Building Technologies Program 

BUILDING TECHNOLOGIES PROGRAM

Framework Document Public Meeting on Energy Conservation Standards for Commercial Refrigeration Equipment

ChDepaEnerCRE

May 18, 2010
Building Technologies Program 

• Introductions• Role of the Facilitator• Ground Rules (norms)

– Listen as an ally– Use short, succinct statements/keep to the po– Hold sidebar conversations outside the room– Focus on issues, not personalities– One person speak at a time (raise hand to be 

your name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

Welcome and Introductions
Building Technologies Program 

Morning Agenda

9:00 – 9:30 am9:30 – 10:00 am10:00 – 10:30 am10:30 – 10:45 am10:45 – 11:15 am11:15 – 11:45 am11:45 – 12:15 pm

Agenda and Opening RemarksRegulatory History and RulemakiRulemaking ScopeBreakTest ProcedureMarket Technology AssessmentScreening and Engineering Analy
Building Technologies Program 

Afternoon Agenda

12:15 – 1:15 pm1:15 – 1:45 pm1:45 – 2:15 pm2:15 – 2:30 pm2:30 – 2:45 pm2:45 – 3:00 pm3:00 – 3:30 pm

3:30 pm

LunchEnergy Use Characterization & MaLife Cycle Cost and Payback PerioShipments Analysis and National BreakLCC Subgroup Analysis and ManuAnalysisUtility Impact Analysis, EmploymeEnvironmental Assessment, and RAnalysisClosing remarks; Other issues anAdjourn
Building Technologies Program 

Test ProcedurePreliminary Analysis

NOPR AnalysesClosing Remarks

Public Meeting Agenda

45672 Rulemaking Overview3 Scope

1 Introduction
Building Technologies Program 

Request for Comment

Issue Box In the Rulemaking Framework DocCommercial Refrigeration Equipment, DOE wecomment. Throughout this presentation, specbe raised for discussion on slides such as thisidentifying numbers corresponding to thosFramework Document. In addition, DOE has questions that are not in the Framework documquestions are identified by a letter. Nonethelesconcerning any part of the document or presenwelcome.
Building Technologies Program 

Contact Information for Feedback

In all correspondence, please refer to the Commercial REquipment rulemaking by:

– Commercial Refrigeration Equipment Rulemaking,– Docket Number EERE-2010-BT-STD-0003 , and

– Regulatory Identification Number (RIN) 1904-AC19

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

Comment period ends: June 7, 2010

Postal: Courier:

Ms. Brenda Edwards-JonesU.S. Department of EnergyBuilding Technologies ProgramMailstop: EE-2J, Room 1J-0181000 Independence Avenue, SWWashington, DC 20585-0121

Ms. Brenda EdU.S. DepartmeBuilding TechnFloor950 L’Enfant PWashington, DTel: 202-586-2
Building Technologies Program 

Purpose of the Framework Document Public Meeting

• Present the proposed procedural and analytical ap

evaluate energy conservation standards for commequipment.

• Provide a forum for public discussion of rulemakin• Encourage interested parties to submit data, inform

comments.

• Inform interested parties and facilitate the rulemak
Building Technologies Program 

Interested Parties Opening Statements

At this time DOE welcomes opening remarks on thdocument for commercial refrigeration equipment. 
Building Technologies Program 

Test ProcedurePreliminary Analysis

NOPR AnalysesClosing Remarks

Public Meeting Agenda

45672 Rulemaking Overview3 Scope

1 Introduction
Building Technologies Program 

Regulatory History

• Energy Policy and Conservation Act (EPCA) of 197

163).

– Established the energy conservation program.

• Energy Policy Act (EPACT) 2005 amendment to EP

– Prescribed standards for self-contained equipment w

January 1, 2010. 

– Directed DOE to develop and publish, by January 1, 2

ice cream freezers, remote-condensing equipment anequipment without doors.

– Directed DOE to determine whether to amend the sta

both by DOE and EPCA. If the determination were to DOE should publish amended standards by January second rulemaking process. (42 U.S.C. 6313(c)(5))
Building Technologies Program 

Regulatory History (contd.)

• DOE published a final rule on January 9, 2009 (74 

January 1, 2012. 

