Rulemaking Framework for Automatic Commercial Ice-Makers 

United States Department of Energy 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

November 4, 2010 
ii

TABLE OF CONTENTS 

1.0 INTRODUCTION ..................................................................................................................1

1.1 The Appliances and Commercial Equipment Standards Program ..............................1

1.2 Definitions...................................................................................................................2

1.3 Current Energy Conservation Standards .....................................................................2

1.4 Overview of the Rulemaking Process .........................................................................3

1.4.1 Preliminary Analysis ....................................................................................4

1.4.2 Notice of Proposed Rulemaking ..................................................................5

1.4.3 Final Rule .....................................................................................................6

1.5 Test Procedures ...........................................................................................................7

1.6 Overview of Automatic Commercial Ice-Making Equipment....................................8

1.6.1 Cube Ice Machines .......................................................................................8

1.6.2 Flake and Nugget Ice Machines ...................................................................9

1.6.3 Block Ice Machines......................................................................................9

1.6.4 Batch and Continuous Processes .................................................................9

1.6.5 Cooling Methods ..........................................................................................9

1.6.6 Configurations............................................................................................10

1.7 Interested Parties .......................................................................................................11

2.0 ANALYSES FOR RULEMAKING .....................................................................................12

3.0 MARKET AND TECHNOLOGY ASSESSMENT .............................................................13

3.1 Market Assessment ...................................................................................................14

3.2 Equipment Classes ....................................................................................................14

3.3 Technology Assessment and Metrics........................................................................17

3.3.1 Energy ........................................................................................................17

3.3.2 Water ..........................................................................................................18

3.4 Processes ...................................................................................................................22

3.5 Type of Cooling ........................................................................................................23

3.5.1 Water-Cooled .............................................................................................23

3.5.2 Air-Cooled .................................................................................................23

3.6 Standby Mode and Off Mode Standards ...................................................................24

3.7 Baseline Units ...........................................................................................................24

3.7.1 Cube Class Baseline ...................................................................................24

3.7.2 Flake and Nugget Class Baseline ...............................................................24

4.0 SCREENING ANALYSIS ...................................................................................................26

5.0 ENGINEERING ANALYSIS ...............................................................................................26

5.1 Engineering Analysis Overview ...............................................................................27

5.2 Proposed Approach for Determining the Cost-Efficiency Relationship ...................28

5.3 Manufacturer Prices ..................................................................................................29

5.4 Proprietary Designs ...................................................................................................29

5.5 Representative Sizes .................................................................................................29

5.6 Extension of Standards .............................................................................................30

5.7 Outside Regulatory Changes Affecting the Engineering Analysis ...........................31

6.0 ENERGY AND WATER USE AND END-USE LOAD CHARACTERIZATION............31

7.0 MARKUPS FOR EQUIPMENT PRICE DETERMINATION ............................................31

8.0 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ..........................................34
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8.1 Energy Prices ............................................................................................................35

8.2 Life-Cycle Cost Discount Rates................................................................................36

8.3 Maintenance, Repair, and Installation Costs .............................................................36

8.4 Equipment Lifetimes .................................................................................................37

8.5 Water and Wastewater Costs ....................................................................................37

9.0 SHIPMENTS ANALYSIS ...................................................................................................38

9.1 Base Case Forecast ...................................................................................................38

9.2 Accounting Methodology .........................................................................................39

9.3 Standards Impacts on Shipments ..............................................................................39

10.0 NATIONAL IMPACT ANALYSIS .....................................................................................40

10.1 Inputs to Forecast ......................................................................................................40

10.2 Calculation of Energy and Water Savings ................................................................41

10.3 Net Present Value of Consumer Savings ..................................................................42

11.0 LIFE-CYCLE COST SUBGROUP ANALYSIS .................................................................43

12.0 MANUFACTURER IMPACT ANALYSIS.........................................................................43

12.1 Sources of Information .............................................................................................44

12.2 Industry Cash Flow Analysis ....................................................................................44

12.3 Manufacturer Subgroup Analysis .............................................................................45

12.4 Competitive Impacts Assessment .............................................................................45

12.5 Cumulative Regulatory Burden ................................................................................45

13.0 UTILITY IMPACT ANALYSIS ..........................................................................................46

14.0 EMPLOYMENT IMPACT ANALYSIS ..............................................................................46

15.0 ENVIRONMENTAL ASSESSMENT .................................................................................47

15.1 Carbon Dioxide .........................................................................................................47

15.2 Sulfur Dioxide ...........................................................................................................47

15.3 Nitrogen Oxides ........................................................................................................48

15.4 Mercury .....................................................................................................................48

15.5 Particulate Matter ......................................................................................................49

16.0 MONETIZATION OF EMISSIONS REDUCTIONS..........................................................49

17.0 REGULATORY IMPACT ANALYSIS ..............................................................................50

LIST OF FIGURES 

Figure 2.1. Flow Diagram of Analyses for the Automatic Commercial Ice-Maker Standards 

Rulemaking Process .................................................................................................... 13

Figure 3.1. Potable Water Use by Ice Machine Type. IMH=Ice-Making Head, RCU=Remote 

Condensing Unit, SC=Self-Contained, A=Air-Cooled, W=Water-Cooled. ............... 20

Figure 3.2. Total Water Use by Ice Machine Type ....................................................................... 21

LIST OF TABLES 

Table 1.1. Automatic Commercial Ice-Maker Standards Prescribed by EPACT 2005 Section 

136(d), Effective January 1, 2010 ................................................................................. 3

Table 3.1. Proposed Classes for Commercial Ice-Makers ............................................................ 16
iv

Table 3.2. ENERGY STAR Efficiency Requirements for Commercial Cubed Ice Machines ..... 19

Table 3.3. Unit Energy Consumption Limits by Equipment Type ............................................... 25

Table 3.4. Automatic Commercial Ice-Maker Standards Prescribed by EPACT 2005 Section 

136(d), Effective January 1, 2010 ............................................................................... 25

Table 5.1. Representative Cube Ice-Maker Sizes to Represent Product Classes .......................... 30

Table 7.1. Proposed Percentage Distribution of Shipments of Automatic Commercial Ice-Making 

Equipment, by Market Channel .................................................................................. 32

Table 8.1. Inputs to the Life-Cycle Cost and Payback Period Analyses ...................................... 35

Table 10.1. Inputs to the National Impact Analysis...................................................................... 41
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LIST OF ACRONYMS 

AEO Annual Energy Outlook

AHRI Air-Conditioning, Heating and Refrigeration Institute 

ARI Air-Conditioning and Refrigeration Institute (now AHRI) 

ASHRAE American Society of Heating, Refrigerating, and Air-Conditioning Engineers 

AWWA American Water Works Association 

BT Building Technologies Program 

CAIR Clean Air Interstate Rule 

CAMR Clean Air Mercury Rule 

CEE Consortium for Energy Efficiency 

CO2 carbon dioxide 

CSL candidate standard level 

DC (Washington) District of Columbia 

DOE U.S. Department of Energy 

DOJ U.S. Department of Justice 

ECM electronically commutated motor 

EERE Office of Energy Efficiency and Renewable Energy 

EGU electricity generating unit 

EIA Energy Information Administration 

EISA 2007 Energy Independence and Security Act of 2007 

E.O. Executive Order 

EPA U.S. Environmental Protection Agency 

EPACT 2005 Energy Policy Act of 2005 

EPCA Energy Policy and Conservation Act 

°F degrees Fahrenheit 

FR Federal Register 

gal gallon(s) 

GDP gross domestic product 

GHG greenhouse gas 

GRIM Government Regulatory Impact Model 

HCFC hydrochlorofluorocarbon 

Hg mercury 

ImSET Impact of Sector Energy Technologies 

IMH ice-making head 

kWh kilowatt-hour 

lb pound(s) 

LCC life-cycle cost 

MIA manufacturer impact analysis 

MPC manufacturer production cost 

NEMS National Energy Modeling System 

NES national energy savings 

NIA national impact analysis 

NOPR notice of proposed rulemaking 

NOX nitrogen oxides 

NPV net present value 
vi

NWS National Water Savings

OMB Office of Management and Budget 

PBP payback period 

PM particulate matter 

PSC permanent split capacitor 

Pub. L. Public Law 

psig pounds per square inch gauge 

R&D research and development 

RIA regulatory impact analysis 

SCC social cost of carbon 

SG&A selling, general, and administrative 

SO2 sulfur dioxide 

TSD technical support document 

TSL trial standard level 

U.S. United States 

U.S.C. U.S. Code 

yr year(s) 

WACC weighted-average cost of capital 
1 

1.0 INTRODUCTION 

The U.S. Department of Energy (DOE) Appliances and Commercial Equipment 

Standards Program within the Office of Energy Efficiency and Renewable Energy’s (EERE) 

Building Technologies Program (BT) develops and promulgates test procedures and energy 

conservation standards for certain consumer appliances and commercial equipment. The process 

for developing standards involves analysis, public notice and comment, and consultation with 

interested parties. “Interested parties” include manufacturers, consumers, energy conservation 

and environmental advocates, State and Federal agencies, and any other groups or individuals 

with an interest in these standards and test procedures. 

The purpose of this document is to describe the procedural and analytical approaches 

DOE anticipates using to determine whether the energy conservation standards for automatic 

commercial ice-making equipment should be amended and, if so, to evaluate potential amended 

standards. (See section 1.1 for a discussion of the statutory authority for this rulemaking.). This 

document is intended to inform interested parties of the process DOE will follow for this 

rulemaking for automatic commercial ice-making equipment and to encourage and facilitate the 

input of interested parties. This document is the starting point for determining whether standards 

should be amended and, if so, for developing such standards. This document is not a definitive 

statement on any issue for which a determination may be made in the rulemaking. 

Section 1.0 of this report provides an overview of DOE’s rulemaking process. Sections 

2.0 through 17.0 discuss analyses DOE intends to conduct to fulfill the statutory requirements 

and guidance for this energy conservation standards rulemaking. As part of this rulemaking, 

DOE is required to determine whether to amend existing energy conservations standards for this 

equipment. DOE believes that these analyses will support its determination of whether to amend 

the standards and, if the determination is positive, to establish any amended standards. DOE will 

maintain information about this rulemaking on its website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/automatic_ice_making_

equipment.html.

Item 1-1 While DOE invites comment on all aspects of the material presented in this 

document, several specific issues on which DOE seeks comment are set out in 

comment boxes like this one. DOE uses these comment boxes to highlight issues 

and ask specific questions on the approaches DOE plans to follow to conduct the 

analyses required for the energy conservation standards rulemaking. Such 

requests for feedback are numbered sequentially throughout the document and 

are repeated in Appendix A.

1.1 The Appliances and Commercial Equipment Standards Program 

Title III, Part C of the Energy Policy and Conservation Act of 1975 (EPCA), Pub. L. 94-

163 (42 U.S.C. 6311–6317, as codified), added by Pub. L. 95-619, Title IV, § 441(a), established 

the Energy Conservation Program for Certain Industrial Equipment, a program covering certain 
2 

industrial equipment, which includes the automatic commercial ice-making equipment that is the 

focus of this notice.1

Section 136(d) of the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58,

amended section 342 of EPCA to add paragraph (d), which set energy conservation standards for 

automatic commercial ice-makers that produce between 50 and 2,500 pounds (lb) of cube-type 

ice per 24-hour period. Automatic commercial ice-makers manufactured on or after January 1, 

2010 are required to meet specific maximum allowable energy use levels and maximum 

allowable condenser water use levels, depending on equipment type, cooling type (water or air), 

and harvest rate (pounds of ice per 24-hour period). 

The EPACT 2005 amendments (42 U.S.C. 6313(d)(2)) also authorize DOE to issue 

standards for types of automatic commercial ice makers that are not covered by 42 U.S.C. 

6313(d)(1). In addition, not later than January 1, 2015, with respect to the standards at 42 U.S.C 

6313(d)(1), and not later than 5 years after the effective date of any standards issued by DOE 

under 42 U.S.C. 6313(d)(2), DOE is to issue a final rule to determine whether amending the 

applicable standards is technologically feasible and economically justified. (42 U.S.C. 

6313(d)(3)(A)) Any final rule issued by the Secretary establishing a new or amended standard 

shall provide that the new or amended standard applies to products manufactured on or after the 

date that is 3 years after the standard is published, unless the Secretary determines by rule that 3 

years is inadequate, in which case the standard shall apply to products manufactured on or after a 

date no later than 5 years after the date on which the final rule is published. Any new or amended 

standard issued by the Secretary under 42 U.S.C. 6313(d) shall be set at the maximum level that 

is technically feasible and economically justified. This framework document is being published 

as a first step toward meeting these statutory requirements. 

