Appliance Standards Program

October 9, 2013

Email: WICF-2008-STD-0015@ee.doe.gov

Walk-in Coolers and Freezers (WICF)

Notice of Proposed Rulemaking (NOPR)

Public Meeting on Energy Conservation Standards 

(ECS)
2 

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of this 

meeting.

– Be concise – share the ‘air-time’.

– Keep the focus here – cell phones on silent; limit sidebar conversations.

– Webinar participants turn phone on mute; ‘raise your hand’ to be recognized 

to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3 

Agenda

9:00 – 9:10 am Welcome, Introductions, Opening Statements

9:10 – 10:00 am Overview, Scope, Market and Technology Assessment, Screening 

Analysis

10:00 – 10:45 am Engineering Analysis

10:45 – 11:00 am Break 

11:00 – 11:30 am Markup Analysis, Energy Use, Life-Cycle Cost and Payback Period 

Analysis

11:30 am – 12:00 pm Shipments, National Impact Analysis

12:00 pm – 1:00 pm Lunch

1:00 – 1:30 pm Manufacturer Impact Analysis

1:30 – 2:00 pm NOPR Analysis: Utility Impact Analysis, Employment Impact 

Analysis, Environmental Assessment, Regulatory Impact Analysis

2:00 – 2:15 pm Break 

2:15 – 2:45 pm Proposed Standard

2:45 – 3:00 pm Closing Remarks
4 

Listening Via the Webcast

• The Department is broadcasting this meeting live over the 

Internet.

• DOE is providing the webcast to accommodate stakeholders 

that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
5 

Purpose of the Public Meeting

• Purpose

- To invite comment on proposed energy conservation standard levels;

- To present methodologies and characterize results of the rulemaking 

analyses;

- To discuss specific issues related to each analysis;

- To seek input from interested parties on methodologies, assumptions, data 

sources, and results from the analyses; and

- To describe next steps in the rulemaking.

• Comments from Participants

- Participants are invited to provide summary comments or statements and 

raise additional issues for discussion. 

- NOPR comment period closes November 12, 2013.
6 

Issues for Discussion

• The deadline for submitting comments is November 12, 2013. 

Issue Box: DOE welcomes comments, data, and information 

concerning the standards it is considering for WICFs. Whether 

invited by an issue box or not, comments are welcome on any 

part of DOE’s analysis.

• Issue “boxes” correspond to the list of issues for which the 

Department seeks comments.

• A list of issues are in the NOPR notice, available at: 

 

http://www.regulations.gov/#!documentDetail;D=EERE-2008-BT-STD-0015-0073
7 

How to Submit Written Comments

• In all correspondence, please refer to the WICF rulemaking by:

– Walk-in Coolers and Freezers Energy Conservation Standard Rulemaking,

– Docket Number EERE-2008-BT-STD-0015, and

– Regulatory Identification Number (RIN) 1904-AB86. 

• Email: WICF-2008-STD-0015@ee.doe.gov 

• Comment period closes: November 12, 2013, 11:59 PM EDT

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J 

1000 Independence Avenue, SW

Washington, DC 20585-0121 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945 
8 

Opening Remarks

Meeting participants are invited to provide opening remarks 

or statements at this time.
9 

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures; Metrics; 

2 Market & Technology; Screening; 

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
10

EPCA Factors

42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors when setting 

energy conservation standards:

EPCA Factors DOE Analysis

1. Economic impact on customers and 

manufacturers

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

2. Lifetime operating cost savings compared 

to increased cost for the product Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis

Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact 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
11

• Walk-in cooler or walk-in freezer (WICF) means an enclosed storage space 

refrigerated to temperatures, respectively, at or below 55 degrees Fahrenheit 

and above 32 degrees Fahrenheit; and at or below 32 degrees Fahrenheit, 

that can be walked into, and has a total chilled storage area of less than 3,000 

square feet.

• Products designed and marketed exclusively for medical, scientific, or 

research purposes are excluded.

• EISA 2007 established the current energy conservation standards for walk-in 

coolers and freezers sold on or after January 1, 2009. (42 U.S.C. 6313(f)(1)-(3))

• The current standards are prescriptive standards that require certain 

components or characteristics for WICFs. For example:

– Wall, ceiling, and door insulation of at least R-25 for coolers and R-32 for freezers

– Electronically commutated motors for evaporator fan motors of under 1 

horsepower and less than 460 volts

– Certain anti-sweat heater requirements

– And others. All current standards can be found at 10 CFR 431.306.

Current Standards
12

• DOE test procedures are used for certifying compliance with standards. 

• For certifying compliance with current prescriptive standards for R-value 

of panels:

– Foam shall be tested using ASTM C518-04, Standard Test Method for 

Steady-State Thermal Transmission Properties by Means of the Heat Flow 

Meter Apparatus. 

• For certifying compliance with the standards proposed in this NOPR:

– U-factor, conduction load, and energy use of panels are determined by 

conducting the test procedure in Appendix A to Subpart R of 10 CFR 431, 

sections 4.1-4.3. 

– Energy use of doors is determined by conducting the test procedure in 

Appendix A to Subpart R of 10 CFR 431, sections 4.4-4.5. 

– Annual Walk-in Energy Factor of walk-in cooler and walk-in freezer 

refrigeration systems is determined by conducting the test procedure set 

forth in AHRI 1250 (I-P)-2009, 2009 Standard for Performance Rating of 

Walk-In Coolers and Freezers.

• All current DOE test procedures for WICFs can be found at 10 CFR 431.304.

Test Procedures
13

• DOE is proposing to set specific component standards for the panels, display 

doors, non-display doors, and refrigeration system of a walk-in, and not set a 

single standard for an assembled walk-in.

• These components are typically produced by different manufacturers. Under this 

approach, each manufacturer would only be responsible for certifying the 

component or components they manufacture.

• The modular nature of a walk-in means it is constructed of standardized 

components that can be assembled in a virtually infinite number of 

configurations that may affect the overall consumption of a given walk-in unit.

• Requiring a whole-walk-in performance standard would be likely to present 

significant testing and enforcement burdens.

Scope of Coverage - Component-Level Standards

Issue 1: DOE seeks comment on the approach of setting 

standards at the component level for walk-ins.
14

• The energy standards for each component are expressed in terms of 

component-specific metrics:

– Refrigeration Systems: Minimum Annual Walk-In Energy Factor (AWEF) 

(represents the ratio of the heat removed from the walk-in to the 

energy input of the refrigeration system, over one year)

– Panels: Maximum U-factor (the amount of heat conducted through the 

panel per hour, per square foot of panel area, per degree Fahrenheit of 

temperature difference across the panel)

– Doors: Maximum daily energy use (a combination of the electrical 

energy used by the door components, plus the estimated energy used 

by the refrigeration system to reject the heat conducted through the 

door. 

Component Standards - Metrics

Issue 10: DOE seeks comment on the proposed metrics.
15

Walk-in Coolers and Freezers Rulemaking Schedule

Milestone Date

Framework Document January 2009

Notice of Public Meeting and Availability of the Preliminary 

Technical Support Document April 2010

Notice of Proposed Rulemaking (NOPR) September 2013

Final Rule, Statutory Deadline January 2012

Final Rule (projected) April 2014

Compliance Date (projected) April 2017

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 
16

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures; Metrics;

2 Market & Technology; Screening; 

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
17

NOPR Rulemaking Stage

 Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
18

Market Analysis - Performance Data

• DOE’s analysis of market data used catalogue and existing component 

performance data to estimate the number of products on the market at 

varying efficiency levels.

• However, WICF equipment has yet to be rated for efficiency by 

manufacturers, nor have the proposed metrics previously been used for 

the equipment. 