• Current round of rulemaking (initiated by this Frame

addresses the second directive from EPACT 2005.

• DOE must publish a rule amending standards by J

determines to amend the standards.

• Any amended standards adopted by DOE would ap

manufactured 3 years or more after the publication maximum of 5 years, in case DOE determines that inadequate. 
Building Technologies Program 

EPCA Factors

• 42 U.S.C. 6295(o)(2)(B)(i) directs DOE to conside

setting energy conservation standards:

EPCA Factors DO

1. Economic impact on consumers and 

manufacturers

Life-Cycle CoManufacturer 

2. Lifetime operating cost savings compared 

to increased cost for the equipment

Life-Cycle Co

3. Total projected energy savings National Impa4. Impact on utility or performance Engineering A

Screening An

5. Impact of any lessening of competition Manufacturer 6. Need for national energy conservation National Impa7. Other factors the Secretary considers 

relevant

EnvironmentaUtility Impact Employment 
Building Technologies Program 

Steps in the Standards Rulemaking: Framework Document

Framework

Document

Preliminary 

Analysis NOPR Fina

Rule

Today

• Today’s public meeting covers the Framework Docu

Refrigeration Equipment.

• Federal Register Notice of Public Meeting, 75 FR 24

– Gives notice of the public meeting and availability of t

Document being discussed today.

• Framework Document

– Provides an overview of the rulemaking process and e

parties early participation.

– Encourages interested parties to submit comments by – The Framework Document and materials from today’s 

available online:http://www1.eere.energy.gov/buildings/appliance_standards/equipment.html
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise Preliminary Analysis

EngineeringAnalysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Steps in the Standards Rulemaking: Final Rule

Revise NOPR 

Analyses

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Timeline for CRE Standards Rulemaking

Framework 

Document 

Public Meeting

May 18, 2010

Points of Interested Parties’ Participation 

Preliminary Analysis

Public Meeting

(Tentative: Spring 2011)

NOPR

Public Mee

(Tentative: Winte

2010 2011 2012 2013 2014 
Building Technologies Program 

Request for Comment

Additional Comment A Any comments on rulemaking overview and proposed schedu
Building Technologies Program 

Test ProcedurePreliminary Analysis

NOPR AnalysesClosing Remarks

Public Meeting Agenda

45672 Rulemaking Overview3 Scope

1 Introduction
Building Technologies Program 

Current Commercial Refrigeration Equipment Standards – EPCA

• EPCA, as modified by EPACT 2005, prescribed standards 

commercial refrigeration equipment with doors, effective J

Category Maxi

Refrigerators with solid doors Refrigerators with transparent doors 

Freezers with solid doors Freezers with transparent doors Refrigerator/freezers with solid doors the Self-contained refrigerators with transparent doors designed for pulldown temperature applications 

• In 2009, DOE set new standards for remote condensing c

refrigeration equipment, self-contained equipment withoucream freezers. These requirements are effective Janua

• DOE intends to include in the scope of the current rulema

equipment with standards prescribed in EPACT 2005 as wfor which it established standards in 2009.

Note: V = volume, AV = Adjusted Volume
Building Technologies Program 

Standby and Off Mode Standards

• EPCA, as modified by EISA 2007, directs DOE to i

and off-mode standards

• Commercial refrigeration equipment, however, gen

constantly to maintain product at a desired tempera

• DOE believes that only the active mode of energy c

applicable to this equipment. However, it will examaddress it in the analyses conducted in this rulema

Additional Comment B DOE welcomes commenfrom the standby mode and off mode provisions froincluding: (a) whether the standby mode and off mapplicable to this equipment; (b) whether DOE shoprocedure for commercial refrigeration equipment; DOE should incorporate standby mode and off moconsumption into its analysis for the energy conse
Building Technologies Program 

Secondary Coolant Applications

• Some supermarket applications utilize “seconda

systems.

• In the 2009 final rule, DOE determined that langu

precluded coverage of secondary coolant equipm

• DOE also concluded that EPCA interpretation wa

AHRI Standard 1200-2006, which explicitly exclucoolant applications.

• Under current statute DOE has determined that s

coolant equipment will not be covered in this rule

Additional Comment C DOE welcomes commenregarding the relevance of secondary-coolant applirulemaking. 
Building Technologies Program 

Stakeholder Equipment Issues

• DOE has received letters from manufacturers of 

contained service over counter and self-contain

refrigeration units with doors stating that they arEPCA standards for this equipment.