1.2 Definitions 

Section 136(a)(4) of EPACT 2005 defines “automatic commercial ice maker” as: 

[A] factory-made assembly (not necessarily shipped in one package) that – 

(A) consists of a condensing unit and ice-making section operating as an integrated unit, 

with means for making and harvesting ice; and 

(B) may include means for storing ice, dispensing ice, or storing and dispensing ice. 

(42 U.S.C. 6311(19)) 

1.3 Current Energy Conservation Standards 

Table 1.1 shows the current standard for automatic commercial ice-making equipment.

This standard covers energy use and maximum condenser water use of cube ice machines. It 

does not apply to flake, nugget, or block ice machines. 

 

1

 For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1.
3 

Table 1.1. Automatic Commercial Ice-Maker Standards Prescribed by EPACT 2005 

Section 136(d), Effective January 1, 2010 

Equipment Type Type of 

Cooling

Harvest Rate

lb ice/24 hours

Maximum Energy 

Use

kWh/100 lb ice

Maximum Condenser Water 

Usea

gal/100 lb ice

Ice-Making Head Water

<500 7.80 - 0.0055Hb200 - 0.022H

≥500 and <1,436 5.58 - 0.0011H 200 - 0.022H

≥1,436 4.0 200 - 0.022H

Air <450 10.26 - 0.0086H Not Applicable

≥450 6.89 - 0.0011H Not Applicable

Remote Condensing 

(but not remote 

compressor)

Air <1,000 8.85 - 0.0038H Not Applicable

≥1,000 5.10 Not Applicable

Remote Condensing 

and Remote 

Compressor

Air <934 8.85 - 0.0038H Not Applicable

≥934 5.3 Not Applicable

Self-Contained

Water <200 11.40 - 0.019H 191 - 0.0315H

≥200 7.60 191 - 0.0315H

Air <175 18.0 - 0.069H Not Applicable

≥175 9.80 Not Applicable

a

 Water use is for the condenser only and does not include potable water used to make ice. 

b

 H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. 

Source: 42 U.S.C. 6313(d).

1.4 Overview of the Rulemaking Process 

Under EPCA, any new or amended standards must achieve the maximum level of energy 

efficiency that is technologically feasible and economically justified. In setting any new or 

amended standards, DOE must consider: (1) the economic impact of the standard on the 

manufacturers and consumers of the affected products; (2) the savings in operating costs 

throughout the estimated average life of the product compared to any increases in the initial cost 

or maintenance expense; (3) the total projected amount of energy savings likely to result directly 

from the imposition of the standard; (4) any lessening of the utility or the performance of the 

products likely to result from the imposition of the standard; (5) the impact of any lessening of 

competition, as determined in writing by the Attorney General, that is likely to result from the 

imposition of the standard; (6) the need for national energy conservation; and (7) other factors 

the Secretary considers relevant. (42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6313(d)) As 

discussed in further detail below, the standards rulemaking process typically involves four public 

notices that are published in the Federal Register, including a notice announcing the availability 

of the framework document. Publication of the framework document, preliminary analysis, and 

notice of proposed rulemaking (NOPR) are typically accompanied by public meetings to solicit 

comment from interested parties to enhance the rulemaking process. DOE encourages interested 

parties to develop and submit joint recommendations and will carefully consider such 

recommendations in its decision making. Preliminary analysis results could serve as the initial 

basis for the development of these recommendations. As stated previously, DOE believes the 

conduct of the analyses accompanying these notices will support DOE’s determination of 

whether to amend the standards and, if the determination is positive, to establish any amended 

standards. 
4 

Preliminary Analysis (section 1.4.1). The preliminary analysis is designed to publicly vet 

the models and tools that DOE intends to use in the rulemaking and to facilitate public 

participation before the proposed rule stage. Using these models and tools, DOE performs 

preliminary analyses to assess candidate standard levels (CSLs), which span the range of 

efficiencies from baseline equipment to the most efficient technology. 

Notice of Proposed Rulemaking (section 1.4.2). The NOPR presents a discussion of 

comments received in response to the preliminary analysis, DOE’s analysis of the 

impacts of potential standards on consumers, manufacturers, and the Nation, DOE’s 

weighting of these impacts, and any proposed standard levels for public comment. 

Final Rule (section 1.4.3). The final rule presents a discussion of comments received in 

response to the NOPR, revised analysis, as appropriate, of the impacts of any standards, 

DOE’s weighting of those impacts, and the standard levels, if any, that DOE is adopting. 

The final rule also establishes the date by which manufacturers must comply with any 

standards. 

1.4.1 Preliminary Analysis 

As part of its energy conservation standards rulemaking activity, DOE typically identifies 

equipment technology options and makes a preliminary determination on whether to retain each

option for detailed analysis or to eliminate it from further consideration. This process includes a 

market and technology assessment (section 3.0) and a screening analysis (section 4.0). DOE 

applies four screening criteria in the screening analysis to determine which technology options to 

eliminate from further consideration: (1) technological feasibility; (2) practicability to 

manufacture, install, and service; (3) adverse impacts on equipment utility or availability; and 

(4) adverse impacts on health or safety. Technologies that pass through the screening analysis are 

evaluated, and referred to as technology or design options, in the engineering analysis. 

DOE consults with interested parties and independent technical experts and researches 

industry literature to identify the key issues and design options or efficiency levels that DOE will 

consider in the rulemaking. DOE initiates dialogue with interested parties with this framework 

document, the public meeting following its publication, and the request for public comment. This 

dialogue provides an opportunity for input into the structural and analytical approach planned for 

the subsequent energy conservation standards rulemaking. 

At the start of the preliminary analysis, DOE considers design options or efficiency levels 

for each equipment class. DOE uses these design options or efficiency levels to collect 

manufacturer cost data, historical shipment data, shipment-weighted average efficiency data, and 

preliminary manufacturer impact data (e.g., capital conversion expenditures, marketing costs, 

and research and development (R&D) costs). Concurrent with the preliminary analysis, DOE 

also conducts other principal analyses, including: 

1. Engineering analysis (section 5.0); 

2. Consumer life-cycle cost (LCC) and payback period (PBP) analyses (section 8.0); 
5 

3. National impact analysis (NIA), which considers national energy savings (NES) and 

consumer net present value (NPV) (section 10.0); and 

4. Preliminary manufacturer impact analysis (MIA) (section 12.0). DOE will present the 

results of these analyses in the preliminary analysis technical support document (TSD). 

DOE selects CSLs from the energy efficiency or energy use levels considered in the 

preliminary analysis. Discussion of various CSLs in the preliminary analysis will help interested 

parties review the spreadsheet models that underpin the analyses. DOE will use comments from 

interested parties to refine the models for the next stage of the rulemaking analyses. In addition 

to the efficiency corresponding to the maximum technologically feasible (“max-tech”) design and 

the efficiency corresponding to the minimum LCC point, DOE generally considers efficiency 

levels or design options that span the full range of technologically achievable efficiencies. The 

range of efficiency levels DOE typically analyzes includes the following: 

The baseline efficiency level typically represents equipment with the lowest energy 

efficiency on the market. For equipment where minimum energy conservation standards 

already exist, the baseline efficiency level is typically defined by the existing energy 

conservation standard. 

The level with the minimum LCC or greatest LCC savings. 

The highest energy efficiency level or lowest energy consumption level that is 

technologically feasible (i.e., max-tech). 

Levels that incorporate noteworthy technologies or fill large gaps between other 

efficiency levels being considered. 

At the preliminary analysis stage, DOE uses analytical models and tools to assess the 

different equipment classes at each efficiency or energy use level analyzed. Many of these 

analytical models and tools are in the form of spreadsheets, which are used to conduct the LCC 

and PBP analyses and to determine the NES and NPV of prospective standards. 

DOE will make the spreadsheet tools and results of the preliminary analysis available on 

its website for review.2 When it publishes the preliminary analysis, DOE will also make a 

preliminary TSD available, which contains the details of all the analyses performed to date. After 

publication of the preliminary analysis, DOE will provide a public comment period and hold one 

public meeting. 

1.4.2 Notice of Proposed Rulemaking 

In developing the NOPR, DOE will consider all the comments it receives on the 

preliminary analysis, within the stated comment period. This process may result in revisions to 

 

2

 All materials associated with the rulemakings for automatic commercial ice-making equipment test procedures and 

energy conservation standards are available on DOE’s website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/automatic_ice_making_equipment.html
6 

the preliminary analysis, including the engineering and LCC analyses. At this point, DOE will 

conduct additional economic and environmental impact analyses. These analyses generally 

include: 

1. Consumer LCC subgroup analysis (section 11.0);

2. Complete MIA (section 12.0);

3. Utility impact analysis (section 13.0);

4. Employment impact analysis (section 14.0);

5. Environmental assessment (section 15.0); and 

6. Regulatory impact analysis (RIA) (section 17.0).

DOE will describe the methodology used and make the results of all the analyses 

available on its website for review. Based on comments from interested parties, further revisions 

to the analysis may be made. This analytical process ends with the selection of proposed standard 

levels, if any, that DOE will present in the NOPR. DOE selects the proposed standard levels 

from the trial standard levels (TSLs) analyzed during the NOPR phase of the rulemaking. The 

NOPR, published in the Federal Register, will document the evaluation and selection of any 

proposed standards levels, along with a discussion of other TSLs considered but not selected and 

the reasons DOE did not select them. 

For each equipment class, DOE will identify the max-tech efficiency level. If DOE 

proposes a lower level, DOE will explain the reasons for eliminating higher levels, beginning 

with the highest level considered. DOE will present the analytical results in the NOPR and 

provide the details of the analysis in an accompanying TSD. 

DOE considers many factors in selecting proposed standards. These factors are contained 

in EPCA and take into consideration the benefits, costs, and impacts of energy conservation 

standards. 

When DOE publishes the NOPR, it will provide the U.S. Department of Justice (DOJ) 

with copies of the NOPR and TSD to solicit feedback on the impact of any proposed standard 

levels on competition in the automatic commercial ice-maker industry. DOJ reviews standard 

levels in light of any lessening of competition likely to result from the imposition of such 

standards. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) Publication of the NOPR will be followed 

by a public comment period that includes a public meeting. 

1.4.3 Final Rule

After publication of the NOPR, DOE will consider public comments it receives on the 

proposal and accompanying analyses. DOE will review the engineering and economic impact 

analyses and any proposed standards based on these comments and consider modifications where 

necessary. Before any final rule is issued, DOE also will consider DOJ comments on the NOPR 
7 

relating to the impacts of any proposed standard levels on competition to determine whether 

changes to these standard levels are needed. DOE will publish the DOJ comments and DOE’s 

response as part of the final rule. 

In any final rule, DOE would determine whether to amend the standards, and if such 

determination is positive, would select the final standard level based on the complete record of 

the standards rulemaking. The final rule would set any final standard levels and the compliance 

date, and would also explain the basis for the selection of any final standard levels. The final rule 

would be accompanied by a final TSD. 

1.5 Test Procedures 

On December 8, 2006, DOE published a final rule (the 2006 test procedure final rule) 

that adopted the test procedure specified in Air-Conditioning and Refrigeration Institute (ARI) 

Standard 810-2003, as in effect on January 1, 2005, with a revised method for calculating the 

energy consumption rate. 71 FR 71340, 71350. DOE used a revised calculation to specify that 

the energy consumption rate be normalized to 100 lb of ice produced. ARI Standard 810-2003 

references the test procedure outlined in the American Society of Heating, Refrigerating and AirConditioning Engineers (ASHRAE) Standard 29 as the testing method. 

Section 342(a)(7)(B) of EPCA states that if the ARI Standard 810-2003 is amended, the 

Secretary shall amend the test procedures as necessary to be consistent with the amended ARI 

standards. (42 U.S.C 6314(a)(7)(B)) 

Since the publication of the 2006 final rule, ARI has updated their Standard 810 to reflect 

changes in the industry. A new version, Air-Conditioning, Heating and Refrigeration Institute 

(AHRI) Standard 810-2007, has been published, but DOE’s test procedure has not been 

amended. 

The new AHRI Standard 810-2007 amends the previous testing procedure, ARI Standard 

810-2003, in several ways. The new test procedure: 

1. Expands the capacity range of covered equipment to between 50 pounds of ice per 24 

hours and up to 4,000 pounds of ice per 24 hours at standard rating conditions; 

2. Provides definitions and specific test procedures for cube type and continuous type icemakers; and 

3. Adds several other definitions related to quality of ice that do not pertain to values used 

to show compliance with the DOE energy conservation standard. 