• More detailed information could help improve DOE’s analysis and 

knowledge of the current market.

Issue 2: DOE requests that interested parties submit market 

performance data, preferably based on the proposed metrics, 

to help inform DOE’s analysis.

Details of the Market and Technology Assessment can be found in chapter 3 of the TSD
19

Equipment Classes: Doors 

• DOE proposes separate equipment classes for display doors, passage 

doors, and freight doors. 

• DOE is proposing to update the definitions of these components as 

follows:

• Display door means a door that: 

(1) Is designed for product display; or 

(2) Has 75 percent or more of its surface area composed of glass or 

another transparent material.

• Freight door means a door that is not a display door and is equal to or 

larger than 4 feet wide and 8 feet tall.

• Passage door means a door that is not a freight or display door. 

• For each type of door, DOE also proposes to create separate equipment 

classes for cooler doors and freezer doors.

Issue 3: DOE requests comment on the definitions relating to 

door equipment classes.

Details of the Market and Technology Assessment can be found in chapter 3 of the TSD
20

Equipment Classes: Panels

• DOE proposes three classes for panels:

– Structural cooler panels

– Structural freezer panels

– Freezer floor panels

• Structural panels include panels used to construct the ceiling or wall of a 

walk-in and provide structure to the walk-in. Cooler and freezer structural 

panels are rated differently and have different baseline requirements 

under EPCA.

• Freezer floor panels are panels used to construct the floor of a walk-in 

freezer and have certain baseline requirements under EPCA. They have 

additional structural members to support the load of people, product, 

and other objects. DOE is proposing standards for freezer floor panels in 

this rulemaking.

Details of the Market and Technology Assessment can be found in chapter 3 of the TSD
21

Equipment Classes: Refrigeration Systems

• DOE is proposing separate refrigeration classes for:

– Medium temperature vs. low temperature systems. Consistent with the statutory 

distinction between coolers and freezers, medium temperature systems operate above 32 

F and low temperature systems operate at or below 32 F.

– Dedicated condensing vs. multiplex condensing. In a dedicated condensing system, only 

one condensing unit serves a single walk-in with one or more unit coolers. A multiplex 

condensing system involves one or more unit coolers in a walk-in connected to a 

compressor rack and condensing system serving other pieces of equipment. For multiplex 

systems, only the unit cooler is covered.

– Indoor vs. outdoor condensing. For dedicated condensing systems, DOE is proposing 

different equipment classes for systems with condensers located indoors vs. outdoors. 

Outdoor systems are exposed to a wider range of ambient temperatures and are tested 

differently under the test procedure.

– Small vs. large systems. For dedicated condensing systems, DOE is proposing different 

equipment classes for systems with gross capacity above vs. those that are at or below 

9,000 Btu/hr. Smaller systems tend to be less efficient and do not have access to as wide a 

range of compressor types.

Issue 6: DOE requests comment on the proposed refrigeration 

system classes.

Details of the Market and Technology Assessment can be found in chapter 3 of the TSD
22

Products Not Included in the Rulemaking

• DOE is not proposing new or amended standards for cooler 

floor panels, display panels, or blast freezer refrigeration 

systems.

– Most walk-in coolers are installed on concrete floors and do not have 

insulated floor panels. Current standards do not cover cooler floor 

panels and DOE is not proposing new standards for cooler floor panels. 

– Display panels make up a small percentage of all panels currently 

present in the market and have extremely limited savings potential. DOE 

is not proposing standards for display panels.

– Blast freezers make up a small percentage of walk-ins currently present 

in the market. DOE tentatively proposes to apply the same standards to 

blast freezer refrigeration systems as to storage freezer refrigeration 

systems, unless DOE finds that blast freezer refrigeration systems would 

have difficulty complying with DOE’s standards. 

Issue 4: DOE requests comment on its tentative decision not to 

propose standards for cooler floor panels, display panels, or blast 

freezer refrigeration systems.
23

Technology Assessment and Screening Analysis

• For the technology assessment, DOE developed a preliminary 

list of technology options that could improve the efficiency of 

WICFs. 

• All technology options DOE considered are described in chapter 

3 of the TSD.

• In the screening analysis (chapter 4 of the TSD), DOE removed 

from consideration in its analysis all technologies that:

– Are not technologically feasible

– Are not practicable to manufacture, install, and service

– Have adverse impacts on equipment utility or availability to customers

– Have adverse impacts on health or safety

Details of the Screening Analysis can be found in chapter 4 of the TSD
24

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures; Metrics

2 Market & Technology; Screening; 

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
25

NOPR Rulemaking Stage

 Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
26

Engineering Analysis: Methodology

Determine 

Representative Units

Select Baseline 

Units

Characterize 

Design Options

Model Unit 

Energy

Conduct Price 

Analysis 









Choose representative units within each equipment class to 

analyze.

Define characteristics of baseline models in each equipment 

class which will serve as reference points to assess changes due 

to energy conservation standards. 

Identify and characterize design options which can be 

implemented to increase efficiency. 

Model equipment energy performance at the baseline and with 

added design options.

Generate manufacturer production costs (MPCs) for 

representative units modeled, and then apply derived markups 

and shipping costs to calculate manufacturer selling prices.

Develop cost-efficiency curves that illustrate the relationship 

between efficiency and manufacturing cost as design options are 

added to baseline equipment.

Develop CostEfficiency Curves





Details of the Engineering Analysis can be found in chapter 5 of the TSD
27

Representative Units

• Within each equipment class of panels and doors, DOE 

analyzed small, medium, and large units, ranging in size 

from ~12 square feet (small display door) to 84 square 

feet (large freight door).

• Non-display doors were assumed to have a small viewing 

window of 2.25 square feet for passage doors and small 

freight doors, and 4 square feet for large freight doors.

• DOE analyzed refrigeration systems ranging in capacity 

from 6,000 Btu/h to 96,000 Btu/h.

• DOE analyzed refrigeration systems with three types of 

compressors: Hermetic reciprocating, scroll, and semihermetic. 

Select Baseline 

Units

Characterize 

Design Options

Model Unit 

Energy

Conduct Price 

Analysis 

Develop CostEfficiency Curves

Determine 

Representative Units

Issue 8: DOE requests comment on the 

representative units used in the analysis, particularly 

whether other sizes of equipment should be 

considered.

Details of the Engineering Analysis can be found in chapter 5 of the TSD
28

Baseline Units

• The baseline model typically represents the most 

common, least efficient model in each class. 

• Baseline models were assumed to meet the existing 

energy conservation standards in EPCA.

• The baseline serves as a reference point from which 

DOE measures impacts due to potential amended 

energy conservation standards. 

Select Baseline 

Units

Characterize 

Design Options

Model Unit 

Energy

Conduct Price 

Analysis 

Develop CostEfficiency Curves

Determine 

Representative Units

Details of the Engineering Analysis can be found in chapter 5 of the TSD
29

Characterization of Baseline Units

• Panels: 

– Foamed in place polyurethane with wood frame

– 3.5” foam for structural cooler panels and freezer floor panels; 4” foam for 

structural freezer panels

• Display doors:

– Argon gas fill and T8 lighting

– 2 panes with soft coat low-e coating for cooler doors; 3 panes with antisweat heater control for freezer doors

• Non-display doors:

– Foamed in place polyurethane with wood frame

– Window with argon gas fill and soft coat low-e coating; 2 glass panes for 

cooler doors and 3 glass panes for freezer doors

• Refrigeration systems:

– ECM evaporator fan motors and PSC condenser fan motors

– 10 degree TD for evaporators; 25 degree TD for medium temperature 

condensers; 20 degree TD for low temperature condensers

Issues 13 and 15: DOE requests comment on the assumptions for 

baseline equipment.