– OHA determined that DOE does not have authori

exceptions or exemptions to amend standards focounter and self-contained under-counter refrigerdoors. 

• Classification issue regarding hybrid doors (mix

transparent doors). 

Item 1-3 DOE welcomes comment on these and oregarding commercial refrigeration equipment.
Building Technologies Program 

Test ProcedurePreliminary Analysis

NOPR AnalysesClosing Remarks

Public Meeting Agenda

45672 Rulemaking Overview3 Scope

1 Introduction
Building Technologies Program 

Test Procedure Schedule

• TP NOPR will be published by February/March 20

with ECS Preliminary Analysis.

• TP NOPR Public Meeting will be held separate fro

meeting.

• TP Final Rule will be published before the publica

NOPR.

Energy Conservation 

Standards (ECS)

Test Procedure (TP)

Framework

Document

Preliminary 

Analysis NOPR 

NOPR Final Rule
Building Technologies Program 

• Previous DOE test procedure, published in 

December 2006, adapted ANSI/ARI Standard 1200-2006 as the DOE test procedure. 

– References ASHRAE Standard 72-2005 as the 

method of test and AHAM Standard HRF-1-2004 for measuring refrigerated compartment volume.

• An updated AHRI test procedure has since been 

published – AHRI 1200-2008. 

– References the updated AHAM Standard HRF-1-

2008. 

• DOE is considering incorporating AHRI 1200-2008 

into the CRE test procedure.

Test Procedure Updates
Building Technologies Program 

Potential Test Procedures Modifications

• DOE is considering certain technology options 

for the energy conservation standards: 

– lighting sensors and controls – infiltration reduction devices– other energy management or part-load controls 

• Current DOE test procedures are unable to quantify 

options.

• DOE is considering amending the test procedure to • DOE suggests the following methods to develop new 

accommodate these technologies:

– Analytical methods– Physical testing– Combination of analytical methods and physical testin
Building Technologies Program 

• Analytical Methods

– Specify a “percent time off” or other scaling facto

data to be used in calculating daily energy consu

– Similar to the method used for Alternate Compon

AHRI 1200. 

Methods for Evaluation of Energy Efficiency Features

Advantages

• Consistent.• Will not cause 

significant increase in testing burden or expense.

Limita

• Depende

availabilitempirical 

• May not c

differenceconsumptsimilar tec
Building Technologies Program 

• Physical Testing

– Specify triggering schedules or part-load test con

of test that would occur as part of the 24 hour tes

test, if necessary. 

– Triggering schedule similar to treatment of door o

Standard 72–2005. 

Methods for Evaluation of Energy Efficiency Features (contd.)

Advantages

• Accurate.• Represents 

differences in energy consumption for similar technologies. 

Limitat

• Additional t

schedules could be impracticalburdensomexpensive. 
Building Technologies Program 

• Combination of Physical Testing and Ana

– Complete limited additional testing and use with 

calculate daily energy consumption.

– Similar to the calculation of Integrated Part Load 

Conditioning and Air-Source Heat Pump Equipm

Methods for Evaluation of Energy Efficiency Features (contd.)

Advantages

• Does not introduce 

more complexities into current test.

Limita

• Additional 

increase teburden an

• May not ca

differences consumptisimilar tec
Building Technologies Program 

Request for Comment

Item 1-1 DOE requests comment regarding the devupdating test procedures for the commercial refrigecovered under this rulemaking. Additional Comment D DOE is interested in any etest procedures which address energy conservation data to support test procedure development. 
Building Technologies Program 

Test ProcedurePreliminary Analysis

NOPR AnalysesClosing Remarks

Public Meeting Agenda

45672 Rulemaking Overview3 Scope

1 Introduction
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Market and Technology Assessment

Purpose

• Characterize the markets, the commercial refrig

industry, and the potential technological measurefficiency

Method

• Identify and characterize manufacturers of comm

refrigeration equipment;

• Estimate shipments and trends in the market;• Identify regulatory and non-regulatory initiatives 

improve the efficiency of the equipment covered rulemaking; and

• Identify technologies that could improve efficienc
Building Technologies Program 