The changes in AHRI Standard 810-2007 reflect the new test procedure in ASHRAE 

Standard 29 that also differentiates between cube-type and continuous-type ice-makers. The 

previous version of ASHRAE Standard 29 did not include test procedures for continuous-type 

ice-makers. As such, DOE intends to modify its test procedure to reference the updated AHRI 

Standard 810-2007 and expand the test procedure to apply to all automatic commercial icemakers regardless of ice type with capacities up to 4,000 lb per day. 
8 

DOE is also considering adding to the test procedure a method to calculate the total water 

use of automatic commercial ice-makers; it would be defined as the sum of the condenser water 

use and the water used to make ice. This value would use a metric of gallons per 100 lb of ice. 

DOE will conduct a separate rulemaking process for any modifications to the test procedure. 

Item 1-2 DOE requests comment regarding the development of updated test procedures 

for the automatic commercial ice-making equipment covered under this 

rulemaking. 

Item 1-3 DOE requests comment on the possibility of applying the AHRI 810-2007 test 

procedure to larger capacity equipment and tube type ice-makers. If the AHRI 

810-2007 test procedure cannot be applied to larger capacity and tube type icemakers, what test procedure should be applied? 

1.6 Overview of Automatic Commercial Ice-Making Equipment 

The automatic commercial ice-making equipment covered under this rulemaking can be 

primarily categorized by output (type of ice produced). The primary categories are as follows: 

Cube ice machines, including water- or air-cooled, and either self-contained or with 

remote condensing units; 

Flake and nugget ice machines, including water- or air-cooled, and either self-contained 

or with remote condensing units; and 

Block ice machines, including water- or air-cooled, and self-contained or with remote 

condensing units.

Other distinguishing features include process (continuous or batch method), cooling (air 

or water), or equipment configurations (self-contained or with a remote condensing unit). The 

current EPACT 2005 standard includes only cube ice machines, including water- and air-cooled, 

and both self-contained and those with remote condensing units. The categories and their 

distinguishing features are described in sections 1.6.1 through 1.6.6, and are based on A report 

on Potential Best Management Practices, prepared by Koeller and Company (Koeller 20083). 

Section 3.2 provides more detail on product classes, as identified in the EPACT 2005 

standard and in the present rulemaking process. 

1.6.1 Cube Ice Machines 

Cube ice is a hard, clear ice that is well suited to beverages. Cube ice is made by 

recirculating water over a freeze plate that is directly cooled by the evaporation of the refrigerant. 

The recirculating water pumped over the surface flushes away minerals that precipitate as ice 

 

3

 Koeller J., and H. Hoffman, A report on Potential Best Management Practices. 2008. Prepared by Koeller and 

Company for the California Urban Water Conservation Council, Sacramento, CA. 
9 

freezes. At the end of the cycle, the ice is released by warming the plate and the water in the 

recirculation trough is purged to dispose of the minerals removed from the ice in the freezing 

process. The process is controlled by an electronic control panel. 

1.6.2 Flake and Nugget Ice Machines 

Flake ice finds wide use where a clear, hard cube is not needed. The product is a flake of 

“soft” ice. Nugget ice is made in the same way as flake, except that the flake ice is recombined 

into chunks or nuggets of ice. For most commercial use, the ice-making head (IMH) contains 

cylinders wrapped by cooling (evaporator) coils. Water is fed to the inside of the tube and ice 

forms on the inside surface. An auger continuously scrapes the sides of the tube to remove the 

ice as it forms. For very large flake ice machines, a cylinder and scraper blade system is used in 

place of the auger. Because there is no recirculation and purge system like that of the cube 

machines, water is not discharged to the drain in the ice-making process. Nugget ice machines 

form ice in the same manner as flake machines, but the ice is formed into a unique shape by 

extruding the flakes through a tube or dye. The ice forms a number of chunks or nuggets that, 

among other things, can be conveyed through a tube to an ice bin or soft drink machine located 

several feet away. 

1.6.3 Block Ice Machines 

Block ice is commonly used for refrigeration and sculptures. Like cube ice, block ice is 

made with a manual batch process. The block ice machine is cooled by air, water, or a 

combination of propylene glycol and water. Block ice-makers typically produce blocks weighing 

anywhere between 8 and 275 lb.

1.6.4 Batch and Continuous Processes 

The batch process consists of separate ice-making and harvesting modes. Cube ice is 

made by using the batch process. In contrast, flake and nugget machines use a continuous icemaking process. In the continuous process, water is fed to the inside of a tube. Ice forms on the 

inside surface of the tube, and an auger or cylinder and scraper blade continuously scrapes the 

sides of the tube to remove the ice as it forms. 

1.6.5 Cooling Methods 

Categorization of automatic ice-makers is often based partially on the cooling media used 

to remove waste heat from the refrigeration system. These media are typically water or air. In a 

water-cooled machine, three cooling methods can be used: once-through or pass-through 

cooling, chilled water loop systems, or evaporative cooling by the use of a cooling tower. 

Air-cooled machines remove waste heat by drawing air over the cooling coils with a fan 

to cool the compressed refrigerant gas so that it will condense back to a liquid. 

Item 1-4 DOE seeks comment on the categories of automatic commercial ice-making 

equipment. 
10

1.6.6 Configurations 

A typical ice-maker consists of a case, insulation, refrigeration system, and a water 

supply system. Some of the smaller models have an integrated storage bin, but most have only an 

ice-making system and are installed on top of a separate insulated ice storage bin. 

An ice machine consists of two major subsystems: the refrigeration system and water 

supply and circulation system. Ice machines primarily use vapor compression to produce the 

refrigeration needed for ice production. In this process, water is circulated across the evaporator 

face and cooled by heat transfer with the refrigerant. The water freezes into ice and is discharged, 

either in a continuous or batch process using thermodynamic or mechanical processes. The 

refrigeration system removes heat from the warmed refrigerant and recirculates it for continued 

heat transfer. Water is continuously supplied to a water sump and distributed using water 

distribution tubing or piping to maintain sufficient water levels. As indicated in the report Energy 

Savings Potential and R&D Opportunities for Commercial Refrigeration, Final Report by 

Navigant Consulting, Inc. (Navigant 20094

), primary refrigeration components include: 

Compressor typically conventional reciprocating refrigeration or heat pump 

compressors of 1/3 to 3 hp capacity 

Condenser conventional air-cooled fin-tube or water-cooled concentric tube type 

Expansion device both thermostatic expansion valves and capillary tubes are used 

Evaporator typically copper tubing attached to a copper or stainless steel icemaking surface with plastic attachments to shape individual cubes 

Liquid line/suction line interchanger 

Refrigerant piping 

Hot gas bypass line (cubers only) directs refrigerant directly from compressor to 

evaporator for harvesting ice 

Hot gas solenoid valve (cubers only) controls hot gas refrigerant flow to the 

condenser during ice production and to the evaporator during ice harvest 

Refrigerant traditionally 134A and R-22, transitioning to R-404A 

Suction accumulator (in certain models only) 

The water system consists of the following: 

 

4

 Navigant Consulting, Inc. Energy Savings Potential and R&D Opportunities for Commercial Refrigeration, Final 

Report. 2009. Prepared for the U.S. Department of Energy Office of Efficiency and Renewable Energy, Washington, 

D.C. Available online at: 

http://apps1.eere.energy.gov/buildings/publications/pdfs/corporate/commercial_refrig_report_10-09.pdf. 
11

Potable water supply connection and control valve 

Water sump 

Water circulation pump

Water circuit plastic tubing and evaporator water distributor 

Purge drain (cubers only) 

1.7 Interested Parties 

Interested parties, or stakeholders, include manufacturers, consumers, energy 

conservation and environmental advocates, State and Federal agencies, and any other groups or 

individuals with an interest in the standards. DOE research into interested parties has thus far 

identified the following. 

Manufacturers: 

A&V Refrigeration 

Arctic-Temp/Holiday-Ice 

Brema Ice Makers 

Cornelius 

Follett 

Hoshizaki 

Howe 

Ice-O-Matic 

ITV 

Kold-Draft

Manitowoc 

North Star 

Scotsman 

Sno-Block 

Summit Appliance 

Tube-Ice/Vogt-Ice, LLC 

Whirlpool 

Other Stakeholders: 

Air-Conditioning, Heating and Refrigeration Institute 

Alliance for Water Efficiency 

Alliance to Save Energy 

American Council for an Energy-Efficient Economy 

American Society of Heating, Refrigerating and Air-Conditioning Engineers 

Appliance Standards Awareness Project 
12

Consortium for Energy Efficiency (CEE) 

Earthjustice 

Great Lakes Ice Association 

Missouri Valley Ice Manufacturers Association 

National Electrical Manufacturers Association 

National Resources Defense Council 

Northeastern Ice Association 

Northwest Energy Efficiency Alliance 

Southern Ice Exchange 

Southwestern Ice Association 

Western Ice Association 

Item 1-5 DOE seeks information concerning any entities that should be added to the 

interested parties list, in particular additional manufacturers, small business 

manufacturers, consumers, and energy conservation and environmental 

advocates. 

2.0 ANALYSES FOR RULEMAKING 

The purpose of the analyses is to support DOE’s determination on whether to amend the 

energy conservation standards for automatic commercial ice-making equipment. The analyses 

ensure that if standards are amended, DOE selects standards that achieve the maximum 

improvement in energy efficiency that is technologically feasible and economically justified and 

will result in significant energy savings, as required by EPCA. Economic justification includes 

the consideration of the factors set forth in EPCA (see section 1.4 of this framework document), 

which encompass economic impacts on domestic manufacturers and consumers, national 

benefits including environmental impacts, issues of consumer utility, and impacts from any 

lessening of competition. 

Figure 2.1 summarizes the analytical components of the DOE standards-setting process. 

The analyses are presented in the center column. Each analysis has a set of key inputs, which are 

data and information required for the analysis. “Approaches” are the methods that DOE will use 

to obtain key inputs, which may vary depending on the information in question. Some key inputs 

exist in public databases. DOE will also collect information from interested parties or others with 

special knowledge and develop information independently to support the rulemaking. The results 

of each analysis are key outputs, which feed directly into the rulemaking. Arrows indicate the 

flow of information between the various analyses. DOE ensures a consistent approach to its 

analyses throughout the rulemaking by considering each analysis as a part of the overall 

standard-setting framework. 
13

Figure 2.1. Flow Diagram of Analyses for the Automatic Commercial Ice-Maker 

Standards Rulemaking Process 

3.0 MARKET AND TECHNOLOGY ASSESSMENT 

The market and technology assessment will provide information about the automatic 

commercial ice-maker industry that DOE will use throughout the rulemaking. This assessment is 

particularly important at the outset of the rulemaking to determine equipment classes and to 

identify potential design options or efficiency levels for each equipment class. 
14

3.1 Market Assessment 

DOE will qualitatively and quantitatively characterize the structure of the automatic 

commercial ice-maker industry and market. In the market assessment, DOE will identify and 

characterize the manufacturers of this equipment; estimate market shares and trends in the 

market; address regulatory and non-regulatory initiatives intended to improve the energy 

efficiency or reduce the energy consumption of the automatic commercial ice-making equipment 

covered under this rulemaking, and explore the potential for technological improvements in the 

design and manufacture of such equipment. 

This market assessment will establish the context for this rulemaking, and it will serve as 

a resource to guide the analyses that follow. For example, DOE may use historical shipments and 

prices as indicators of future shipments and prices. In addition, DOE plans to use market 

structure data for the manufacturer impact analysis (MIA), data that will be particularly useful 

for assessing competitive impacts. This phase also allows DOE to start updating design options 

by reviewing equipment literature and industry publications. 

The Automatic Commercial Ice Makers and Ice Storage Bins Manufacturers Division of 

AHRI is the trade association for manufacturers of equipment covered under this rulemaking. 

DOE expects that AHRI will play a critical role in providing market information, including input 

on characterizing current and historical trends in equipment shipments and energy efficiency. 

This type of data is an important input for analyses that determine whether any amended energy 

conservation standards are economically justified and will result in significant energy savings. 

DOE encourages interested parties to submit data that will improve DOE’s understanding 

of the automatic commercial ice-making equipment market. DOE aggregates data provided by 

manufacturers and other organizations for use in its analyses. 

Item 3-1 DOE seeks information on annual shipments into the U.S. market from 1995 to 

2010 (both domestic and imports) by equipment class, and the corresponding 

shipment-weighted average efficiency of these shipments. 

Item 3-2 DOE seeks information on the proportion(s) of equipment shipped annually that 

replaces existing equipment. 