Details of the Engineering Analysis can be found in chapter 5 of the TSD
30

Design Options

• Design options are technologies that pass the screening 

analysis that manufacturers can use to improve the rated 

efficiency or energy consumption of equipment.

• DOE did not consider options that would not improve 

the rated efficiency as tested by the test procedure.

• The efficiency improvement and cost of each design 

option are described in detail in Chapter 5 of the TSD.

Select Baseline 

Units

Characterize 

Design Options

Model Unit 

Energy

Conduct Price 

Analysis 

Develop CostEfficiency Curves

Determine 

Representative Units

Issues 16, 17, and 18: DOE requests comments and data on 

the proposed design options, particularly their cost and 

energy impact, and whether they are technologically 

feasible. 

Issue 26: DOE requests comment on whether there are 

features or attributes of the more energy efficient walk-in 

coolers and freezers that manufacturers would produce to 

meet the standards in this proposed rule that might lessen 

the utility or performance of these products in current uses. 

Details of the Engineering Analysis can be found in chapter 5 of the TSD
31

Design Options Considered in the Engineering Analysis

• Panels

– Increased insulation thickness up to 6 inches

– Improved insulation material (e.g. foam-vacuum panel hybrid)

– Improved framing material (e.g. high-density foam)

• Display Doors

– High-efficiency lighting

– Occupancy sensors

– Improved display and window glass system performance improvement

– Anti-sweat heater controls

• Non-Display Doors

– Increased insulation thickness up to 6 inches

– Improved insulation material

– Improved panel framing material 

– Improved display and window glass system insulation performance

– Anti-sweat heater controls

– No anti-sweat heater systems

• Refrigeration systems

– Improved condenser coil

– ECM condenser fan motors

– Improved condenser and evaporator fan blades

– Ambient sub-cooling

– Evaporator and condenser fan control

– Defrost control

– Hot gas defrost

– Floating head pressure control

– Variable speed compressors

Details of the Engineering Analysis can be found in chapter 5 of the TSD
32

Modeling Unit Energy

• DOE’s energy models estimate the energy ratings of 

baseline equipment and levels of performance 

above the baseline associated with configurations 

including groups of design options. 

• The model is based on engineering principles, 

supplemented by test data and information from 

manufacturer interviews.

• DOE considered interactive effects on the energy 

use of implementing multiple design options for a 

unit. 

Select Baseline 

Units

Characterize 

Design Options

Model Unit 

Energy

Conduct Price 

Analysis 

Develop CostEfficiency Curves

Determine 

Representative Units

Issue 9: DOE requests any data that stakeholders can 

provide about the performance of covered equipment, 

particularly with the addition of design options.

Details of the Engineering Analysis can be found in chapter 5 of the TSD
33

Cost Analysis - Manufacturer Production Cost

• Manufacturing costs are based on material prices, 

conversion processes used by manufacturers, labor rates, 

and overhead factors such as depreciation and utilities. 

• DOE disassembled WICF equipment to create a bill of 

materials for several representative units, which it used 

to calculate manufacturing costs. 

• DOE supplemented these data with catalog and other 

publicly-available data, as well as information from 

manufacturer interviews. 

• DOE did not include in the engineering analysis the costs 

of any components not supplied by the manufacturer; 

e.g. refrigerant piping connecting a unit cooler to a 

multiplex condensing system.

Select Baseline 

Units

Characterize 

Design Options

Model Unit 

Energy

Conduct Price 

Analysis 

Develop CostEfficiency Curves

Determine 

Representative Units

Issue 14: DOE requests comment on production costs and 

its assumptions about components not provided by the 

manufacturer.

Details of the Engineering Analysis can be found in chapter 5 of the TSD
34

Cost Analysis - Manufacturer Selling Price

• The manufacturer’s selling price is the production 

cost multiplied by a markup, plus the shipping cost.

• Estimated markups for each type of equipment were 

based on information from manufacturer interviews.

- Panels: 1.32

- Display doors: 1.50

- Non-display doors: 1.62

- Refrigeration systems: 1.35

• Shipping costs were calculated by product volume. 

Select Baseline 

Units

Characterize 

Design Options

Model Unit 

Energy

Conduct Price 

Analysis 

Develop CostEfficiency Curves

Determine 

Representative Units

Issues 11 and 12: DOE requests comment on its 

assumptions about markups and shipping.

MSP = (MPC x Markup) + Shipping

Details of the Engineering Analysis can be found in chapter 5 of the TSD
35

Cost-Efficiency Curves

• The output of the engineering analysis is a set of 

cost-efficiency curves, one for each representative 

unit of each equipment class. 

• The point on the curve with the highest energy 

consumption (or lowest efficiency) and lowest 

manufacturer cost represents the baseline unit.

• Each subsequent point represents a higher efficiency 

level, corresponding to an additional or more 

advanced design option. Points are ordered by 

simple payback.

• The point on the curve with the lowest energy 

consumption (or highest efficiency) and highest 

manufacturer cost represents the maximum 

technologically feasible unit. 

• All cost-efficiency curves can be found in Appendix 

5A.

Select Baseline 

Units

Characterize 

Design Options

Model Unit 

Energy

Conduct Price 

Analysis 

Develop CostEfficiency Curves

Determine 

Representative Units

Details of the Engineering Analysis can be found in chapter 5 of the TSD
36

Example Cost-Efficiency Curve

Cooler display door, 6.25 ft. x 2.5 ft.

Level Added Design 

Option

0 

(Baseline) None

1 LED Lighting

2 Anti-sweat Control

3 Enhanced Glass Pack 

4 Lighting Sensors

5 More-enhanced

Glass Pack

6 (max

tech)

Super-enhanced

Glass Pack



EL0 

(Baseline) EL 2 EL 1

EL 5

EL 3

EL 4

EL6 (Max tech)

Details of the Engineering Analysis can be found in chapter 5 of the TSD
37

Example Cost-Efficiency Curve

Dedicated-condensing, medium temperature, outdoor refrigeration system, 

18,000 Btu/h with a scroll compressor

Level Added Design Option

0 

(Baseline) None

1 Modulated Evaporator 

Fans

2 Variable Speed

Evaporator Fans

3 Floating Head Pressure

4 Ambient Sub-cooling

5 EC Condenser Fan 

Motors

6 Variable Speed 

Condenser Fans

7 Larger Condenser Coil

8 Enhanced Evaporator 

Fan Blades

9 

Floating Head Pressure 

with Electronic

Expansion Valve

10 

(max tech)

Enhanced Condenser 

Fan Blades

 EL0 

(Baseline)

EL10 

(Max tech)

Details of the Engineering Analysis can be found in chapter 5 of the TSD
38

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening; 

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
39

NOPR Rulemaking Stage

 Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
40

Distribution Channels

• DOE considered two overlapping sets of distribution channels 

• For refrigeration systems and doors, these are: national accounts, sales to 

the envelope manufacturer (OEM), and sales to wholesalers

• For equipment sourced from the OEM, these are: national accounts, 

distributor, and general contractor

Details on the Distribution Channels can be found in chapter 6 of the TSD

Category Equipment Type National Account Wholesaler OEM

Refrigeration Multiplex 45% 45% 10% 

Refrigeration Dedicated 3% 42% 55% 

Envelope Display Doors 70% 0% 30% 

National Account Distributor Contractor

Envelope Panels 45% 44% 11% 

Envelope Non-display Doors 45% 44% 11% 

OEM Channels (all) 7% 79% 14% 
41

Equipment Markups

DOE applies markups to equipment MSP to determine the 

customer purchase price of analyzed equipment.