Relationship of Market and Technology Assessment to Other Analyses

Market and Technology 

Assessment Equ

Technology Options to improve efficiency

Screening Analysis

Design Options to improve efficiency

Engineering Analysis
Building Technologies Program 

Request for Comments

Additional Comment E DOE welcomes input and estimates of market shares, equipment features, atrends for the commercial refrigeration equipment crulemaking. DOE also seeks input on shipment estcommercial refrigeration equipment.Additional Comment F DOE welcomes input on covered equipment as well as distribution channels of covered equipment.
Building Technologies Program 

Equipment Classes

• DOE divides covered equipment into classes based 

related features that justify different standard levelsaffecting consumer utility (42 U.S.C. 6295(q))

• DOE establishes separate energy conservation sta

equipment class.

• In the 2009 Final Rule, DOE established equipmen

equipment covered by that rulemaking, and includedesignations for the equipment for which standards 

• DOE could also further subdivide existing classes, 

due to inherent differences within equipment currenclass. 

Item 3-4 DOE welcomes comments on equipment commercial refrigeration equipment and approacheclasses in accordance with the requirements of 42 
Building Technologies Program 

Technology Options Under Consideration

Technology options applicable to all commercial refequipment:Higher-efficiency lighting Higher-efficiency Remote lighting ballast location Higher-efficiency Higher-efficiency evaporator fan motors Variable-speed evIncreased evaporator surface area or efficiency Evaporator fan moHigher-efficiency evaporator fan blades Low-pressure diffAnti-sweat heater controls Improved or increHot-gas defrost Anti-fog films on tDefrost-cycle controls Occupancy sensoVacuum insulated panels
Building Technologies Program 

Technology Options Under Consideration (contd.)

Technology options applicable to equipment without Air curtain design Night curtains placStrip curtains Radiation shieldsTechnology options applicable self-contained equipmHigher-efficiency compressors Liquid-to-suction hIncreased condenser surface area or efficiency

Higher-efficiency cmotors

Variable-speed condenser fan motors Condenser-fan-moHigher-efficiency condenser fan blades
Building Technologies Program 

Request for Comments

Item 3-5 DOE welcomes comments on the prelimoptions identified in this section and whether there technology options it should consider. In commentoptions, please discuss any potential impacts on sperformance, and consumer utility.
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Screening Analysis

Impacts on health or safety

Impacts on equipment utility or availabi

consumers

Practicability to manufacture, install, and 

Technological feasibility

Purpose

• Screen out technology options that DOE will not c

engineering analysis for commercial refrigeration 

Approach

• DOE will evaluate each technology option based 

criteria:
Building Technologies Program 

Request for Comments

Item 4-1 DOE welcomes comments on how the focriteria might apply to any additional technology opinterested party recommends to DOE.
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Goals of the Engineering Analysis

• A key factor in setting the standard is the increa

efficient equipment.

• The Engineering Analysis determines the relatio

cost and efficiency.

Rulema

• Life-Cyc

Payback 

• Manufac

Analysis 

• Employ

Analysis

Manufacturer Selling Price –

Efficiency Relationship

Manufacturer 

Selling Price

Efficiency Level
Building Technologies Program 

Engineering Analysis Methodology

Õ Choose equipment classes that represent 

volume for the engineering analysis. 

Õ Define characteristics of models in each re

equipment class to serve as reference poichanges due to more stringent standard le

Õ Identify more efficient substitutes using de

approach methodology.

Õ Determine manufacturer production costs 

equipment and their more efficient substituprices based on production costs and mar

Õ Develop candidate standard levels that sp

equipment efficiencies.

Õ Scale results to equipment classes not ana

Scale Results

Choose 

Representative 

Equipment 

Classes

Define Baseline 

Models

Identify

Efficient 

Substitutes

Develop

Manufacturer 

Selling Price

Develop

Candidate 

Standard Levels
Building Technologies Program 

Engineering Analysis Methodology

Additional Comment G DOE welcomintended preliminary engineering analy

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Define Baseline 

Models

Identify

Efficient 

Substitutes

Develop

Manufacturer 

Selling Price

Develop

Candidate 

Standard Levels
Building Technologies Program 

Proprietary Designs

• DOE will evaluate all design options that are com

available or present in a working prototype, includesigns and technologies.

