard: **DOE requests comment on the proposal for round off of the energy standard.**  

# DOE is currently considering amending its test procedure to require round

- off to the nearest kWh/year for energy use measurements. DOE has proposed round

off of the energy standards to the nearest kWh/year for consistency.54 | Program Name or Ancillary Text eere.energy.gov

54 Building Technologies Program 

## Background • DOE must publish an initial regulatory flexibility analysis if it cannot certify that the rule will not have a significant economic impact on a substantial number of small entities. Findings • DOE identified one small business manufacturer of residential refrigerators, refrigerator

- freezers, and freezers 

# Regulatory Flexibility Act

Issue 22: Impact on small businesses and small manufacturers: **DOE requests comment on the regulatory flexibility determination, as well as any information concerning small**  **businesses that could be impacted by this rulemaking and the nature and extent of those potential impacts of the proposed**  **energy conservation standards on small residential refrigeration product manufacturers.** 55 | Program Name or Ancillary Text eere.energy.gov

55 Building Technologies Program 

# How to Submit Comments...



#  Public Meeting
– Oral comments will be captured in the transcript and become part of the public record.


#  Written comments
– Preliminary comment period open until November 26 , 2010. Reference docket #EERE - 2008 - BT- STD - 0012 and/or RIN #1904 - AB79 Email: ResRefFreez - 2008 - STD - 0012@hq.doe.gov Mail: Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mail stop EE - 2J 1000 Independence Avenue, SW Washington DC, 20585 - 0121 Courier: Ms. Brenda Edwards - Jones U.S. Department of Energy Building Technologies Program 950 L’Enfant Plaza, SW, Suite 600 Washington DC, 20024 Telephone: (202) 586 - 2945