• DOE used baseline and incremental markups, applied to the MSP in the base case, 

and the incremental difference in MSP in each standards case

• DOE determined separate baseline and incremental markups for each of indoor 

and outdoor dedicated condensing and multiplex condensing refrigeration 

systems, as well as panels, display doors, and non-display doors. 

Markup Multipliers for All Equipment Classes

• DOE used a national average markup for sales tax of 1.07

Equipment Class

DC.M.I DC.M.O MC.M SP.M DD.M PD.M FD.M

 DC.L.I DC.L.O MC.L SP.L DD.L PD.L FD.L

Baseline 1.51 1.51 1.43 1.16 1.41 1.16 1.16

Incremental 1.19 1.19 1.25 1.09 1.29 1.09 1.09

*For DC refrigeration systems, markups apply to both capacity ranges.

Details of the Markup Analysis can be found in chapter 6 of the TSD
42

Energy Use – Refrigeration Systems 

• DOE conducted a separate energy use analysis for the refrigeration systems and for 

the envelope components. 

• For each equipment class, the refrigeration system AEC was modeled assuming that 

the system serves a walk-in box with a given refrigeration load. The refrigeration 

load depends on both equipment sizing and duty cycle.

• Variable ambient temperature conditions were included for outdoor dedicated 

condensing systems

• DOE used AHRI 1250 to define the rated capacity for the refrigeration system 

representative units. 

• DOE revised its sizing methodology to be consistent with its understanding of current 

industry practice:

• Calculate the daily heat load on the basis of a 24-hour cycle, divided by 16 hours 

of runtime for coolers, and by 18 hours of runtime for freezers

• Add 10% safety margin

• Include an additional 10% margin for capacity mismatch

Details of the Energy Use Analysis can be found in chapter 7 of the TSD
43

Energy Use – Envelope Components 

DOE based its energy use estimates for envelope components on transmission loads, 

assuming the component has been paired with a selected refrigeration system.

• Transmission loads were calculated under test procedure conditions for the selected 

envelope component

• Any direct electrical component energy consumption, and its associated load, are 

added to the transmission load for the component

• The efficiency metric of the selected refrigeration system was used to estimate the 

additional energy consumption attributed to the component

– Door AEC was calculated per door at 3 different sizes

– Panel AEC was calculated per panel by unit area

Details of the Energy Use Analysis can be found in chapter 7 of the TSD

Issue 19: DOE assumed 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 and requests comment on this assumption.
44

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening; 

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
45

NOPR Rulemaking Stage

 Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
46

Life-cycle Cost and Payback Period Analysis

• Purpose

– To develop the customer life-cycle cost (LCC) savings and payback period 

(PBP) for higher-efficiency equipment compared to the baseline 

equipment.

• Method

– Used Monte Carlo simulation to estimate the life-cycle costs for a 

population of commercial refrigeration equipment classes (10,000 trials), 

implemented in an Excel® spreadsheet using Crystal Ball

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

equipment lifetime

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

– Payback Period: Equipment-installed price divided by first-year 

operating costs

– LCC is discounted; PBP is not discounted (“simple” PBP)

Detailed LCC and PBP results can be found in chapter 8 of the TSD
47

LCC: Overview

Detailed LCC and PBP results can be found in chapter 8 of the TSD
48

LCC Inputs

• Installation Costs: DOE developed separate installation 

costs for WICF refrigeration systems and envelope 

components based on data from the RSMeans Mechanical 

Costs Data Handbook, 2012. Installation costs vary for 

refrigeration systems by type and capacity; for envelopes by 

floor area including display doors, and structural and floor 

panels; and overall area for passage and freight doors.

• Discount Rates: DOE developed a distribution of possible 

discount rates specific to each of the business types 

considered. 

• Electricity Prices: DOE developed regional electricity prices 

for each of the business types considered.

• Electricity Price Trend: DOE used the AEO2013 commercial 

electricity price projections, which vary by census division

Detailed LCC and PBP results can be found in chapter 8 of the TSD
49

LCC Inputs: Lifetime

• DOE recognizes that there may be variation between WICF 

economic and physical lifetime. For this rule DOE used a 

distribution of WICF economic lifetimes.

– Economic lifetime is duration of time that a WICF is in service for a 

single business.

– Physical lifetime is the duration of time that a WICF operates before 

it fails or is replaced, regardless of ownership.

WICF component Min. Lifetime 

(Yrs)

Average Lifetime 

(Yrs)

Max. Lifetime 

(Yrs)

Envelope 2 15 25 

Refrigeration System 2 12 25 

Display Doors

Passage Doors 8 14 25 

Freight Doors

Walk-in lifetime estimates

Details of the WICF lifetimes can be found in chapters 8 and 9 of the TSD
50

LCC Inputs: Lifetime

Issue 30: DOE is seeking information on whether there is a significant 

market for used walk-in coolers and freezers. Given the high turnover 

rate in the food service industry (e.g., a commenter noted 70 to 90 

percent failure rates for restaurants), DOE is seeking to understand 

whether it is reasonable to assume that the useful life of the 

refrigeration system would be 12 years and other components 15 years 

due to active used equipment markets.

Details of the WICF lifetimes can be found in chapters 8 and 9 of the TSD
51

LCC Inputs: Maintenance Costs

• DOE based its annualized maintenance costs on information 

from RS Means Facilities Maintenance and Repair Cost Data, 

2012.

– Total annual maintenance costs for a walk-in range from $170 to 

$262, of which $150 is assumed to be spent on the refrigeration 

system with the difference spent on the envelope.

– DOE assumed that part of the $150 annual maintenance cost for 

refrigeration systems to include expenses related to refrigerant (re-) 

charging.

– DOE assumed that all non-lighting maintenance costs do not change 

with increased efficiency. 

 

Issue 21: DOE requests that interested parties submit data on 

refrigerant charging maintenance costs.

Detailed LCC and PBP results can be found in chapter 8 of the TSD
52

Process Used to Define TSLs

• The engineering analysis defines efficiency levels (ELs) for each 

equipment class and capacity based on the design options

• In a preliminary step, DOE generated LCC and national impacts 

results for refrigeration system ELs to determine what level of 

efficiency improvement is cost-effective in isolation

• The TSLs defined for policy consideration consist of a choice of 

cost-effective refrigeration system efficiency levels for each 

equipment class combined with various envelope ELs

• The final LCC and NIA results incorporate interactions between 

the refrigeration and envelope components 

• Final set of TSLs represents the range of results across all 

possible combinations

Discussion of the development of TSLs is presented in Appendix 10D
53

LCC and PBP analysis results for each refrigeration system

LCC-PBP Analysis: Results – TSL 4

Detailed LCC and PBP results can be found in chapter 8 of the TSD

Equipment 

Class Avg. LCC 2012$ Avg. LCC Savings 2012$ Net Cost % No Impact % Net Benefit % Median PBP Years 

DC.M.O 10,222 1,509 0 0 100 2.0

DC.M.I 11,169 611 4 0 96 4.4

DC.L.O 12,168 2,001 5 0 95 2.3

DC.L.I 16,205 1,117 0 0 100 2.7

MC.M 6,002 1,724 0 0 100 0.5

MC.L 9,817 2,061 0 0 100 0.4

Equipment Temp. Class Average LCC 

2012$ 

Average LCC 

Savings 2012$ Net Cost % No Impact % Net Benefit % Median PBP Years 

Structural Panel M 1,088 8 34 0 66 5 

L 1,338 72 7 0 93 4 

Floor Panel L 1,390 30 28 0 72 5 

Display Door M 1,385 228 0 0 100 2 

L 2,710 200 0 0 100 N/A*

Panel Door M 774 0 52 0 48 6 

L 3,090 52 27 0 73 5 

Freight Door M 1,408 1 50 0 50 5 

L 4,780 136 1 0 99 3 

* N/A indicates that payback was negative

LCC and PBP analysis shipment weighted results for each component type
54

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;

2 Market & Technology; Screening; 

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
55

NOPR Rulemaking Stage

 Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Shipments

Analysis

National

Impact

Analysis

Energy Use 

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
56

Shipments

• Shipments were modeled separately for refrigeration 

systems and envelope components (these were modeled 

together in the Preliminary Analysis).