• Proprietary designs will only be considered if the

a unique path to a given efficiency level.

• The confidentiality of manufacturers will be main

Item 5-5 DOE seeks information on proprietary dshould be aware of for the commercial refrigeratioequipment under consideration in this rulemakingproprietary designs exist, how DOE can acquire tnecessary for evaluating these designs.
Building Technologies Program 

Representative Sizes

Item 5-6 DOE welcomes comment on the selecrepresentative equipment sizes for the commercrefrigeration equipment under consideration in th

• In the engineering analysis, DOE will select equip

which best represent typical offerings within each 

• Selection of representative sizes will allow for the 

the majority of the equipment in the classes.

• DOE developed representative equipment sizes a

final rule, and intends to use those sizes as startin

engineering analysis in this rulemaking.
Building Technologies Program 

Normalization Metrics

• The standards prescribed by EPCA use a metric of 

compartment volume for equipment with both transdoors.

• In the 2009 rulemaking, DOE developed standards 

– Total display area (TDA) for open cases and equipm

doors.

– Refrigerated compartment volume for equipment with 

• In this rulemaking, DOE is considering using a con

metric for similar equipment classes.

• DOE needs to develop a conversion between the e

and a TDA metric in order to translate the existing E

terms of TDA for equipment with transparent doors
Building Technologies Program 

Request for Comments

Item 5-8 DOE seeks comment regarding mapping volume and total display area metrics, as well as tto translate baseline energy use between the two Item 5-9 DOE requests feedback regarding specifclasses which may need to be subdivided, or equicategories which may need their own equipment crevised normalization metrics be used in this rulem
Building Technologies Program 

Outside Regulatory Changes

• DOE takes into consideration the effects on man

other regulatory changes outside of the standardprocess.

Additional Comment H DOE welcomes commregulatory burdens and changes that should be the engineering analysis of commercial refrigeraequipment.Additional Comment I DOE welcomes commeengineering issues that could affect the enginee
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Energy Use Characterization

• Develop energy use and peak electricity demand 

buildings that use commercial refrigeration equipm

• Provide the basis for the unit energy costs used in 

Analysis.

Purpose

Background (2009 final rule)

• Energy consumption estimates from engineering 

as basis for Energy Use Characterization.

• DOE used a whole building simulation tool to exa

improvements on building HVAC for a supermarkeclimates. Overall effect was found to be negligib

• Lighting in display case was assumed to operate 

specified in the test procedure. Sensitivity study to 

assumptions was presented in Energy Use Chara
Building Technologies Program 

Energy Use Characterization: Issues

• New rule will have a larger share of self-contained 

– Self-contained equipment has a greater impact on b

compared to remote-condensing equipment. 

– Previous sources/studies for annual energy consum

focused on remote condensing equipment, so additinecessary. 

• Fluorescent vs. LED lighting operating hours assum

– Fluorescent lighting was assumed to operate 24-hou

and moisture-related maintenance issues 

– LED lighting does not face this problem and is more 

shutoff or dimming, e.g. when triggered by occupanc
Building Technologies Program 

Request for Comments

Item 6-1 DOE seeks input on whether the impact of highrefrigeration equipment in self-contained equipment on thconditioning loads is significant enough to warrant taking in the energy analysis. If so, what methods could best be the net energy consumption and load impacts of higher ecommercial refrigeration equipment in buildings using thiItem 6-2 DOE seeks data or data sources that could be uthe operating hours assumptions to assess lighting energlighting and lighting control technologies contained in comrefrigeration equipment.Item 6-3 DOE seeks data or data sources that could be uthe energy use of commercial refrigeration equipment andeviate from that estimated using the DOE test procedurItem 6-4 DOE seeks feedback on this approach to the enuse load characterization.
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Markups for Equipment Price Determination

Purpose

• Develop overall distribution chain price markups fro

manufacturer to the consumer.

• Establish the consumer prices for both baseline eq

equipment at higher standard levels.