3.2 Equipment Classes 

DOE classifies the automatic commercial ice-making equipment covered under this 

rulemaking into equipment classes (Table 3.1). The statutory criteria for separation into different 

classes are type of energy used and capacity or other performance-related features that justify the 

establishment of a separate energy conservation standard. In determining whether a performancerelated feature justifies a higher or lower standard, DOE must consider such factors as utility to 

the consumer of such performance-related features and other factors the Secretary deems 

appropriate. (42 U.S.C. 6295(q) and 6313(d)) 

The EPACT 2005 standard, referenced in section 1.1 of this document, covered cube type 

ice machines with capacities between 50 and 2,500 lb per 24-hour period. (42 U.S.C. 6313(d)(1)) 
15

Section 342(d) of EPCA also provides that DOE may issue, by rule, standard levels for types of 

automatic commercial ice-makers not specified by Congress. (42 U.S.C. 6313(d)(2)(A)) 

Ice-making equipment classes are defined according to equipment type (ice-making head, 

self-contained or with a remote condensing unit), cooling method (air or water), harvest rate 

capacity (pounds per 24 hours) and output (type of ice produced). DOE is considering the 

equipment classes listed in Table 3.1. 

DOE is considering amending the existing standard for cube machines and extending it to 

include machines with capacities up to 4,000 lb per 24-hour period, and is proposing to issue a 

new standard for continuous-type flake, nugget, and tube machines with capacities up to 4,000 lb 

per 24-hour period. During the public comment period for the test procedure proposed rule 

promulgated in 2006, which served to adopt test procedures for the EPACT 2005 automatic 

commercial ice-maker standards, stakeholders requested that additional product classes be 

considered. Specifically, Howe Corporation requested that DOE test procedures and 

requirements be amended and expanded to apply a revised ARI Standard 810 to all automatic 

ice-makers regardless of ice-cube type (docket number EE-RM/TP-05-500, Howe, No. 6 at pp. 

3 4). At that time DOE stated: 

Consideration for expanding the standard for automatic commercial ice makers to 

include equipment that produces ice other than cube-type ice is outside the scope 

of this rulemaking proceeding. DOE acknowledged at the public meeting, 

however, that it is authorized to adopt standards for such other commercial ice 

makers (42 U.S.C. 6313(d)(2)), and if and when it seeks to adopt such standards, 

it intends to consider ice makers that produce flake type ice. (Public Meeting 

Transcript, No. 18.8 at pp. 46, 48) 

71 FR 71340, 71351 

Furthermore, as noted in section 1.5 of this document, a new version of the referenced 

test procedure, ARI 810-2007, has been published, and the test establishes a capacity range of 

50.0 to 4,000.0 lb of ice per day at standard rating conditions, and includes continuous-type icemakers. 
16

Table 3.1. Proposed Classes for Commercial Ice-Makers 

Type of Ice

Equipment Type Type of Cooling Harvest Capacity Rate

lb/day

Cube Flake Nugget

Ice-Making Head

Water

<500 Existing Proposed Proposed

≥500 and <1,436 Existing Proposed Proposed

≥1,436 Existing Proposed Proposed

Air

<450 Existing Proposed Proposed

≥450 Existing Proposed Proposed

Remote Condensing 

(but not remote 

compressor) 

Air

<1,000 Existing Proposed Proposed

≥1,000 Existing Proposed Proposed

Remote Condensing 

and Remote 

Compressor

Air

<934 Existing Proposed Proposed

≥934 Existing Proposed Proposed

Self-Contained Unit

Water

<200 Existing Proposed Proposed

≥200 Existing Proposed Proposed

Air

<175 Existing Proposed Proposed

≥175 Existing Proposed Proposed

DOE does not propose to include a class for block ice at this time. Research thus far 

shows domestic block ice machines tend to be manual and the automatic commercial block ice 

machines researched are manufactured internationally for sale internationally. 

To accommodate ice machines with harvest rates between 2,500 and 4,000 lb of ice per 

24-hour period, and to reflect the current market availability of automatic commercial 

ice-making machines, DOE will evaluate the harvest capacity rate breakdowns used in the 

current standard during the initial stages of the engineering analysis. If needed, DOE will 

identify revised harvest rate breakdowns. 
17

Item 3-3 DOE requests feedback on amending the current standard for cube machines. 

Item 3-4 DOE requests feedback on promulgating a new standard to include flake, 

nugget, and tube machines. 

Item 3-5 DOE requests feedback on the exclusion of block ice-makers from promulgation 

of a new standard at this time. DOE particularly seeks information on the 

potential for domestic use of automatic commercial block ice-makers. 

Item 3-6 DOE requests feedback on tube type machines. DOE understands the machines 

have tube-shaped evaporators and/or make tube-shaped ice and that these 

machines operate cyclically like cube machines, but they do not produce clear 

ice. DOE requests comment on whether separate equipment classes should be 

established for such equipment. If yes, what are the appropriate capacity ranges 

for these classes? If not, with which of the proposed equipment classes should 

the tube machines be grouped? 

Item 3-7 DOE requests feedback concerning the proposed harvest rate breakdowns, and if 

they accurately reflect the current market. 

Item 3-8 DOE requests feedback on the proposed equipment classes for the automatic 

commercial ice-making equipment covered under this rulemaking, and the 

criteria used in creating the classes. 

Item 3-9 DOE requests comment on including ice-makers with capacities greater than 

4,000 pounds per day in this rulemaking. If DOE should include standards for 

ice-makers with capacities larger than 4,000 pounds per day, what should the 

range of capacities be in this rulemaking? 

3.3 Technology Assessment and Metrics 

3.3.1 Energy 

The technology assessment centers on understanding how equipment uses energy and 

water and what measures can reduce energy and water consumption of automatic commercial 

ice-making equipment. 

Measures that could improve the energy efficiency of equipment are called technology 

options, and they are based on existing technologies as well as prototype designs and concepts. 

In consultation with interested parties, DOE intends to develop a list of technology options that 

should be considered in the analysis. 

DOE is studying technology options by reviewing manufacturer catalogs, recent trade 

publications, technical journals, and patent filings. DOE also intends to consult with technical 

experts within the field and to conduct manufacturer interviews about these technology options. 

For the preliminary analysis, DOE is currently considering the specific technologies and designs 

listed below. 
18

Current research shows the following technologies and design change options for 

improving ice-making equipment efficiencies:5

1. Higher Insulation Levels 

2. Permanent Split Capacitor (PSC) Condenser Fan Motor 

3. Electronically Commutated Motor (ECM) for Condenser Fan Motors 

4. Higher Efficiency Compressors 

5. Design Options which Reduce Harvest Meltage 

6. Design Options which Reduce Evaporator Thermal Cycling 

7. High Efficiency Fan Blades 

Item 3-10 What technologies or designs, if any, should be added to or removed from the 

above list? If certain changes to the list are not applicable to all equipment 

classes, what equipment classes are affected? 

3.3.2 Water 

The current standards for automatic commercial ice-makers (42 U.S.C. 6313(d)(1)) 

regulate the maximum condenser water use (gallon per 100 lb of ice) for water-cooled products. 

DOE is considering whether to extend the standard to include total maximum water use, which 

includes water use for condenser cooling, water that becomes ice, and water drained from the 

sump between ice-making cycles. Water is used in both the condensing unit and to make ice. In 

addition, there can be large variations in the amount of water used to produce a given mass of ice 

depending of the type of ice-maker and type of ice being produced. Water used to produce ice 

can also affect ice quality. AHRI Standard 810-2007 defines “dump water” as the water drainage 

from an ice-maker to control the clarity of ice or to prevent scaling. Increased dump water 

increases the clarity of ice, but also increases overall water use. Both the previously referenced 

ARI Standard 810-2003 and the updated AHRI Standard 810-2007 provide a test method to 

measure the water used in making ice in units of gallons per 100 lb of ice. Recent research, 

including work by the CEE,6 Koeller,7and American Council for an Energy Efficient Economy,8

suggests significant water savings can be attained through more efficient ice-making machines. 

The current U.S. Environmental Protection Agency (EPA) ENERGY STAR Standard9

and 

Canada’s High Efficiency Standard10 limit water use in air-cooled machines, as illustrated in 

 

5

 Navigant 2009. 

6

 CEE. High Efficiency Specifications for Ice Machines. 2008. Consortium for Energy Efficiency, Boston, MA. 

7

 Koeller 2008. 

8

 ACEEE. Analysis of Standards Options for Commercial Packaged Refrigerators, Freezers, Refrigerator-Freezers 

and Ice Makers. 2004. American Council for an Energy-Efficient Economy, Washington, D.C. 

9

 See www.energystar.gov/index.cfm?c=comm_ice_machines.pr_crit_comm_ice_machines. 

10 CSA C742-08. Energy Performance of automatic icemaker and storage bins. Canadian Standards Association, 

Mississauga, Ontario, Canada. 
19

Table 3.2. DOE is considering measuring potable water use as gallons/100 lb of ice for both airand water-cooled machines. 

Table 3.2. ENERGY STAR Efficiency Requirements for Commercial Cubed Ice 

Machines 

Equipment Type Harvest Rate, 

H 

lb ice/day

Energy Use 

Limit 

kWh/100 lb ice

Potable Water Use 

Limit 

gal/100 lb ice

Air-Cooled

IMH

< 450 9.23 – 0.0077H <= 25

>= 450 6.20 – 0.0010H <= 25

Remote Condensing Unit (without remote 

compressor)

< 1,000 8.05 – 0.0035H <= 25

>= 1,000 4.64 <= 25

Remote Condensing Unit (with remote 

compressor)

< 934 8.05 – 0.0035H <= 25

>= 934 4.82 <= 25

Self-Contained Unit

< 175 16.7 – 0.0436H <= 35

>= 175 9.11 <= 35

Item 3-11 DOE requests feedback on potable water use as a metric. 

The minimum amount of water necessary to produce 100 lb of ice is 12 gallons. 

However, additional water is typically required because of incomplete freezing, purge water, or 

harvest melting. These additional sources can range between 15 and 50 gallons of water use per 

100 lb of ice produced, as shown in Figure 3.1. It should be noted that Figure 3.1 displays only 

the water drawn to create ice; water use for cooling purposes is not included. 
20

Figure 3.1. Potable Water Use by Ice Machine Type. IMH=Ice-Making Head, 

RCU=Remote Condensing Unit, SC=Self-Contained, A=Air-Cooled, W=Water-Cooled. 

Additional water is used in the water-cooled machines to remove waste heat from the 

refrigeration cycle. This adds considerably to the water use and in most cases draws from the 

same potable water supply. Figure 3.2 shows that this additional water use can add from 75 to 

200 gallons of cooling water for every 100 lb of ice produced.11

 

11 Koeller 2008. 

0.0

10.0

20.0

30.0

40.0

50.0

60.0

0 500 1000 1500 2000 2500 3000 3500 4000 Water Use (gal/100 lbs ice)

Capacity (lbs ice/24 hours)

Potable Water Use by Ice Machine Type

IMH-A

RCU-A

SC-A

IMH-W (potable only)

SC-W (potable only)
21

Figure 3.2. Total Water Use by Ice Machine Type 

These larger machines also have greater water efficiency because their water sumps are 

of an appropriate size. Smaller machines tend to be equipped by manufacturers with oversized 

sumps designed in order to minimize the need for unique components for these smaller 

machines.12

The data presented above for energy and water consumption comes from the AHRI 

database. That data is provided by the manufacturers and is not independently verified by a third 

party. In 2007, however, the Financial Services Technology Consortium and the East Bay 

Municipal Utility District, with funding from Pacific Gas and Electric, Seattle Public Utilities, 

and Eugene (OR) Electric, conducted a field study to determine the actual energy and water use 

of ice machines in the field compared to their reported values in the AHRI database. The AHRI 

reported values were found to accurately represent the actual performance of the eight cube type 

machines studied within approximately 20 percent.13

 

12 Although manufacturers typically claim that water-cooled machines use less energy than air-cooled machines, the 

transportation and treatment of this additional cooling water can add considerable energy use and utility costs to 

their operation. The analysis done by Koeller and Company for the California Urban Water Conservation Council 

(Koeller 2008) found that cooling water conveyance and disposal contributed on average an additional 1.04 kWh per 

100 lb of ice produced. Although water-cooled machines use an average of 1.2 kWh less electricity per 100 lb of ice 

than similar air-cooled ice-makers, if the additional energy cost for cooling water is taken into account, the energy 

use of the two cooling methods is more comparable. 

13 Koeller 2008. 

0.0

50.0

100.0

150.0

200.0

250.0

300.0

350.0

400.0

450.0

0 500 1000 1500 2000 2500 3000 3500 4000 Water Use (gal/100 lbs ice)

Capacity (lbs ice/24 hours)

Total Water Use by Ice Machine Type

IMH-A

IMH-W

RCU-A

SC-A

SC-W
22

DOE research shows the primary focus on water savings (direct and indirect) is from 

reduction of once-through cooling. 

Item 3-12 DOE requests comment on the relationship between potable water use and 

energy efficiency. Specifically, to what degree is potable water efficiency likely 

to increase with increased stringency of energy efficiency requirements for the 

ice-makers covered under this rulemaking without explicit potable water 

efficiency requirements? 