• DOE projected future shipments based on historical stocks. 

Stock data came from several sources:

1. 2003 Commercial Buildings Energy Consumption 

Survey

2. 2007 Economic Census

3. Confidential Manufacturer Interviews

• The model predicts the number of complete WICF units 

installed, which were disaggregated into system and 

component equipment classes.

Details of the Shipments Analysis can be found in chapter 9 of the TSD

Issue 27: DOE welcomes input and data on the shipments assumptions.
57

Shipments: Complete WICF System to EC Mapping

Complete WICF System to Equipment Class Mapping

Application & Size 

category

Distribution of Refrigeration System Equipment Classes (%)

DC.M.I DC.M.O DC.L.I DC.L.O MC.M MC.L

Storage Cooler Small 3.6% 93.1% 0.0% 0.0% 3.2% 0.0%

Storage Cooler Medium 1.3% 84.0% 0.0% 0.0% 14.7% 0.0%

Storage Cooler Large 0.0% 50.8% 0.0% 0.0% 49.2% 0.0%

Display Cooler Small 4.6% 92.3% 0.0% 0.0% 3.1% 0.0%

Display Cooler Medium 4.0% 88.7% 0.0% 0.0% 7.3% 0.0%

Display Cooler Large 0.0% 71.8% 0.0% 0.0% 28.2% 0.0%

Storage Freezer Small 0.0% 0.0% 3.1% 95.6% 0.0% 1.3%

Storage Freezer Medium 0.0% 0.0% 2.4% 92.2% 0.0% 5.4%

Storage Freezer Large 0.0% 0.0% 0.0% 74.7% 0.0% 25.3%

Display Freezer Small 0.0% 0.0% 5.3% 89.5% 0.0% 5.3%

Display Freezer Medium 0.0% 0.0% 5.3% 85.3% 0.0% 9.5%

Display Freezer Large 0.0% 0.0% 0.0% 25.0% 0.0% 75.0%

Details of the Shipments Analysis can be found in chapter 9 of the TSD
58

Shipments: WICF Envelope Component Size Market Share Distributions

WICF Envelope Component Size Market Share Distributions 

Envelope Component Surface 

Area

Percent 

Sales

Representative 

Height 

Representative 

Width

ft2 ft ft

Panels

< 20 20% 8 1.5

21-40 60% 8 4 

> 41 20% 9 5.5

Passage Doors

< 18 8% 6.5 2.5

18-25 76% 7 3 

> 25 16% 7.5 4 

Freight Doors

< 54 47% 8 5 

55-75 38% 9 7 

> 75 15% 12 7 

Details of the Shipments Analysis can be found in chapter 9 of the TSD
59

Shipments Analysis: Systems Shipment Results

-

20,000 

40,000 

60,000 

80,000 

100,000 

120,000 

140,000 

160,000 

180,000 

200,000 

2015 2020 2025 2030 2035 2040 2045

Number of Units Shipped

WICF Refrigeration System Shipments by Year

DC.M.I DC.M.O DC.L.I DC.L.O MC.L MC.M

Details of the Shipments Analysis can be found in chapter 9 of the TSD
60

Shipments Analysis: Component Shipments Results

-

100,000 

200,000 

300,000 

400,000 

500,000 

600,000 

700,000 

2015 2020 2025 2030 2035 2040 2045

Number of Units Shipped

WICF Refrigeration Component Shipments by Year

DD.M DD.L PD.M PD.L FD.M FD.L

Details of the Shipments Analysis can be found in chapter 9 of the TSD
61

Shipments: Comments

Issue 27: DOE welcomes stakeholder input and estimates on the effect of 

amended standards on future walk-in cooler and freezer shipments. DOE 

is seeking information on what factors drive the demand for walk-in 

coolers and freezers and whether those factors are likely to remain 

unchanged in the relevant analytic time period of 30 years. 

Details of the Shipments Analysis can be found in chapter 9 of the TSD
62

National Impact Analysis (NIA)

Purpose

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

– National Energy Savings (NES)

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

Method

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

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

– Total consumer expenditures on commercial refrigeration equipment:

• National equipment expenditures

• National operation and maintenance costs

• The difference between the base case and each standards case, summed over 

the analysis period, defines the NES and the NPV of consumer economic impacts.

• Dollar values are discounted to the analysis year (2013) using discount rates of 3 

and 7 percent.

Details of the National Impact Analysis can be found in chapter 10 of the TSD
63

NIA: Price Trends

• DOE developed projections of future equipment price trends over the analysis 

period

• The reference was derived using inflation adjusted historical equipment 

price index from the Bureau of Labor Statistics, PPI series Refrigeration, Air 

Conditioning, and Warm Air Heating Equipment

Further information is provided in appendixes 8D, and 10B of the TSD

0 

0.2

0.4

0.6

0.8

1 

2010 2015 2020 2025 2030 2035 2040 2045 2050

Price Factor Index

Default

Constant Price

Issues 20 and 28: DOE invites comment on methods to improve its 

equipment price forecasting, as well as any data supporting alternate 

methods. DOE is seeking input and price data that could be used in place 

of PPI. Also, DOE is seeking input on the magnitude of the price data and 

the cause of those price changes.
64

NIA: Efficiency Distributions

Base-case forecast efficiencies were assumed to be established by 

EISA 2007. EISA 2007 established prescriptive standards for WICF 

manufactured on or after Jan 1, 2009.

• Refrigeration systems:

– 75% of shipments at the baseline (i.e. EISA) , remainder at higher 

efficiencies

• Components

– 25% of display doors at the baseline, remainder at higher efficiencies 

– 80% of freezer doors at the baseline, remainder at higher efficiencies

– 100% of all other components baseline

• DOE used a roll-up method to estimate the efficiency distribution 

in the standards case.

Detailed Efficiency Distributions can be found in chapter 10 of the TSD

Issue 23: DOE requests comment on its assumptions about base-case 

efficiency distributions.
65

NIA: Cumulative NES Results (2017 – 2073) 

Combined National Energy Savings (NES) results for 

refrigeration systems and components in quads.

Application

Trial Standard Levels

1 2 3 4 5 6 

Medium Temperature 2.9 3.3 3.0 3.5 3.6 4.2 

Low Temperature 1.5 1.3 1.7 1.8 2.0 2.3 

Primary Energy Savings Total 4.4 4.5 4.7 5.3 5.6 6.5 

Upstream Energy Savings 0.1 0.1 0.1 0.1 0.1 0.1 

TOTAL SAVINGS 4.5 4.6 4.7 5.4 5.7 6.6 

Details of the National Impact Analysis can be found in chapter 10 of the TSD
66

NIA: Cumulative NPV Results (2017 – 2046) 

Cumulative Net Present Values (million 2012$) 

Application Discount 

Rate

Trial Standard Levels

1 2 3 4 5 6 

Med. Temp.

3% 14,102 14,970 13,914 15,814 15,630 -43,607 

7% 5,161 5,386 5,004 5,627 5,425 -25,809 

Low. Temp.

3% 7,285 6,155 6,636 8,482 7,707 -3,037 

7% 2,604 2,255 2,114 3,015 2,438 -3,408 

Totals

3% 21,387 21,125 20,550 24,296 23,337 -46,644 

7% 7,765 7,641 7,118 8,642 7,863 -29,217 

Details of the National Impact Analysis can be found in chapter 10 of the TSD
67

NIA: Rebound Effect

• A rebound effect occurs when users operate higher efficiency 

equipment more frequently and/or for longer durations, thus 

offsetting estimated energy savings. 