Manufacturer

Consumer Consumer

Manufacturer

Distributor Distributor

Distribution Channel 1 Distribution Channel 2 Distribu

Mech. Contractor

Distribution Channels
Building Technologies Program 

Markups for Equipment Price Determination

• Two Types of Markups in Distribution Chain: Baseline 

• Baseline Markups

– Markups relate consumer price to cost of goods sol– Baseline markups relate price to cost prior to a cha– Baseline markups indicate a consumer price that co

Distributor’s or Contractor’s expenses plus profit.

• Incremental Markups

– Incremental markups relate the incremental change 

the incremental change in CGS.

– Certain costs, such as direct labor costs (salaries, p

occupancy) do not vary with efficiency induced charemain constant in the calculation of incremental m

– Incremental markups cover only expenses that vary 

case, expenses that increase due to an increase in 
Building Technologies Program 

Request for Comments

Item 7-1 DOE also requests information on the frashipments expected for each distribution channel frefrigeration equipment covered under this rulemawhether the distribution channels derived for food establishments adequately covers sales to food seestablishments. Item 7-2 DOE requests feedback on its plan to use distribution channel markups for the LCC analysisItem 7-3 DOE seeks comment on other sources othat could be used to characterize markups for the refrigeration industry.Item 7-4 DOE seeks comment on appropriate transhipping costs to include in the analysis and whethare likely to vary for higher efficiency equipment. 
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Life-Cycle Cost (LCC) and Payback Period (PBP) Analysis

Purpose

• Assess the net LCC and PBP for different efficien

Analysis

• LCC equals consumer price plus the sum of annu

discounted to a particular base year.

• Economic evaluation from the consumer perspect• Analysis implemented in an Excel® spreadsheet.

• Results expressed as LCC difference (baseline m• Simple Payback equals the incremental first cost 

operating cost savings for one year.

Consumer Life 

Cycle Cost

(Baseline and Standard)

Operating Cost 

(Sum & discount to 

present value)

First Cost

(Consumer Price & 

Installation)
Building Technologies Program 

Life-Cycle Cost and Payback Period Analysis

LCC Flowc

From 

Engineering 

Analysis

(Price is a 

Function of 

Efficiency)

From Markups 

for Equipment 

Price 

Determination 

Analysis

From Energy 

Use 

Characterization 

Analysis 

Energy

Consumption

Power

Demand

Distributor

Markup

Sales Tax

Mechanical

Contractor

Markup

Consumer

Price

Total Installed

Cost

Annual Energy

Expense

Annual

Operating

Expense

Payb

Peri
Building Technologies Program 

Energy Prices

• Energy prices are necessary to convert the energy 

buildings analyzed to energy costs.

• DOE intends to use regional average electricity and 

prices for the commercial building sector for its anarefrigeration equipment.

• DOE will use projections of national average energ

from the most recent EIA Annual Energy Outlook (Afuture energy prices in the LCC analysis.

Item 8-1 DOE welcomes input on the electricity this analysis.
Building Technologies Program 

Life-Cycle Cost Discount Rates

• DOE uses the discount rate to determine the prese

(future) operating expenses.

• DOE will derive the LCC discount rates by estimati

average cost of capital (WACC) for companies that commercial refrigeration equipment. 

• DOE suggests that the WACC be derived from esti

capital of companies and store chains primarily in tfood service businesses (e.g. grocery and convenierestaurants).

Item 8-2 DOE seeks comment on the intended approdiscount rates for consumers.Item 8-3 Which commercial entities beyond grocery srestaurants should be considered in the evaluation of addition, do stakeholders feel government purchases are large enough to require that they be included in thdiscount rates?
Building Technologies Program 

Installation, Maintenance, and Repair Costs

2009 Rulemaking Approach• Installation costs: Do not change with increased effic• Maintenance & Repair costs:

– Source: RS Means Facilities Maintenance & Repair Cost Dat– Preventive maintenance costs remain constant.– Estimated the lighting maintenance cost based on each displ

design option analysis was performed.

Item 8-4 DOE seeks feedback on whether it is cothat changes in preventative maintenance, repair, costs will be negligible for equipment with lower econsumption.Item 8-5 If it is not appropriate to assume that chamaintenance, repair, or installation costs would be equipment with lower energy consumption, DOE son appropriate methodologies for assessing how twould change for equipment with lower energy co
Building Technologies Program 

Equipment Lifetimes

2009 Rulemaking:

– Assumption: equipment is typically replaced whe

renovated 

– 10 years for large grocery stores and multiline re– 15 years for small grocery stores and convenien

Item 8-6 DOE seeks comment on appropriate eqlifetimes for the classes of equipment covered in rulemaking. 
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Shipment Analysis

Purpose

• Estimate changes in shipments due to potential 

energy efficiency standards.