Item 3-13 DOE seeks feedback on including total water use in the technological 

assessment. 

Item 3-14 DOE seeks input on what technologies or designs should be considered to 

improve water efficiencies. 

3.4 Processes

The batch process consists of an ice-making mode and harvesting mode. In the icemaking mode, water fills an internal water sump with about 10 to 40 percent14,15 more water than 

is required to make a given batch of ice. The refrigeration system is activated and the sump water 

is circulated over the evaporation plate with the compressor, water circulating pump, and 

compressor fan activated, if applicable. The water is cooled and ice builds up on the plate until 

the proper ice weight is reached as determined by the sump water level, compressor suction 

pressure, or the thickness of ice on the plate. 

The machine then switches to “harvest mode,” in which hot refrigerant vapor is directed 

from the compressor to the evaporator plate to melt the first layer of ice to free the cube. Some 

machines also use a mechanical means in combination with hot refrigerant gas to remove the ice 

cubes. Typically, 10 to 20 percent of ice is melted during the harvest period. Once melted, the ice 

falls into the storage bin. During the harvest process, the remaining water in the sump is purged 

and fresh potable water is circulated through the system to remove impurities. The machine then 

returns to ice-making, or “freeze mode,” when the evaporator cools to a certain temperature or a 

timer resets. 

The batch process can produce harder, clearer, and more regularly shaped ice, but is 

significantly more water- and energy-intensive. 

In most commercial flake and nugget machines, the IMH contains cylinders wrapped by 

cooling (evaporator) coils. Water is fed to the inside of the tube and ice forms on the inside 

surface. An auger continuously scrapes the sides of the tube to remove the ice as it forms. For 

very large flake ice machines, a cylinder and scraper blade system is used in place of the auger. 

Because there is no recirculation and purge system like that of cube ice machines, water is not 

 

14 Koeller 2008. 

15 Westphalen, D., R.A. Zogg, A.F. Varone, M.A. Foran. Energy Savings Potential for Commercial Refrigeration 

Equipment. 1996. 46230-00. Prepared by Arthur D. Little, Inc. for the Building Equipment Division 

Office of Building Technologies, U.S. Department of Energy, Washington, D.C. 
23

discharged to the drain in the ice-making process. However, since the ice is harvested in a wet 

state, the product does contain some unfrozen water. The amount of unfrozen water can range 

from 1 to 4 gallons per 100 lb of ice, depending on the machine.16

3.5 Type of Cooling 

3.5.1 Water-Cooled 

The three primary cooling methods are as follows:17 

1. Once-through or pass-through cooling, which involves connecting the ice machine 

directly to a potable water supply. The water is then passed through the heat exchanger 

and discharged to the drain. This method of cooling with water is the most commonly 

found and the most water-intensive. 

2. Chilled water loop systems, which are found where central chilled water is used for air 

conditioning. The ice machine is attached to the central chilled water loop, where it 

rejects heat to the chilled water, which is later removed by the air-conditioning 

equipment. 

3. Cooling towers, which provide evaporative cooling for water heated by ice-making 

equipment. Evaporative cooling is only used in complex mechanical systems, and would 

not be found in typical small to medium retail, offices, or food service facilities, but may 

be appropriate in health care, lodging, or larger educational, office, and retail complexes. 

3.5.2 Air-Cooled 

As noted in section 1.6.5, air-cooled machines remove waste heat by drawing air over the 

cooling coils with a fan to cool the compressed refrigerant gas so that it will condense back to a 

liquid.18

The condensing unit containing the compressor coils can be either integral to the icemaking equipment or separate. When the coils (condensing units) are located separately, they are 

referred to as remote condensing units. Remote condensing units are typically located outside, 

much like a home air conditioner. 

Units that reject heat directly to the space in which they are located include those with 

air-cooled IMHs and those with self-contained, air-cooled units, such as under-the-counter icemakers. The actual compressor pumps can be located either (1) at the IMH inside the building or 

(2) outside with the condensing coil. Remote condensing units are typically located on the roof 

or along an outside wall of the building. 

 

16 Navigant 2009. 

17 Navigant 2009. 

18 Koeller 2008. 
24

3.6 Standby Mode and Off Mode Standards 

The Energy Independence and Security Act of 2007 (section 310 of EISA 2007; Pub. L. 

110-140) requires quantification of standby and off mode energy consumption in energy 

conservation standards for consumer products. (42 U.S.C 6295) The section which establishes

energy conservation standards for commercial and industrial equipment, section 342, was not 

similarly amended to include requirements for addressing standby and off mode equipment. 

Therefore, standby and off modes will not be considered for automatic commercial ice-makers. 

Item 3-15 DOE welcomes comment on standby and off mode energy consumption as it 

relates to automatic commercial ice-making equipment. 

Item 3-16 DOE seeks information that would confirm or deny the presence of secondary 

cooling in automatic commercial ice-maker applications. 

3.7 Baseline Units 

Once DOE establishes equipment classes, it will select a baseline model as a reference 

point for each class, against which it can measure changes resulting from amended energy 

conservation standards. The baseline model in each equipment class represents the characteristics 

of the equipment in that class (i.e., capacity or ice produced per day). Typically, a baseline unit 

would be a model that just meets current minimum energy conservation standards, when such a 

standard exists. If there is no energy conservation standard, the baseline unit would represent 

typical industry efficiency levels. DOE will use the baseline models in the engineering analysis 

and the LCC, NES, and PBP analyses. To determine energy savings and changes in price, DOE 

will compare each higher-energy efficiency, or lower-energy consumption, design option with 

the baseline model. 

3.7.1 Cube Class Baseline 

Within the cube class engineering analysis, DOE will compare the CLS to the existing 

EPACT 2005 standard, since the applicable standard exists, and may also use them in the LCC 

and PBP analyses. 

3.7.2 Flake and Nugget Class Baseline 

Within the flake and nugget class engineering analysis, LCC, PBP and NES, DOE 

proposes using the average unit energy consumption (kWh/100 lb of ice) identified in Table 3.3

as the baseline. For comparison purposes, the commercial ice-making standards presented in 

Table 1.1 are repeated here as Table 3.4. 
25

Table 3.3. Unit Energy Consumption Limits by Equipment Type 

Equipment Type Type of 

Cooling

Capacity

lbs/day

Unit Energy Consumption

kWh/100 lbs of ice

Average (Min – Max)

Cube Flake Nugget

Ice-Making Head

Water

<500 5.4 (4.2-9.9) 4.4 (3.8-5.6) 4.6 (4.2-4.9)

≥500 and <1,436 4.3 (3.6-6.0) 3.5 (2.5-4.7) 3.7 (3.0-4.7)

≥1,436 3.9 ( 3.4-4.3) 2.7 (2.2-3.5) 2.7

Air

<450 6.8 (5.4-8.2) 5.6 (4.8-6.6) 6.2 (5.2-7.4)

≥450 5.5 (4.6-7.5) 3.8 (0.6-5.8) 4.5 (3.5-6.4)

Remote Condensing 

(but not remote 

compressor) 

Air

<1,000 5.8 (4.7-7.1) 4.9 (3.4-6.2) 5.3 (4.1-6.2)

≥1,000

4.9 (4.2-6.0) 3.4 (2.8-4.0) 3.8 (3.6 – 4.2)

Remote Condensing 

and Remote 

Compressor

Air

<934 5.8 (5.0-6.7) 4.5 4.6 (4.1-5.1)

≥934

4.7 (4.3-5.0) 3.9 4.2 (3.9-4.8)

Self-Contained Unit

Water

<200 7.8 (6.6-9.8) N/A N/A

≥200 6.5 (5.7-7.3) 5.0 (4.9-5.0) 4.6 (4.0-5.1)

Air

<175 13.0 (8.4-20.4) N/A 8

≥175 9.1 (6.8-13.0) 5.5 (4.1-6.7) 6.5 (5.3-7.6)

Source: Navigant 2009. 

Table 3.4. Automatic Commercial Ice-Maker Standards Prescribed by EPACT 2005 

Section 136(d), Effective January 1, 2010 

Equipment Type Type of 

Cooling

Harvest Rate

lb ice/24 hours

Maximum Energy 

Use

kWh/100 lb ice

Maximum Condenser Water 

Usea

gal/100 lb ice

Ice-Making Head Water

<500 7.80 - 0.0055Hb200 - 0.022H

≥500 and <1,436 5.58 - 0.0011H 200 - 0.022H

≥1,436 4.0 200 - 0.022H

Air <450 10.26 - 0.0086H Not Applicable

≥450 6.89 - 0.0011H Not Applicable

Remote Condensing 

(but not remote 

compressor)

Air <1,000 8.85 - 0.0038H Not Applicable

≥1,000 5.10 Not Applicable

Remote Condensing 

and Remote 

Compressor

Air <934 8.85 - 0.0038H Not Applicable

≥934 5.3 Not Applicable

Self-Contained

Water <200 11.40 - 0.019H 191 - 0.0315H

≥200 7.60 191 - 0.0315H

Air <175 18.0 - 0.069H Not Applicable

≥175 9.80 Not Applicable

a

 Water use is for the condenser only and does not include potable water used to make ice. 

b

 H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. 

Source: 42 U.S.C. 6313(d).
26

Item 3-17 DOE seeks feedback on the proposed baselines. 

4.0 SCREENING ANALYSIS 

The purpose of the screening analysis is to determine which technology options will be 

analyzed further in the engineering analysis. DOE will follow the process set forth below to 

screen out technology options. 

DOE will use the list of technology options (developed through its own research and in 

consultation with interested parties in the technology assessment) for consideration in the 

engineering analysis (section 5.0). DOE will review each technology option or best available 

technology in light of the following four criteria: 

1. Technological feasibility. DOE will screen out technologies that are not incorporated in 

commercially available products or working prototypes. 

2. Practicability to manufacture, install, and service. If DOE determines that mass 

production of a technology in commercial products and reliable installation and servicing 

of the technology could not be achieved on the scale necessary to serve the relevant 

market by the effective date of the standard, it will not consider that technology further. 

3. Adverse impacts on product or equipment utility or availability. If DOE determines a 

technology has significant adverse impact on the utility of the product for significant 

consumer subgroups, or would result in the unavailability of any covered product type 

with performance characteristics (including reliability), features, size, capacities, and 

volumes that are substantially the same as products generally available in the United 

States at the time, it will not consider that technology further. 

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider that technology 

further. 

DOE will fully document the rationale for eliminating any technology options during the 

screening analysis and will publish this documentation for interested parties to review as part of 

the preliminary analysis. Those technology options not screened out by the above four criteria 

will be considered design options in the development of cost-efficiency curves in the engineering 

analysis. 

Item 4-1 DOE welcomes comments on the above four screening criteria. 

5.0 ENGINEERING ANALYSIS 

After conducting the screening analysis, DOE performs an engineering analysis based on 

the remaining design options. The engineering analysis provides cost estimates of equipment at 

the performance levels considered in the rulemaking. Because DOE is considering establishing 

standards for both energy consumption and water consumption of automatic commercial icemakers, the engineering analysis will address the costs of reducing both. 
27

5.1 Engineering Analysis Overview 

The purpose of the engineering analysis is to determine the relationship between 

manufacturer selling price and energy and/or water consumption for automatic commercial 

ice-making equipment. In determining this relationship, DOE will estimate the increase in 

manufacturer selling price associated with design changes that decrease energy and water 

consumption as compared with baseline-efficiency models. DOE recognizes that some design 

options will reduce both energy and water consumption, but others may reduce one and increase 

the other. DOE will make simplifying assumptions as appropriate to reduce the potential 

complexity of analyses that would fully evaluate the trade-off in benefits associated with water 

conservation versus energy conservation. 

Item 5-1 DOE seeks comments from stakeholders providing insights regarding such 

trade-offs. 

DOE will develop cost estimates for the engineering analysis disaggregated into the cost 

contributions of materials (including purchased parts), labor, and overhead. This information will 

be used in all of the downstream analyses, including the MIA. DOE will create an industry-wide 

analysis based on a variety of data sources, including manufacturer-supplied data. 

As DOE has not yet finalized the expected product class structure, it has not yet 

developed specific requests for data to assist in collection of aggregated industry data. DOE 

hopes that industry stakeholders will be willing to participate in such an effort. DOE anticipates 

the data request will address such questions as costs to achieve reductions in energy and water 

use, shipments disaggregated by product classes or proposed new product classes, efficiency 

levels of current shipments, etc. 

In addition, DOE must identify the model with the lowest energy and/or water 

consumption that is technologically feasible within each equipment class (i.e., the “max-tech”

model). DOE recognizes that a max-tech model minimizing energy use may not minimize water 

use, and vice versa. 