• DOE assumed a rebound factor of one, or no effect, because 

walk-ins must cool their contents at all times and it is not 

possible for consumers to operate them more frequently.

Issue 32: DOE seeks comment on this assumption and whether other 

factors should be considered in the rebound effect, such as customers 

leaving doors open longer, a decision to buy a larger system due to 

increased lifetime cost savings, or money saved in electricity bills with 

more efficient walk-in coolers and freezers being used for other 

electricity consuming activities.

Details of the National Impact Analysis can be found in chapter 10 of the TSD
68

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures; Metrics

2 Market & Technology; Screening; 

3 Engineering; 

4 Energy Use; Markups Analysis;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks
69

NOPR Rulemaking Stage

 Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Markups Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Manufacturer 

Impact 

Analysis
70

• Purpose

– To assess the impacts of standards on manufacturers;

– To identify and estimate impacts on manufacturer subgroups that may be more 

severely affected than the industry as a whole; and

– To examine the direct employment, manufacturing capacity, and cumulative 

regulatory impacts on the industry.

• Methodology 

– Analyze industry cash flow and industry net present value (INPV) through use 

of the Government Regulatory Impact Model (GRIM); and

– Interview manufacturers to refine inputs to the GRIM, develop subgroup 

analyses, and address qualitative issues.

MIA: Overview

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
71

• Phase 1

– DOE creates an industry profile to characterize the market and identify 

important issues that require further investigation.

• Phase 2

– DOE prepares an industry cash flow model and an interview questionnaire to 

guide subsequent discussions with manufacturers.

• Phase 3

– DOE interviews manufacturers and assesses the impacts of standards both 

quantitatively (using the GRIM) and qualitatively (impacts on employment, 

competition, manufacturing capacity, and regulatory burden).

MIA: Methodology

Industry 

profile

Develop 

straw-man 

GRIM

Develop 

interview 

guide

Interviews

& industry

subgroup

analyses

Assess 

employment, 

competition, 

capacity, & 

regulatory

burdens

Phase 1 Phase 2 Phase 3

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
72

MIA: Key Issues

• Test Burden

– Manufacturers expressed concern over the cost of testing and over test lab 

availability.

• Profitability Impacts

– Cost increases due to more material, more expensive components, and increases 

in shipping costs could lead to reduced sales volume and reduced profitability.

• Excessive Conversion Costs

– Panel manufacturers noted that any standard that necessitates 6-inch or 7-inch 

panels would lead to excessive conversion costs

– Refrigeration and display door manufacturers were concerned about the cost of 

testing due to the large numbers of models and the high level of customization 

required for their customers.

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
73

• DOE evaluated refrigeration, panel, and door manufacturers as separate 

industries in its general MIA analysis.

MIA: Industry Subgroups

Walk-in Cooler and Freezer Industry

WICF 

Refrigeration

WICF 

Panels

WICF 

Doors

• DOE evaluated small businesses for each of the 3 industries 

above as sub-groups.

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
74

MIA: WICF Industry INPV Results

• Combined results for WICF Refrigeration, Panels, and Doors

 

Units Base 

Case

Trial Standard Level 

1 2 3 4 5 6 

INPV 2012 $M 851 791 to 850 807 to 862 743 to 828 774 to 851 717 to 832 194 to 1775

Change in INPV

2012 $M - -60 to -1 -44 to 11 -108 to -23 -77 to 0 -134 to -19 -657 to 924

% - -7 to 0 -5 to 1 -13 to -3 -9 to 0 -16 to -2 -77 to 109

Conversion Costs 2012 $M - 42 24 88 51 101 315 

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
75

MIA: WICF Refrigeration INPV Results

• Results for the WICF Refrigeration Industry 

 

Units Base 

Case

Trial Standard Level 

1 2 3 4 5 6 

INPV 2012 $M 189.1 170.9 to 183.3 153.6 to 184.8 170.9 to 183.3 153.6 to 184.8 145.8 to 188.3 145.8 to 188.3

Change in INPV

2012 $M - -18.3 to -5.9 -35.5 to -4.4 -18.3 to -5.9 -35.5 to -4.4 -43.3 to -0.8 -43.3 to -0.8

% - -9.7 to -3.1 -18.8 to -2.3 -9.7 to -3.1 -18.8 to -2.3 -22.9 to -0.4 -22.9 to -0.4

Conversion Costs 2012 $M - 15 24 15 24 28 28 

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
76

MIA: WICF Panel INPV Results

• Results for the WICF Panel Industry

 

Units Base 

Case

Trial Standard Level 

1 2 3 4 5 6 

INPV 2012 $M 207.3 182.2 to 195.8 207.3 to 207.3 144.1 to 177.0 182.2 to 195.8 144.1 to 177.0 -212.9 to 441.9

Change in INPV

2012 $M - -25.0 to -11.5 0.0 to 0.0 -63.1 to -30.2 -25.0 to -11.5 -63.1 to -30.2 -420.2 to 234.7

% - -12.1 to -5.6 0.0 to 0.0 -30.5 to -14.6 -12.1 to -5.6 -30.5 to -14.6 -202.7 to 113.2

Conversion Costs 2012 $M - 21 0 58 21 58 195

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
77

MIA: WICF Door INPV Results

• Results for the WICF Door Industry

 

Units Base 

Case

Trial Standard Level 

1 2 3 4 5 6 

INPV 2012 $M 454.6 437.6 to 470.7 446.2 to 470.2 428.2 to 467.8 437.8 to 470.6 427.3 to 466.4 260.8 to 1145.1

Change in INPV

2012 $M - -17.0 to 16.1 -8.4 to 15.6 -26.4 to 13.2 -16.8 to 16.0 -27.3 to 11.8 -193.8 to 690.5

% - -3.7 to 3.5 -1.8 to 3.4 -5.8 to 2.9 -3.7 to 3.5 -6.0 to 2.6 -42.6 to 151.9

Conversion Costs 2012 $M - 6 0.0 15 6 15 92 

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
78

MIA: Small Business Impacts

• DOE searched several publicly available databases to identify any potential 

domestic small business manufacturers.

– These included the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) 

certification database, North American Association of Food Equipment Manufacturers 

(NAFEM) Section 7 certification database, and market research tools (e.g. Dun & Bradstreet 

reports).

• DOE’s small business screening results:

– Walk-in Refrigeration Systems

• 9 manufacturers total 

• 2 small manufacturers identified

– Walk-in Panels

• at least 52 manufacturers total

• 42 small manufacturers identified

– Walk-in Doors: 

• 54 manufacturers identified (most manufacture panels as their primary business)

• 3 small solid door manufacturers (that were not primarily in the business of producing 

panels)

• 2 small display door manufacturers

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD
79

MIA: Small Business Impacts 

• DOE did not certify that the proposed standard would not have a significant 

impact on a substantial number of small business manufacturers.

• Key drivers

– Large number of small business panel manufacturers.

– The role of small businesses in the WICF freight doors and display doors industry.

• Initial Regulatory Flexibility Analysis (IRFA) produced for the Small Business 

Administration

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD

Issue 32: DOE seeks comment on the number of small manufacturers of walk-in 

cooler and freezer refrigeration systems, panels, and doors; on the potential 

impacts of new energy conservation standard on those small manufacturers; 

and on the severity of those impacts.
80

Life-Cycle Cost Subgroup Analysis

• The customer subgroup analysis evaluates impacts on identifiable 

groups of customers of walk-in cooler and freezer equipment who 

may be disproportionately affected by amended energy conservation 

standards. 