Approach

• Data sources (2009 rulemaking): AHRI, Applianc

Freedonia, US Census Bureau, Annual Energy O

• Estimate base case forecast – what is the effect 

new/amended energy standards were not impos

• Estimate impact of standards – increase/decrea

in each equipment class due to new/amended s
Building Technologies Program 

Shipment Analysis (contd.)

Approach (continued)

• Estimate future shipments based on:

– New construction estimates from AEO– Historical rates of ownership– Equipment lifetimes used in LCC and PBP analyses

• Separately account for units installed in new constru

buildings

• Quantify sensitivity of shipments, if necessary, to pu

operating-cost savings
Building Technologies Program 

Request for Comment

Item 9-1 DOE seeks information on historical shipmerefrigeration equipment for each equipment class, as trend data regarding relative growth in each equipmeItem 9-2 DOE seeks information on representative saeach equipment class covered under this rulemakingtrend data regarding relative growth in each equipmeItem 9-3 DOE requests input from manufacturers on of new energy conservation standards on equipment interested parties are also welcome to provide input. input on any market-pull programs that currently exist adoption of more-efficient equipment.
Building Technologies Program 

Steps in the Standards Rulemaking: Preliminary Analysis

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups for Equipment Price Determination

Life-CycleCost andPayback Period Analysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

National Impact Analysis

Purpose

• Estimate National Energy Savings (NES) and Nati

Value (NPV) of consumer savings for higher-efficielevels.

Analysis

• Rebound effect was neglected in 2009 rulemaking 

CRE is operated 24 hours and thus there will be oincrease in the operation of CRE, if at all, due to h

• NES spreadsheets will be used for calculation of N

consumer savings.
Building Technologies Program 

National Impact Analysis

• National Energy Savings:

– Compare national energy consumption of base ca

efficiency equipment – year-on-year calculations.

– Site-to-source conversion factors account for ener

generation, transmission, and distribution of electrNational Energy Modeling System (NEMS).

• NPV of consumer savings will be calculated, as p

guidance, with two different discount rates 3% an

Item 10-1 DOE welcomes comments from interesteNES spreadsheet models it plans to use for estimatimpacts of amended energy conservation standards refrigeration equipment.
Building Technologies Program 

Test ProcedurePreliminary Analysis

NOPR AnalysesClosing Remarks

Public Meeting Agenda

45672 Rulemaking Overview3 Scope

1 Introduction
Building Technologies Program 

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise Preliminary Analysis

EngineeringAnalysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise Preliminary Analysis

EngineeringAnalysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Life-Cycle Cost Subgroup Analysis

Purpose

• Analyze the economic impacts of standards on custo

may be disproportionately impacted compared with tpopulation.

• Subgroups include small businesses, ethnic minoritie

consumers, and senior citizens.

Analysis

• In 2009 rulemaking, small grocery stores and conven

examined as a subgroup.

• Due to increased scope of this rulemaking, independ

may be considered as small business and a subgrou

Item 11-1 DOE seeks input as to what customeDOE should consider in the present rulemaking
Building Technologies Program 

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise Preliminary Analysis

EngineeringAnalysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Manufacturer Impact Analysis

Purpose

• Assess the impacts of standards on manufacture• Identify and estimate impacts on manufacturer s

may be more severely impacted than the industr

• Examine the impact of cumulative regulatory bur

industry.