Item 5-2 DOE requests comments on the best ways to collect such information from the 

industry. DOE anticipates that such data might be collected and aggregated by 

AHRI for submittal to DOE.

Item 5-3 DOE requests input on appropriate categories and questions to be included on 

such requests for data.

Item 5-4 DOE seeks comment on simplifying assumptions that may be made to reduce the 

potential complexity of maximizing benefits associated with both water and 

energy use reductions. 
28

Item 5-4A DOE seeks comments and recommendations regarding the potential data 

collection efforts that might be made by industry participants to support this 

rulemaking, and the possible structure of data request forms that could be used 

to assist such efforts. 

Item 5-5 DOE is also interested in receiving equipment test data (test procedure used, 

rating conditions, harvest rate, voltage, integrated average product temperature, 

daily energy consumption, etc.). Test data representative of the baseline model in 

each equipment class is particularly important. 

5.2 Proposed Approach for Determining the Cost-Efficiency Relationship 

DOE typically structures its engineering analysis using one of three approaches: 

(1) design-option, (2) efficiency-level, or (3) reverse-engineering (or cost-assessment). 

A design-option approach uses individual design options, or combinations of design 

options, to identify increases in efficiency. Under this approach, cost estimates are based on 

manufacturer or component supplier data or engineering computer simulation models. Individual 

design options, or combinations of design options, are added to the baseline model in ascending 

order of cost-effectiveness. Also, the efficiency levels addressed in the analyses, including the 

downstream analyses, are based on groups of design options. 

An efficiency-level approach establishes the relationship between manufacturer cost and 

increased efficiency at predetermined efficiency levels above the baseline. Under this approach, 

manufacturers typically provide manufacturer cost data for incremental increases in efficiency, 

without identifying the technology or design options they would use to achieve such increases. 

A reverse-engineering or cost-assessment approach involves purchasing representative 

units of automatic commercial ice-making equipment, disassembling the units, and reverseengineering the manufacturing costs based on a “bottoms-up” manufacturing cost assessment. 

The efficiency levels addressed in the analyses for such an analysis are based on the efficiency 

levels of the reverse-engineered products. 

DOE plans to use a combination of all three of these approaches to determine the costefficiency relationship. This approach will seek to obtain information from a variety of sources, 

including consultation with outside experts, review of publicly available cost and performance 

information, modeling of equipment cost and energy consumption, interviews with 

manufacturers, product teardowns and reverse engineering, and data submissions provided by the 

industry (discussed in section 5.1). DOE expects that efficiency levels addressed in the analyses 

will be associated, to the extent possible, with existing voluntary programs for efficiency 

improvement, such as ENERGY STAR or CEE, to simplify comparison of engineering analyses 

with reverse engineering and/or industry data submissions. 

For each equipment class, the engineering analysis will estimate manufacturer production 

cost (MPC) for each design option considered. DOE plans to use a cost model to estimate the 

cost of the condensing unit and ice-making section operating as an integrated unit. 
29

Item 5-6 DOE requests feedback on the use of a combined analysis approach that uses 

multiple information sources to determine the relationship between manufacturer 

selling price and energy consumption for automatic commercial ice-makers. 

5.3 Manufacturer Prices 

DOE plans to apply markups to convert MPC to manufacturer selling prices. DOE will 

evaluate a variety of sources to estimate manufacturer markups, including publicly available 

financial information (e.g., Securities and Exchange Commission 10-K reports), and interviews 

with manufacturers during the preliminary analysis phase. DOE recognizes that manufacturers of 

automatic commercial ice-making equipment may produce many types of equipment and that 

extracting the markup characteristics of automatic commercial ice-making equipment may not be 

feasible. 

Item 5-7 DOE seeks comment on which information sources may be the best for 

developing estimates of manufacturer selling prices. 

5.4 Proprietary Designs 

DOE notes that the four screening criteria mentioned in section 4.0 do not include 

proprietary status of designs. However, DOE will consider proprietary designs in the engineering 

analyses only if they are not part of a unique path to a given efficiency level. If the proprietary 

design is the only approach available to achieve a given efficiency level, then DOE will reject 

that efficiency level from further analysis. Further, DOE is sensitive to manufacturer concerns 

regarding proprietary designs and will maintain the confidentiality of any proprietary data 

submitted by manufacturers, consistent with applicable law. This information will provide input 

to the competitive impacts assessment and other economic analyses. 

Item 5-8 Are there proprietary designs that DOE should consider in the analyses for any 

of the equipment under consideration by this rulemaking? If so, how should DOE 

acquire the cost data necessary for evaluating these designs? Conversely, are 

there proprietary designs that should not be considered? Which products use 

these designs? 

5.5 Representative Sizes 

In performing the engineering analysis, DOE will select equipment models from the 

range of available equipment with sizes that best represent the most typical offerings within that 

specific equipment class. Proper selection of representative sizes will allow for the analyses to 

accurately model the majority of available equipment. DOE plans to select a model with 

representative size for each equipment class, while considering the possible design constraints at 

very small and very large capacities. Table 5.1 shows suggested representative sizes of cube icemakers to represent their product classes. 

The size of ice-maker refers to the harvest rate, or nominal capacity, designated as the 

weight of ice produced in a 24-hour period at an ambient exterior temperature of 90 degrees 
30

Fahrenheit (°F), inlet water temperature of 70 °F, and inlet water pressure of 30 ± 3 pounds per 

square inch gauge (psig).19

Table 5.1. Representative Cube Ice-Maker Sizes to Represent Product Classes 

Equipment Type Type of Cooling Capacity 

lbs/day

Cube Representative Capacity

Ice-Making Head

Water

<500 300

≥500 and <1,436 750

≥1,436 2,400

Air

<450 300

≥450 1,000

Remote Condensing 

(but not remote 

compressor) 

Air

<1,000 600

≥1,000

1,400

Remote Condensing 

and Remote 

Compressor

Air

<934 600

≥934

1,400

Self-Contained Unit

Water

<200 150

≥200 300

Air

<175 100

≥175 240

Item 5-9 DOE requests feedback on the suggested representative sizes for cube ice 

machines. Should multiple sizes be considered for any of the product classes? 

Item 5-10 Can any of the product groups (i.e., combination of equipment type and 

condenser cooling type) be represented by consideration of fewer representative 

products than the group’s number of product classes? 

Item 5-11 Can flake and nugget machines be represented by fewer representative products 

than cube machines? 

5.6 Extension of Standards 

For the engineering analysis, DOE will review the automatic commercial ice-making 

equipment available for the equipment classes. Generally each equipment type has multiple 

equipment classes, so DOE selects certain classes as representative and concentrates its 

analytical effort on these. DOE selects representative equipment classes primarily because of 

their high market volumes. For equipment classes that are secondary and are not analyzed, DOE 

extrapolates CSLs from representative equipment classes. 

 

19 AHRI 810-2007, Performance Rating of Automatic Commercial Ice-Makers. Air-Conditioning, Heating and 

Refrigeration Institute, Arlington, VA. 
31

Item 5-12 DOE welcomes comments on which product classes could be selected for 

focused analysis, and for which product classes the analyses could be 

extrapolated. 

5.7 Outside Regulatory Changes Affecting the Engineering Analysis 

In conducting an engineering analysis, DOE must consider the effects of regulatory 

changes outside DOE’s statutory energy conservation standards rulemaking process that can 

affect the energy efficiency or energy consumption of the covered equipment, the cost of 

improving such efficiency or consumption, or both. The current standards took effect coincident 

with the EPA-mandated phaseout of the hydrochlorofluorocarbon (HCFC) refrigerant HCFC-22 

for use in new equipment. DOE expects that all current products use HFC refrigerants such as R404A, R-507C, or HFC-134a, and the analysis will consider use of such refrigerants. DOE is 

aware of no other such regulations that significantly affect the cost to reduce energy or water use 

of automatic commercial ice-making equipment. The consideration of these issues is closely 

related to the cumulative regulatory burden assessment that DOE will carry out as part of the 

MIA. Based on consideration of the comments received for the preliminary analysis, DOE will 

make the necessary changes to the analysis. These changes will be reflected in the 

documentation of the NOPR. 

Item 5-13 Are there outside regulatory issues that DOE should consider in its engineering 

analysis of commercial automatic ice-makers? 

6.0 ENERGY AND WATER USE AND END-USE LOAD CHARACTERIZATION 

The purpose of the energy and water use and end-use load characterization analysis is to 

assess the energy and water savings potential of different equipment efficiencies. As part of the 

energy use analysis, DOE must make certain engineering assumptions regarding equipment 

application, including how and under what conditions the equipment is operated. 

Many automatic commercial ice-maker machines are located inside conditioned spaces, 

and multiple machines may be installed in an individual building (e.g., in health care, lodging, 

and large retail or office buildings). DOE recognizes that automatic commercial ice-maker 

machines will add to the cooling loads and reduce heating loads, but these impacts are believed 

to be modest. Furthermore, DOE believes the added complexity of determining the overall 

impact to the building space-conditioning loads is not warranted, particularly given the variety of 

building types and of the ice machine locations (e.g., outside, inside, or in vestibules) that would 

need to be taken into account. 

Item 6-1 DOE seeks data or data sources that could be used to characterize the energy 

use of automatic commercial ice-making equipment. 

Item 6-2 DOE seeks feedback on the assumption that commercial ice-making machine 

operation has a negligible impact on the building space-conditioning loads. 
32

7.0 MARKUPS FOR EQUIPMENT PRICE DETERMINATION 

DOE uses manufacturer-to-consumer markups to convert the manufacturer-selling-price 

estimates from the engineering analysis to consumer prices, which are then used in the LCC and 

PBP analyses and the MIA. Retail prices are needed for the baseline efficiency level and all other 

efficiency levels under consideration. DOE will obtain these retail prices by applying 

manufacturer-to-consumer markups (consisting of shipping and transportation charges, 

distribution channel markups, and sales tax) to the manufacturer-selling-price estimates. 

To develop markups, DOE must identify distribution channels (i.e., how the equipment is 

distributed from the manufacturer to the consumer). Once it establishes proper distribution 

channels for each equipment class, DOE will rely on economic census data from the U.S. Census 

Bureau and input from the industry to define how equipment is marked up from the manufacturer 

to the consumer. To the extent possible, DOE also will use collected retail price data to help 

qualify overall manufacturer-to-consumer markups. 

This analysis will generate retail prices for each efficiency level that DOE considers. 

Because it expects to generate a range of price estimates, DOE plans to describe new retail prices 

within a range of uncertainty. If the range of retail prices for the equipment is large enough, DOE 

will conduct a sensitivity analysis to determine how high or low estimates of retail price impact 

the economic feasibility of potential energy conservation standard levels. 

In the past, DOE developed estimates of manufacturer-to-consumer markups for related 

types of commercial refrigeration equipment. DOE’s analysis focused on three distribution chain 

paths and calculated markups for individual points along these paths. Two of these paths involved 

selling the equipment through a distributor. One distributor path then went directly to customers 

while the second path included general contractors, mechanical contractors, or both, who installed 

the equipment for the final customer. A third ―national account‖ path involved the manufacturer 

selling the equipment directly to the end customer. 

DOE’s preliminary research indicates the automatic commercial ice-maker market appears to 

be similar. For food service equipment, including automatic commercial ice-making equipment, 

manufacturers sell either to dealers or directly to the customer. Some equipment, notably the remote 

condensing equipment, requires the assistance of a mechanical contractor for installation, and the 

dealer or manufacturer frequently either provides the contractor or helps the customer secure 

contractor services. 

For this rulemaking, DOE’s research suggests a set of distribution channels described as 

follows: 

Manufacturer Whole Distributors/Dealers Mechanical Contractor Customer (“Contractor” Channel) 

Manufacturer Whole Distributors/Dealers Customer (“Distributor” Channel) 

Manufacturer Customer (“National Account” Channel) 

For the equipment covered by this rulemaking, DOE plans to use a sales distribution 

among the three channels following the percentages shown in Table 7.1. The overall percentages 
33

for equipment covered by this current rulemaking will depend on the proportion of selfcontained unit shipments relative to the proportion of remote condensing unit shipments. 

Table 7.1. Proposed Percentage Distribution of Shipments of Automatic Commercial 

Ice-Making Equipment, by Market Channel 

Remote Condensing Equipment

%

New and Replacement Construction National Account Distributor Contractor

70 15 15

Self-Contained Equipment

%

New and Replacement Construction National Account Distributor Contractor

30 35 35

DOE’s understanding is that a general contractor would not normally enter into the 

distribution path for this equipment. DOE also understands that the relative fractions of 

equipment distributed in each channel could be different depending on whether the equipment is 

self-contained or remote condensing, as indicated by Table 7.1, and on whether the equipment is 

sold to a food sales establishment or a food service establishment. 