• DOE examined small restaurants as the representative small business 

for the LCC Subgroups Analysis. They experience higher electricity 

prices and higher capital costs than the national average. It was 

assumed that they did not have access to the National Accounts 

distribution channel, thus they faced higher equipment costs.

• DOE found the difference in life-cycle cost between the national 

average and the analyzed subgroups is typically a few percent, with 

no impact on the relative cost-effectiveness of the proposed standard 

for this subgroup.

Details of the LCC Subgroups Analysis can be found in chapter 11 of the TSD
81

Emissions Analysis

• DOE estimates the cumulative emissions reductions resulting from amended 

energy conservation standards. DOE considers full-fuel-cycle emissions. 

Thus, both power plant emissions and “upstream” emissions are included in 

the analysis.

– Includes fugitive methane emissions.

Trial Standard Level

 1 2 3 4 5 6 

CO2 (million metric tons) 248.2 255.2 261.4 298.0 317.5 365.5 

NOx (thousand tons) 369.9 379.6 389.6 443.8 473.0 544.8 

Hg (tons) 0.5 0.5 0.6 0.6 0.7 0.8 

N2O (thousand tons) 5.4 5.5 5.7 6.4 6.9 7.9 

CH4 (thousand tons) 1188.8 1222.7 1251.9 1427.6 1521.1 1750.6 

SO2 (thousand tons) 316.0 325.1 332.7 379.5 404.3 465.3 

Cumulative Emissions Reduction for Potential Standards for Commercial 

Refrigeration Equipment

Details of the Emissions Analysis can be found in chapter 15 of the TSD
82

Emissions Analysis: Monetization

• DOE uses the most current Social Cost of Carbon (SCC) values developed by 

interagency process.

– SCC is intended to be a monetary measure of the incremental damage resulting 

from greenhouse gas (GHG) emissions, including but not limited to agricultural 

productivity loss, human health effects, property damage from rising sea level, 

and changes in the ecosystem.

• The most recent (2013) U.S. government interagency estimates of the SCC 

for emissions in 2015 are $12.90, $40.80, $62.2, and $117.0 per metric ton 

avoided (2012 dollars).

– The SCC in constant dollars increases over time

• DOE also monetizes the NOx emissions reductions resulting from amended 

standards. The medium estimate is $2639 per ton of NOx. 

Details of the Emissions Monetization Analysis can be found in chapter 16 of the TSD
83

Emissions Monetization Results: Present Value of CO2 Reduction (million 2012$)

TSL

SCC: $12.9 per 

metric ton @ 5% 

discount

rate,

Average

SCC: $40.8 per 

metric ton @ 3% 

discount

rate,

average

SCC: $62.2 per 

metric ton @ 

2.5% discount

rate,

average

SCC: $117.0 per 

metric ton @ 3% 

discount

rate,

average

1 1,564 7,447 11,942 22,885 

2 1,622 7,699 12,336 23,654 

3 1,644 7,833 12,564 24,074 

4 1,882 8,955 14,357 27,518 

5 2,004 9,536 15,291 29,306 

6 2,301 10,959 17,577 33,682 

Note: For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.9, $40.8, $62.2 

and $117.0 per metric ton

Details of the Emissions Monetization Analysis can be found in chapter 16 of the TSD
84

Emissions Monetization Results: Present Value of NOx Reduction (million 2012$)

TSL 3% discount

rate

7% discount

rate

1 459.8 201.6 

2 477.1 211.4 

3 483.3 211.4 

4 553.5 243.5 

5 589.2 258.9 

6 676.5 296.3 

Note: Based on medium estimate: $2639 per ton.

Details of the Emissions Monetization Analysis can be found in chapter 16 of the TSD
85

Utility Impact Analysis

• Purpose

– To estimate the changes in electric installed capacity and generation that 

result for each trial standard level (TSL). 

• Method 

– The NES is used to provide a stream of energy savings over the analysis 

period

– The Energy Information Administration’s National Energy Modeling 

System (NEMS) is modified to represent the impacts of DOE’s standards 

program (modified code is known as NEMS-BT)

• Output

– Reductions in total electricity generation

– Reductions in primary fuel (coal, natural gas, etc.) consumption

– Changes to the mix of electricity generation by fuel type

– Changes to total installed capacity

Details of the Utility Impact Analysis can be found in chapter 14 of the TSD
86

Utility Impact Analysis: Results

Year

TSL

1 2 3 4 5 6 

Installed Capacity Reduction (MW)

2020 162 173 169 197 209 237 

2025 583 626 609 710 753 854 

2030 1362 1440 1425 1648 1751 1999 

2035 2503 2606 2630 3017 3211 3680 

2040 4172 4332 4385 5025 5349 6135 

Electricity Generation Reduction (TWh) 

2020 4.5 4.8 4.7 5.4 5.8 6.5 

2025 10.1 10.9 10.6 12.3 13.1 14.8 

2030 14.0 14.8 14.7 17.0 18.1 20.6 

2035 15.5 16.2 16.3 18.7 19.9 22.8 

2040 16.4 17.0 17.2 19.8 21.0 24.1 

Details of the Utility Impact Analysis can be found in chapter 14 of the TSD
87

Employment Analysis

• Purpose

– To estimate the net jobs created or eliminated nationally as a 

consequence of amended energy conservation standards. This 

includes direct and indirect employment impacts.

• Method 

– Uses the ImSET (Impact of Sector Energy Technologies) model for the 

evaluation of indirect employment impacts.

– The changes in equipment and energy expenditures are taken from 

the National Energy Savings Analysis.

– Direct employment impacts to the WICF industry are developed in 

the Manufacturer Impact Analysis (chapter 12).

• Output

– Change to commercial and energy sector employment as a 

consequence of amended energy conservation standards

Details of the Employment Impact Analysis can be found in chapter 13 of the TSD
88

Employment Analysis: Results

Net Short-term Changes in Employment 2017 and 2021 (jobs, 

in thousands)

Year Trial Standard Level Net National Change in Jobs

Thousands

2017 1 0.7 

2 0.8 

3 0.7 

4 0.9 

5 1 

6 1.1 

2021 1 3.4 

2 3.7 

3 3.5 

4 4.2 

5 4.4 

6 5 

* Compliance date of standard is 2017.

Details of the Employment Impact Analysis can be found in chapter 13 of the TSD
89

Regulatory Impact Analysis

• Purpose

– To investigate the national impacts of non-regulatory alternatives to mandatory 

amended energy conservation standards

– The non-regulatory alternatives that may be considered include: 

• No new regulatory action; early replacement; prescriptive standards; 

customer tax credits; manufacturer tax credits; customer rebates; voluntary 

efficiency targets and bulk government procurement

• Method

– The NES spreadsheet model is modified to consider different scenarios

– The variables that may be modified include energy prices and escalation factors, 

implicit market discount rates, customer purchase price and operating cost, 

income elasticities, and equipment stock data. 

• Output

– National Energy Savings and Net Present Value for the non-regulatory 

alternatives

– Impact of non-regulatory alternatives on purchase price and use of energyefficient equipment

Details of the Regulatory Impact Analysis can be found in chapter 17 of the TSD
90

Regulatory Impact Analysis: Results

• DOE modified the shipments and NIA models to represent nonregulatory alternatives that could potentially achieve similar 

improvements in WICF energy efficiency

• In general, DOE considers a number of alternatives including 

consumer tax credits, rebate programs and voluntary efficiency 

targets.

• For this analysis, DOE estimated the benefits associated with 

consumer tax credits and rebates by assuming the market shift 

that would result (relative to a 100% shift for mandatory 

standards) 

Details of the Regulatory Impact Analysis can be found in chapter 17 of the TSD
91

Trial Standard Levels

• For walk-ins, DOE presents 6 composite TSLs. Each composite TSL combines a 

refrigeration system efficiency level with specific panel and door efficiency 

levels, based on certain criteria.