Method

• Analyze industry cash flow and net present value 

the Government Regulatory Impact Model (GRIM

• Interview manufacturers to refine inputs to the G

subgroup analyses, and address qualitative issu

Output

• Industry NPV impacts• Subgroup NPV impacts• Other impacts
Building Technologies Program 

MIA Methodology

• The MIA consists of three main phases: 

Industry profile

Develop straw-man GRIM

Develop interview guide

Intervi& industwide / subgroanalys

Phase 2 

Preliminary MIA Interviews

Phase 1

Preliminary Analysis

NOPR
Building Technologies Program 

Request for Comments

Item 12-2 DOE seeks comment on the subgroucommercial refrigeration equipment manufactureshould consider in a manufacturer subgroup anaItem 12-3 What regulations or pending regulatioDOE consider in the analysis of cumulative regu
Building Technologies Program 

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise Preliminary Analysis

EngineeringAnalysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Utility Impact Analysis

Purpose

• Assess the overall impact on the electric utility i

Method

• DOE plans to use NEMS (EIA 2009), developed 

DOE/EIA for their Annual Energy Outlook reportthe Utility Impact Analysis.

• Use the energy savings calculated from the NE

analysis to reduce the sector electrical loads in 

Item 13-1 DOE seeks input from interested parties oof NEMS to conduct the utility impact analysis. 
Building Technologies Program 

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise Preliminary Analysis

EngineeringAnalysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Employment Impact Analysis

Purpose

• Assess the overall impact on national employment 

of efficiency standards.

• Include both direct and indirect employment impac

– Direct employment impacts are estimated in the man

analysis.

– Indirect employment impacts result from shifting con

among goods and services ( “substitution effect”) anand energy costs (“income effect”).

Analysis

• DOE intends to use PNNL’s Impact of Sector Ener

(ImSET) model for the evaluation of indirect emplo

Item 14-1 DOE requests feedback on its approach to impact analysis. 
Building Technologies Program 

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise Preliminary Analysis

EngineeringAnalysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Environmental Assessment

Purpose

• To consider and quantify, where applicable, the e

effects of new/amended energy conservation sta

Analysis

• The emissions that will be considered: Carbon D

Sulphur Dioxide (SO2), Nitrogen Oxides (NOx), M

Particulate Matter.

• DOE will use the NEMS-BT model to calculate al

reductions.

• Net benefit of the standard is the difference betw

estimated at each efficiency level and the AEO R

• Emissions reductions will be monetized in accord

recent interagency guidance.
Building Technologies Program 

Request for Comments

Item 15-1 DOE seeks input on its plans to use NEMSenvironmental impact analysis on the equipment covrulemaking. DOE is particularly interested in whether other approaches to the Environmental Assessment tconsider and the advantages and disadvantages of e
Building Technologies Program 

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise Preliminary Analysis

EngineeringAnalysis

Framework

Document

Preliminary 

Analysis NOPR Final Rule
Building Technologies Program 

Regulatory Impact Analysis

Purpose

• Explore the potential of non-regulatory alternati

result in new manufacturing efficiency standard

Analysis

• DOE recognizes that voluntary and other non-re

by the manufacturers, utilities, and other interesresult in substantial efficiency improvements.

• DOE will consider the impacts of such initiatives

Item 17-1 DOE seeks comment regarding progrshould be examined as optional, non-regulatory 
Building Technologies Program 

Test ProcedurePreliminary Analysis

NOPR AnalysesClosing Remarks

Public Meeting Agenda

45672 Rulemaking Overview3 Scope

1 Introduction
Building Technologies Program 

Contact Information for Feedback

In all correspondence, please refer to the Commercial REquipment rulemaking by:

– Commercial Refrigeration Equipment Rulemaking,– Docket Number EERE-2010-BT-STD-0003 , and

– Regulatory Identification Number (RIN) 1904-AC19

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

Comment period ends: June 7, 2010

Postal: Courier:

Ms. Brenda Edwards-JonesU.S. Department of EnergyBuilding Technologies ProgramMailstop: EE-2J, Room 1J-0181000 Independence Avenue, SWWashington, DC 20585-0121

Ms. Brenda EdU.S. DepartmeBuilding TechnFloor950 L’Enfant PWashington, DTel: 202-586-2
Building Technologies Program 

Relevant Webpages

• DOE Appliance Standards

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

• Commercial Refrigeration Equipment Rule

– http://www2.eere.energy.gov/buildings/appliance_st

efrigeration_equipment.html

• Contact Charles Llenza, Project Manager, from the A

Program for additional information: 

– Charles.Llenza@ee.doe.gov– 202.586.2192

• Contact John Cymbalsky, Supervisor, from the Appl

Program for additional information: 

– John.Cymbalsky@ee.doe.gov– 202.287.1692