Item 7-1 DOE requests information on the proposed distribution channels for the 

commercial ice-making equipment covered under this rulemaking. 

Item 7-2 DOE requests information on whether the distribution channels differ by the 

types of buildings that comprise the market for automatic commercial icemakers, namely, food sales establishments, food service establishments, health 

care facilities, lodging facilities, and others. 

DOE intends to develop both markups for baseline equipment and incremental markups 

that are applied only to the incremental cost of higher-efficiency equipment. To develop 

markups, DOE must compile financial information for entities engaged in food service 

equipment distribution and for mechanical contractors in order to identify direct costs, indirect or 

overhead costs, and profits. DOE seeks input on data sources specific to food service equipment 

distribution channels. For similar rulemakings related to commercial refrigeration, DOE 

calculated markups from distribution chain data supplied by an association of heating, airconditioning, and refrigeration dealers. For this rulemaking, DOE will identify and use data 

specific to foodservice equipment dealers supplemented with U.S. Census of Business data. State 

and local tax data will come from the Sales Tax Clearinghouse. Shipping costs will be 

considered as part of the markup analyses, as appropriate. 

Item 7-3 DOE requests feedback on its proposal to use incremental distribution channel 

markups for the LCC analysis. 

Item 7-4 DOE seeks comment on sources of food service equipment distribution chain 

data that could be used to characterize markups for the food service equipment 

industry.
34

Item 7-5 DOE seeks comment on appropriate transportation and shipping costs to include 

in the analysis and whether those costs are likely to vary for higher efficiency 

equipment. 

8.0 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

The effects of amended energy conservation standards on consumers include a change in 

operating expense (usually decreased) and a change in purchase price (usually increased). The 

LCC of a piece of equipment is the cost it incurs over its lifetime, taking into account both 

purchase price and operating expenses. The PBP represents the time it takes to recover the 

additional installed cost of the more-efficient device through annual operating cost savings. DOE 

analyzes the net effect of new or amended standards on individual consumers by calculating the 

LCC and PBP using the engineering performance data (section 5.0), the energy-use and end-use 

load characterization data (section 6.0), and the markups for equipment price determination 

(section 7.0). Inputs to the LCC calculation include the installed cost to the consumer (purchase 

price, including transportation and markups, plus installation cost), operating expenses (energy 

expenses, repair costs, and maintenance costs), the lifetime of the equipment or other defined 

period of analysis, and a discount rate appropriate for the consumer of the equipment. Inputs to 

the PBP calculation include the installed cost to the consumer and annual operating costs. 

In addition to the LCC and PBP calculations, DOE also conducts a rebuttable 

presumption analysis for certain equipment. 42 U.S.C. 6295(o)(2)(B)(iii) and 6313(d) establishes 

a rebuttable presumption that a standard for commercial ice-making equipment is economically 

justified ―[i]f the Secretary finds that the additional cost to the consumer of purchasing a product 

complying with an energy conservation standard level will be less than three times the value of 

the energy ... savings during the first year that the consumer will receive as a result of the 

standard, as calculated under the applicable test procedure.‖

While the rebuttable presumption calculation is helpful for understanding that certain 

standard levels have short PBPs, DOE routinely conducts a full economic analysis that considers 

the full range of impacts, including those to the consumer, manufacturer, Nation, and 

environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as 

the basis for DOE to definitively evaluate the economic justification for a potential standard level 

(thereby supporting or rebutting the results of any preliminary determination of economic 

justification). 

For the preliminary analysis, DOE will conduct the LCC and PBP analyses using typical 

values for the following to reflect actual conditions for the purchase and use of the equipment: 

retail price, installation costs, lifetime, energy usage and cost, water usage, water and wastewater 

cost, repair and maintenance costs, and discount rates. If DOE determines that there is significant 

variability in any of these inputs, it will conduct uncertainty analyses (e.g., Monte Carlo analysis) 

to determine how the statistical distribution of estimates for each input affects the LCC and PBP. 

The detailed impact calculation, which DOE will conduct after the preliminary analysis, will 

include an assessment of LCC and PBP impacts on consumer subgroups, as described in section 

11.0. For the NOPR, DOE will augment the analysis with inputs received from interested parties. 
35

The following sections discuss the methodologies DOE plans to use to develop 

(1) energy, water and wastewater prices, (2) discount rates, (3) maintenance, repair, and 

installation costs, and (4) lifetimes for commercial ice-making equipment. Table 8.1 lists some of 

the major inputs DOE anticipates it will develop for the LCC and PBP analyses. 

Table 8.1. Inputs to the Life-Cycle Cost and Payback Period Analyses

Input Type Description

Equipment Price DOE will establish the price of commercial ice-making equipment, including 

transportation charges, based on manufacturer’s sales prices developed in the 

engineering analysis and the markups established in section 7.0, Markups for 

Equipment Price Determination. 

Sales Tax Sales tax is applied to convert the product price to a final consumer price. DOE 

will develop sales tax markups as described in section 7.0, Markups for 

Equipment Price Determination. 

Installation, Maintenance, and 

Repair Costs 

These inputs represent the cost to consumers of installing and maintaining 

commercial ice-making equipment. 

Annual Operating Hours The annual operating hours are the estimated hours that commercial ice-making

equipment is in use over a full year. DOE will develop operating hours as 

described in section 6.0, Energy and Water Use and End-Use Load 

Characterization. 

Product Energy Consumption 

Rate 

The product energy consumption rate is the site-energy usage rate associated with 

operating the commercial ice-making equipment. DOE will develop this rate as 

described in section 6.0, Energy and Water Use and End-Use Load 

Characterization. 

Electricity Prices Electricity prices used in the analysis are the average price per kilowatt-hour 

($/kWh) that consumers pay in each state for each type of business (e.g., grocery, 

convenience store, restaurant) that uses the equipment. 

Electricity Price Trends Electricity price trends estimate the future cost of electricity. 

Lifetime Lifetime is the number of years a commercial ice-making piece of equipment is 

in operation before the consumer retires the case from service. 

Product Water Consumption 

Rate

The product water consumption rate is the site-water usage rate associated with 

operating the commercial ice-making equipment. DOE will develop this rate as 

described in section 6.0, Energy and Water Use and End-Use Load 

Characterization. 

Water / Wastewater Prices Water and wastewater prices used in the analysis are the average price per 1,000 

gallons ($/1,000 gal) that consumers pay in each state for each type of business 

(e.g., grocery, convenience store, restaurant) that uses the equipment. 

Water / Wastewater Price 

Trends

Water / wastewater price trends estimate the future cost of water and wastewater. 

Discount Rate The discount rate is the consumer rate at which DOE discounts future 

expenditures to establish their present value. 

Analysis Period The analysis period is the time span over which DOE calculates the LCC. 

8.1 Energy Prices 

DOE will survey average state-level electricity prices for consumers of automatic 

commercial ice-making equipment. Average prices will be used because automatic commercial 

ice-making equipment runs nearly continuously and the cost of operation is effectively captured 

using average electricity prices. DOE will conduct a sensitivity analysis to determine how high 

and low electricity price estimates might affect the economic feasibility of any amended energy 

conservation standards. DOE will use projections of national and regional average energy 
36

prices—principally from the most recent Energy Information Administration (EIA) Annual 

Energy Outlook (AEO)

20—as inputs for future energy prices in the LCC analysis. 

Item 8-1 DOE seeks comment on the proposed approaches for estimating current and 

forecasted energy prices. 

8.2 Life-Cycle Cost Discount Rates 

Calculation of consumer LCC requires use of an appropriate discount rate. DOE uses the 

discount rate to determine the present value of lifetime operating expenses. Because consumers 

of automatic commercial ice-making equipment are typically commercial entities, DOE will 

derive the discount rates for consumers by estimating the cost of capital of these types of 

companies. The cost of capital is commonly used to estimate the present value of cash flows to 

be derived from a typical company project or investment. Most companies use both debt and 

equity capital to fund investments, so the cost of capital is the weighted-average cost of equity 

and debt financing. This corporate finance approach is referred to as the weighted-average cost 

of capital (WACC). DOE will calculate WACC from equity and debt cost data on individual 

Value Line reported companies from the Damodaran Online website.21

Because the set of commercial companies purchasing automatic commercial ice-making 

equipment may differ from those who purchase other types of commercial equipment, each 

rulemaking requires development of its own targeted discount rates. DOE will develop the 

discount rates and associated calculations and provide an opportunity for interested parties to

comment on this issue during the preliminary analysis comment period. DOE will make 

necessary changes to the preliminary analysis based on the comments it receives on the LCC and 

PBP analyses, and will reflect those changes in the NOPR. 

Item 8-2 DOE seeks comment on the proposed approaches for estimating discount rates 

for consumers of the equipment covered under this rulemaking. 

8.3 Maintenance, Repair, and Installation Costs 

DOE will consider expected changes to maintenance, repair, and installation costs for the 

equipment covered in this rulemaking. DOE bases repair costs on annualized costs of key 

components and frequency of replacement in the field. Maintenance costs will be based on 

estimates of preventative maintenance and a separate estimate of maintenance for different icemaking technologies. DOE will project annualized maintenance costs for automatic commercial 

ice-making equipment from data developed in the engineering studies and using engineering cost 

index services such as RS Means. 

Preventative maintenance costs related to water handling and scaling are important for 

automatic commercial ice-makers. At present no information is available to indicate how 

preventative maintenance costs vary with equipment efficiency level. 

 

20 See www.eia.doe.gov/oiaf/aeo/. 

21 See http://pages.stern.nyu.edu/~adamodar/. 
37

As a default, DOE proposes to assume preventative maintenance costs will remain 

constant as equipment efficiency is increased. DOE will rely on input from manufacturers and 

other stakeholders in determining if the default assumption is appropriate, and if it is found to not 

be appropriate, in developing appropriate incremental repair and maintenance costs for higher 

efficiency equipment. 

Unless the efficiency increases considered for this rulemaking result in significantly 

larger or heavier equipment, DOE expects that more efficient automatic commercial ice-making 

equipment will not incur increased installation costs. 

Item 8-3 DOE seeks answers to the question: What are the typical installation, 

maintenance, and repair costs and practices during the life cycle of an originally 

manufactured automatic commercial ice-making machine? 

Item 8-4 What is a typical time period between the sale of a new product and the first 

maintenance or repairs? What are the typical cycles of maintenance and 

repairs? 

Item 8-5 DOE seeks feedback on whether and how routine maintenance, repair, and 

installation costs will change for products that are more energy and water 

efficient. 

Item 8-6 If it is not appropriate to assume that changes in maintenance, repair, or 

installation costs would be negligible for more-efficient products, DOE seeks 

feedback on appropriate methodologies for assessing changes to each of these 

costs. 

8.4 Equipment Lifetimes 

Current research shows automatic commercial ice-maker machine life typically ranges 

from 7 to 10 years, with an average of 8.5 years.22,23

As appropriate, DOE will use information from additional various literature sources (e.g., 

Appliance Magazine, handbooks published by ASHRAE) and input from manufacturers and 

other interested parties to better establish average equipment lifetimes for use in the LCC and 

subsequent analyses. 

Item 8-7 DOE seeks comment on appropriate equipment lifetimes for the classes of 

equipment covered in this rulemaking. 

 

22 Navigant 2009. 

23 Koeller 2008. 
38

8.5 Water and Wastewater Costs 

Water is used in the manufacture of ice and in the cooling process. Total water usage 

ranges from 13 gallons/100 lb of ice for air-cooled flake ice-makers up to 200 gallons or more 

for cube ice-makers with water cooling. Water not embodied in the finished product is water that 

ultimately is sent into the wastewater system. Thus, water and wastewater costs represent 

important cost components, and in the case of water-cooled systems, significant cost components 

in the LCC analysis. 

DOE proposes to develop nationwide estimates of water and wastewater costs and 

incorporate these estimates into the annual operating cost, LCC, and PBP analyses. DOE 

proposes to rely upon sources such as the American Water Works Association’s (AWWA’s) 

biennial price survey and other surveys of retail water purveyors to establish base year prices. 

AWWA has performed the biennial survey for many years, and DOE anticipates using data from 

multiple years’ surveys to establish trends for purposes of developing water price forecasts. Base 

year prices will be combined with price growth rates developed from AWWA surveys, and as 

needed, supplemented with information from commercial macroeconomic forecast services or 

other sources to develop projections of water and wastewater commodity prices. 

Once estimated, price projections will be combined with commodity consumption rate, 

consistent with section 6.0 of this framework document, and the resulting cost streams will be 

included in LCC and PBP analyses. 

Item 8-8 DOE seeks input on the proposed methodology for developing estimates of 

national water costs and potential savings associated with the proposed rule. 