• Criteria for refrigeration system levels:

– All Compressors (highest efficiency level that can be met by all compressor types) 

– Maximum NPV (level that maximizes the net present value)

– Max Tech (level with the maximum energy savings)

• Criteria for envelope component (panel and door) levels:

– Display Doors Only (level with maximum energy savings with positive NPV for 

display doors and current baseline for panels and non-display doors)

– Maximum NPV (level that maximizes the net present value)

– Maximum NES with NPV>0 (level with maximum energy savings with a positive 

NPV)

– Max Tech (level with the maximum energy savings)

• The composite TSLs are ordered by overall energy savings.

Details of the Trial Standard Levels can be found in appendix 10D of the TSD
92

Composite TSLs

Refrigeration System Criteria

Envelope 

Component 

Criteria

All Compressors Maximum NPV

Max Tech

(Same as Max NES 

with NPV>0)

Display Doors Only TSL 2: All display 

doors only at NPV>0

Maximum NPV

TSL 1: All 

compressors, max 

NPV

TSL 4: Maximum NPV 

for both refrigeration 

system and 

components

Maximum NES with 

NPV>0

TSL 3: All 

compressors, NPV>0

TSL 5: Max NES with 

NPV>0 for both 

Refrigeration system 

and Components

Max Tech

TSL 6: Max-tech for 

both refrigeration 

system and envelope

components

Proposed Standard

Increased Energy Savings

Increased Energy Savings

Details of the Trial Standard Levels can be found in appendix 10D of the TSD
93

TSL/Design Option Mapping - Panels

Equipment 

Class Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6

SP.M

-3.5” Foam

-Wood 

Frame

-3.5” Foam

-Softnose

Frame

-Same as 

Baseline

-4” Foam

-Softnose

Frame

-Same as 

TSL 1

-Same as 

TSL 3

-Hybrid VIP

-No Framing

SP.L

-4” Foam

-Wood 

Frame

-5” Foam

-Softnose

Frame

-Same as 

Baseline

-6” Foam

-No Framing

-Same as 

TSL 1

-Same as 

TSL 3

-Hybrid VIP

-No Framing

FP.L

-3.5” Foam

-Wood 

Frame

-4” Foam

-Softnose

Frame

-Same as 

Baseline

-6” Foam

-Softnose

Frame

-Same as 

TSL 1

-Same as 

TSL 3

-Hybrid VIP

-Softnose

Frame

Details of the Trial Standard Levels can be found in appendix 10D of the TSD
94

Summary of Proposed Standards

• Recap of standards metrics:

– Refrigeration Systems: Minimum annual walk-in energy factor (AWEF)

– Panels: Maximum U-factor 

– Doors: Maximum daily energy use

• The proposed standards are expressed as equations.

Issue 24: DOE requests comment on the TSL equations and asks 

interested parties to submit data on how the efficiency or energy 

consumption of equipment varies with size or capacity.
95

Proposed Standards for Refrigeration Systems

Condensing Type Operating 

Temperature

Condenser 

Location

Refrigeration 

Capacity (Btu/h) Class Code Equations for Minimum AWEF

(Btu/W-h)*

Dedicated 

Condensing

Medium

Indoor

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

≥ 9,000 DC.M.I, ≥ 9,000 6.90

Outdoor

< 9,000 DC.M.O, < 9,000

≥ 9,000 DC.M.O, ≥ 9,000 12.21

Low

Indoor

< 9,000 DC.L.I, < 9,000

≥ 9,000 DC.L.I, ≥ 9,000 3.63

Outdoor

< 9,000 DC.L.O, < 9,000

≥ 9,000 DC.L.O, ≥ 9,000 6.15

Unit Cooler

Connected to 

Multiplex 

Condensing 

System

Medium - - MC.M 10.74

Low - - MC.L 5.53

*Q represents the system gross capacity as calculated by the procedures set forth in AHRI 1250.

.2 1063 .4 53 4 +×× − Q

.1 1034 .0 12 3 +×× − Q

.1 1093 .1 89 4 +×× − Q

.5 1070 .1 02 4 +×× − Q
96

Example Graph of Proposed Refrigeration Standard 

• Minimum AWEF for Dedicated Condensing, Low Temperature, 

Outdoor Systems at TSL 4
97

Proposed Standards for Panels

Component Type

Walk-In 

Operating 

Temperature

Class Code Equations for Maximum U-Factor 

(Btu/h-ft2-°F)*

Structural

Medium SP.M

Low SP.L

Floor Low FP.L

*Anf edge and Anf core represent the edge and core surface area of the structural panel, respectively. 

Afp edge and Afp core represent the edge and core surface area of the floor panel, respectively.

.0 041

nf core

nf edge .0 024

2

nf core

nf edge .0 012×− ×+ +































A

A

A

A

.0 029

nf core

nf edge .0 017

2

nf core

nf edge .0 0083×− ×+ +































A

A

A

A

.0 033

fp core

fp edge .0 018

2

fp core

fp edge .0 0091×− ×+ +

































A

A

A

A
98

Example Graph of Proposed Panel Standard

• Maximum U-value for Medium Temperature Panels at TSL 4 

(various frame to foam ratios)
99

Proposed Standards for Doors

Component Type

Walk-In 

Operating 

Temperature

Class Code Equations for Maximum Energy Consumption

(kWh/day)*

Passage Door

Medium PD.M

Low PD.L

Freight Door

Medium FD.M

Low FD.L

Display Door

Medium DD.M

Low DD.L

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

Add represents the surface area of the display door.

.0 0032 And +× .0 22

.0 14 +× 0.4 And

.0 0073 +× .0 082 And

.0 11 +× 4.5 And

.0 049 +× .0 39 Add

.0 33 +× .0 38 Add
100

Example Graph of Proposed Passage Door Standard

• Maximum Energy Use for Cooler Passage Doors at TSL 4 
101

Example Graph of Display Door Standard

• Maximum Energy Use for Cooler Display Doors at TSL 4 
102

Summary of Proposed Rule Impacts

• Energy

– Cumulative energy savings = 5.39 quadrillion FFC* Btus (quads) for 

equipment purchased in 2017 - 2046 

• Cost Savings

– Cumulative national net present value (NPV) = $8.6 billion (7% discount 

rate (DR)), $24.3 billion (3% DR)

– Approximate life cycle cost savings are approximately $10-$70 for panels, 

$200 for display doors, $0-$140 for non-display doors, and $600-$2000 

for refrigeration systems

• Environmental Benefit

– Energy saved in the form of electricity would result in cumulative 

greenhouse gas emission reductions of ~300 million metric tons (Mt) of 

carbon dioxide (CO2) for equipment purchased in 2017-2046

– Estimated net present monetary value of the CO2 emissions reduction is 

between $1.88 and $27.5 billion

* FFC denotes full fuel cycle energy
103

Proposed Energy Conservation Standards

Issue 25: DOE seeks comment on the appropriateness of 

choosing TSL 4 energy conservation standards.
104

Closing Remarks
105

How to Submit Written Comments

• In all correspondence, please refer to the WICF rulemaking by:

– Walk-in Coolers and Freezers Energy Conservation Standard Rulemaking,

– Docket Number EERE-2008-BT-STD-0015, and

– Regulatory Identification Number (RIN) 1904-AB86. 

• Email: WICF-2008-STD-0015@ee.doe.gov 

• Comment period closes: November 12, 2013, 11:59 PM EDT

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J 

1000 Independence Avenue, SW

Washington, DC 20585-0121 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945