### 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 Remarks3 

# 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 Remarks4 

# 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
- 00737 

# 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 -29458 

# 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 Remarks10 

# 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 Analysis11 

### • 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 Standards12 

### • 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 Procedures13 

### • 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 2010 2013 2012 2015 2009 2016 2011 2014 2017 201816 

# 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 Remarks17 

# 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 Analysis18 

# 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 TSD19 

# 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 TSD20 

# 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 TSD21 

# 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. O utdoor 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 TSD22 

# 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 TSD24 

# 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 Remarks25 

# 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 Analysis26 

# 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 Cost

Efficiency Curves 

#  

Details of the Engineering Analysis can be found in chapter 5 of the TSD27 

# 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 semi

hermetic. Select Baseline Units

Characterize Design Options

Model Unit Energy

Conduct Price Analysis

Develop Cost

Efficiency 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 TSD28 

# 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 Cost

Efficiency Curves Determine Representative Units

Details of the Engineering Analysis can be found in chapter 5 of the TSD29 

# 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 anti

sweat 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 TSD30 

# 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 Cost

Efficiency 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 TSD31 

# 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 TSD32 

# 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 Cost

Efficiency 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 TSD33 

# 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 Cost

Efficiency 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 TSD34 

# 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 Cost

Efficiency 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 TSD35 

# 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 Cost

Efficiency Curves Determine Representative Units

Details of the Engineering Analysis can be found in chapter 5 of the TSD36 

# Example Cost

- Efficiency Curve
C ooler 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 1 EL 2 EL 5

EL 3 EL 4 EL6 (Max tech)

Details of the Engineering Analysis can be found in chapter 5 of the TSD37 

# 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 TSD38 

# 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 Remarks39 

# 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 Analysis40 

## 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 TSD42 

# 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 TSD43 

# 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 Remarks45 

# 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 Analysis46 

# 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 TSD47 

# LCC: Overview

Detailed LCC and PBP results can be found in chapter 8 of the TSD48 

# 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 TSD49 

# 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 14 25 Passage Doors 8 Freight Doors 

### Walk

- in lifetime estimates

Details of the WICF lifetimes can be found in chapters 8 and 9 of the TSD50 

# 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 TSD51 

# 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 TSD52 

# 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 10D53 

### 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 type54 

# 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 Remarks55 

# 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 Analysis56 

# 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 TSD58 

### 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 ft 2 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 TSD59 

# 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 2045Number 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 TSD60 

# 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 2045Number 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 TSD61 

# 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 TSD62 

# 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 TSD63 

# 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 2050Price 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 TSD66 

# 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 TSD67 

# 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 TSD68 

# 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 Remarks69 

# 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 Analysis70 

### • 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 TSD71 

### • 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 burden s Phase 2 Phase 3 Phase 1

Details of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD72 

# 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 TSD73 

## • 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 TSD74 

# 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 TSD75 

## 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 TSD76 

# 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 TSD77 

# 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 TSD78 

# 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 TSD79 

# 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 TSD81 

# 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 

### CO 2 (million metric tons) 

### 248.2 255.2 261.4 298.0 317.5 365.5 NO x (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 N 2 

### O ( thousand tons ) 

### 5.4 5.5 5.7 6.4 6.9 7.9 CH 4 ( thousand tons ) 

### 1188.8 1222.7 1251.9 1427.6 1521.1 1750.6 SO 2 ( 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 TSD82 

# 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 NO x 

### 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 TSD83 

### Emissions Monetization Results: Present Value of CO 2 

### 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 TSD84 

### Emissions Monetization Results: Present Value of NO x 

### 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 TSD85 

# 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 TSD86 

# 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 TSD87 

# 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 TSD88 

# 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 TSD89 

# 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 energy

efficient equipment

Details of the Regulatory Impact Analysis can be found in chapter 17 of the TSD90 

# Regulatory Impact Analysis: Results

• DOE modified the shipments and NIA models to represent non

regulatory 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 TSD91 

# 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 TSD92 

# 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 c omponents 

### Proposed StandardIncreased Energy Savings Increased Energy Savings

Details of the Trial Standard Levels can be found in appendix 10D of the TSD93 

# 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 TSD94 

# 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. 53 .4 1063 .2 4 **+×× −**  Q

12 .0 1034 .1 3 **+×× −**  Q

89 .1 1093 .1 4 **+×× −**  Q

02 .1 1070 .5 4 **+×× −**  Q96 

# Example Graph of Proposed Refrigeration Standard

• Minimum AWEF for Dedicated Condensing, Low Temperature , Outdoor Systems at TSL 497 

# Proposed Standards for Panels

Component Type Walk

- In Operating Temperature Class Code Equations for Maximum U

- Factor (Btu/h -ft 2

- ° F )*

Structural Medium SP.M

Low SP.L

Floor Low FP.L

*A nf edge and A nf core represent the edge and core surface area of the structural panel, respectively. A fp edge and A fp core represent the edge and core surface area of the floor panel, respectively. 041 .0
core nf edge nf 024 .0 2

core nf edge nf 012 .0 **+ ×+**  **×− **  ** **  ** **  ** **  ** **  ** **  ** **  ** **  ****

A A
A A

029 .0
core nf edge nf 017 .0 2

core nf edge nf 0083 .0 **+ ×+**  **×− **  ** **  ** **  ** **  ** **  ** **  ** **  ** **  ****

A A
A A

033 .0
core fp edge fp 018 .0 2

core fp edge fp 0091 .0 **+ ×+**  **×− **  ** **  ** **  ** **  ** **  ** **  ** **  ** **  ****

A A
A A98 

# 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
*A nd represents the surface area of the non

- display door. A dd represents the surface area of the display door. 22 .0 0032 .0 **+×** nd A

0.4 14 .0 **+×** nd A

082 .0 0073 .0 **+×** nd A

4.5 11 .0 **+×** nd A

39 .0 049 .0 **+×** dd A

38 .0 33 .0 **+×** dd A100 

# Example Graph of Proposed Passage Door Standard

• Maximum Energy Use for Cooler Passage Doors at TSL 4101 

# Example Graph of Display Door Standard

• Maximum Energy Use for Cooler Display Doors at TSL 4102 

# 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 (CO 2 

### ) for equipment purchased in 2017

- 2046

– Estimated net present monetary value of the CO 2 

### emissions reduction is between $1.88 and $27.5 billion * FFC denotes full fuel cycle energy103 

# Proposed Energy Conservation Standards

Issue 25: DOE seeks comment on the appropriateness of choosing TSL 4 energy conservation standards.104 

# Closing Remarks105 

# 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