9.0 SHIPMENTS ANALYSIS 

Shipment forecasts are required to calculate the national impacts of standards on energy 

use, NPV, and future manufacturer cash flows. DOE plans to develop shipment forecasts based 

on an analysis of key market drivers for automatic commercial ice-making equipment. 

9.1 Base Case Forecast 

To evaluate the various impacts of standards, DOE must develop a base case forecast 

against which to compare forecasts for higher efficiency levels. The base case forecast is 

designed to depict what will happen to energy consumption and energy costs over time if DOE 

does not adopt amended energy conservation standards for the equipment covered under this 

rulemaking. In determining the base case forecast, DOE will consider historical shipments, the 

mix of efficiencies sold under current standards, and how that mix might change over time. For 

these purposes, DOE needs data on historical shipments and the market shares of the different 

efficiency levels offered in each equipment class. 

DOE’s Buildings Energy Data Book publishes shipment data on ice-making machines as 

a total product group.24 In addition, the Census Bureau has published limited statistics on the 

 

24 See http://buildingsdatabook.eere.energy.gov/. 
39

quantity and value of product shipments.25 Census Bureau data is available online, divided into 

categories based on whether the machine is self-contained, the type of ice produced, the capacity 

of the machine, and if the machine also dispenses beverages. The data is collected every year, 

but is missing some categories because of issues with proprietary information or data that did not 

meet publication standards. EPA also collects shipments data through their ENERGY STAR 

program. 

Between 1990 and 2000, annual ice machine sales more than doubled, from 171,000 units 

to 385,000 units per year. However, between 2000 and 2006, which are the most recent years 

available through DOE’s EERE Buildings Energy Data Book, ice machine sales have shown a 

decreased rate of growth, increasing from 385,000 units to only 386,000 units per year. In 2006,

197,000 units of the total ice-maker shipments were commercial machines. 

DOE intends to collect shipment data within each equipment class, as well as marketshare efficiency data (i.e., data on the distribution of product shipments by efficiency) for each 

class. DOE recognizes that this information may be difficult to collect, and may therefore 

consider other methods to estimate the efficiency distribution in the market. For example, when 

market-share efficiency data are not available, DOE may use efficiency distributions based on 

available equipment models as a proxy. DOE may also request separate shipment information for 

equipment sold with specific design features. 

9.2 Accounting Methodology 

DOE proposes to determine annual shipments in the base case by accounting for new 

building construction and historical rates of ownership (saturation rates) in buildings. For 

equipment retirements, DOE will use the same equipment lifetimes and retirement functions that 

it generates for the LCC and PBP analysis. This method has the distinct advantage of separately 

accounting for units installed in new construction and existing buildings. More importantly, DOE 

can express saturation rates as a function of consumer price and operating cost to capture their 

impact on future shipments. DOE plans to rely on EIA’s AEO to forecast new commercial 

construction. 

DOE will also consider any other input provided by interested parties. 

Item 9-1 DOE seeks information on historical shipments of automatic commercial icemaking equipment for each equipment class covered under this rulemaking, as 

well as industry-trend data regarding relative growth in each equipment class. 

Item 9-2 DOE seeks information on representative saturation rates for each equipment 

class covered under this rulemaking, as well as industry-trend data regarding 

relative growth in each equipment class. 

 

25 See www.census.gov. 
40

9.3 Standards Impacts on Shipments 

For each equipment class, DOE will develop a set of shipment forecasts for the covered 

equipment for each set of potential standards analyzed. DOE will use these standards case 

forecasts to evaluate the impacts of standards on shipments. Standards case forecasts are derived 

using the same datasets as base case forecasts; however, because the standards case forecasts 

take into account the increase in purchase price and the decrease in operating costs caused by 

new or amended standards, forecasted shipments could deviate from the base case. The 

magnitude of the difference between the standards case and base case shipment forecasts 

depends on the estimated purchase-price-increase as well as the operating-cost-savings caused by 

the standard. Because the purchase price tends to have a larger impact than operating cost on 

equipment purchase decisions, standards case forecasts typically show a drop in shipments 

relative to the base case. 

DOE’s past standards analyses have attempted to quantify the sensitivity of shipments to 

purchase price and operating-cost-savings. Because the data required to develop these 

sensitivities are limited and often difficult to obtain, DOE will consider modeling standards case 

shipments forecasts with scenarios (i.e., specified impacts to equipment shipments) rather than 

developing sensitivities to purchase price or operating-cost-savings. 

Market-pull programs, such as consumer rebate programs that encourage the purchase of 

more-efficient equipment and manufacturer tax credits that encourage the production of moreefficient equipment, also affect standards case forecasts. When such programs exist, DOE 

considers their impact on the forecast of both standards case and base case shipments. 

Item 9-3 DOE requests input from manufacturers on the potential impact of new energy 

conservation standards on equipment shipments. Other interested parties are 

also welcome to provide input. DOE also requests input on any market-pull 

programs that currently exist to promote the adoption of more-efficient 

equipment. 

10.0 NATIONAL IMPACT ANALYSIS 

The national impact analysis (NIA) will discuss DOE’s assessment of the aggregate 

impacts of potential efficiency standards at the national level. Measures of impact that DOE will 

report include future NES from CSLs (i.e., the cumulative incremental primary energy savings 

from an increased energy conservation standard relative to a base case that assumes no change in 

the energy conservation national standard over a specific forecast period). DOE will also report 

the impact on the NPV for consumers in the aggregate from CSLs (i.e., the cumulative 

incremental LCC from an increased energy conservation standard relative to the base case over a 

specific forecast period). 

10.1 Inputs to Forecast 

Analyzing impacts of Federal energy conservation standards requires a comparison of 

projected U.S. energy consumption for the automatic commercial ice-making equipment covered 

under this rulemaking with, and without, new or amended energy conservation standards. The 
41

forecasts contain projections of unit energy consumption for new equipment, annual equipment 

shipments, and the price of purchased equipment. Analysis of water savings is done in the same 

manner. The derivations of the base case shipments forecasts are discussed in section 9.1. 

Approaches to determining retail prices are described in section 7.0, while approaches to 

determining per unit net energy consumption impact are described in section 6.0.

One factor often considered in DOE rulemakings is the rebound effect. The rebound 

effect is generally included in the input to the NIA. Often, consumers that encounter lower 

operating costs associated with more energy-efficient equipment will use that equipment more 

often than would have used the less-efficient equipment. The rebound effect analysis accounts 

for this increase in consumer use. DOE assumes that there is essentially no rebound effect for 

automatic commercial ice-making equipment because the equipment is presumed to run nearly 

continuously, and its operating settings are based on the amount of ice to be produced. 

Item 10-1 DOE requests information on whether a rebound effect exists and should be 

incorporated in the NIA. 

Table 10.1 describes some of the major inputs DOE anticipates it will develop for the 

NIA. 

Table 10.1. Inputs to the National Impact Analysis 

Input Data Description of Data Sources

Shipments DOE develops estimates of annual shipments over a 30-year analysis 

period as described in section 9.0, Shipment Analysis. 

Stock of Commercial Ice-Makers This stock is calculated from the service life of equipment developed as 

described in section 8.0, Life-Cycle Cost and Payback Period Analysis, and 

annual shipments of equipment developed as described in section 9.0, 

Shipment Analysis. 

Compliance Date of Standard The compliance date of the standard is January 1, 2016

Analysis Period This analysis period is 2015 to 2046 (30 years).

Base-Case Forecasted Efficiency Distribution of base-case shipments by efficiency level over time 

developed as described in section 9.0, Shipment Analysis. 

Standards-Case Forecasted 

Efficiency 

Distribution of shipments by efficiency level for each standards case over 

time as described in section 9.0, Shipment Analysis. 

Unit Energy and Water 

Consumption (kWh/yr) and (1,000 

gallons/yr)

This is the average energy and water consumption of automatic 

commercial ice-making equipment established as described in section 6.0, 

Energy and Water Use and End-Use Load Characterization. 

Total Installed Cost Established as described in section 7.0, Markups for Equipment Price 

Determination, and section 8.0, Life-Cycle Cost and Payback Period 

Analysis. 

Electricity and Water Price 

Forecasts

Established as described in section 8.0, Life-Cycle Cost and Payback 

Period Analysis. 

Electricity Site-to-Source 

Conversion 

Conversion varies yearly and is generated from detailed NEMS forecasts of 

electricity generation by technology and electricity-related losses. 

Discount Rate The discount rate is the rate at which DOE discounts future expenditures to 

establish their present value. DOE will use 3- and 7-percent discount rates 

mandated by the Office of Management and Budget (OMB). 

Present Year Future costs and savings will be discounted to 2011. 

Rebound Effect The difference between the projected and actual savings due to increased 

efficiency. DOE may base this effect on economics literature on energy 

efficiency in the commercial and industrial sectors. 
42

10.2 Calculation of Energy and Water Savings 

DOE intends to calculate national energy and water consumption for each year, 

beginning with the expected compliance date of the standards. It will calculate national energy 

consumption by fuel type for the base case and each standard level analyzed. DOE plans to 

perform this calculation through the use of a spreadsheet model that effectively multiplies annual 

equipment stock forecasts by efficiency level (based on shipments and retirements in each year) 

by unit electricity use at the site of use, for each efficiency level. DOE then plans to multiply the 

site electricity use by year-by-year marginal site-to-source conversion factors that account for 

energy losses in generation, transmission, and distribution of electricity in order to estimate 

national primary energy savings. DOE proposes to base the site-to-source conversion factors on 

modeled savings of primary energy in the electric utility industry of EIA’s National Energy 

Modeling System (NEMS) (section 13.0). 

National Water Savings (NWS) will be estimated in much the same fashion. Because the 

nation’s water systems are not integrated (like the power grid), site-to-source conversion factors 

will require the compilation of loss factors at the various levels of the water system (distribution, 

transmission, and source). 

In response to comments by interested parties who asked for a simple, transparent model, 

DOE developed NIA spreadsheet models for its standards rulemakings starting in 1996. These 

models project energy and water savings and demonstrate how to account for the growth in 

efficiency over time.26 DOE expects the NIA spreadsheet model to provide a credible, standalone 

forecast of NES, NWS, and aggregate consumer NPV for automatic commercial ice-making 

equipment. DOE will make any necessary changes to the preliminary analysis based on the 

comments it receives. DOE will reflect those changes in the NOPR. 

Item 10-2 DOE welcomes comments from interested parties on the use of NIA spreadsheet 

models for estimating national impacts of amended energy and water 

conservation standards for automatic commercial ice-making equipment. 

10.3 Net Present Value of Consumer Savings 

DOE calculates the national NPV of the standards in conjunction with the NES and 

NWS. It calculates annual energy and water expenditures from annual energy and water 

consumption by incorporating forecasted prices, using the shipment forecasts described in 

section 9.1, Base Case Forecast, and electricity and water savings forecasts described in section 

10.2. DOE calculates annual equipment expenditures by multiplying the price per unit by the 

forecasted shipments. The difference between a base case and a standards case scenario gives the 

national energy and water bill savings and increased equipment expenditures in dollars. The 

difference each year between energy and water bill savings and increased equipment 

expenditures is the net savings (if positive) or net cost (if negative). DOE discounts these annual 

values to the present time and sums them to give an NPV. Since the national cost of capital may 

differ from the consumer cost of capital, the discount rate used in the NIA can be different from 

 

26 Several examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at 

www.eere.energy.gov/buildings/appliance_standards. 
43

the rate used in the LCC. In accordance with OMB guidance, DOE will conduct two NPV 

calculations, one using a real discount rate of 3 percent and another using a real discount rate of 

7 percent.27

Based on consideration of the comments received for the preliminary analysis, DOE will 

make any necessary changes to the analysis and the CSLs. 

11.0 LIFE-CYCLE COST SUBGROUP ANALYSIS 

DOE recognizes that there are potential subgroups of commercial consumers or 

purchasers of automatic commercial ice-making equipment who may be impacted by standards 

differently than consumers or purchasers generally. DOE analyzes such differences in impacts by 

dividing consumers into subgroups and accounting for variations in key inputs to the LCC 

analysis. A customer subgroup comprises a subset of the purchaser population likely to be 

impacted disproportionately by new or revised energy conservation standards. The purpose of a 

subgroup analysis is to determine the extent of this disproportionate impact. DOE will work with 

interested parties early in the rulemaking process to identify any subgroups for this consideration 

and will analyze the consumer subgroups in the NOPR stage of the analysis. 

In comparing potential impacts on the different consumer subgroups, DOE will evaluate 

variations in regional energy and water and wastewater prices, variations in energy and water 

use, and variations in installation costs that might affect the NPV of a standard to consumer 

subgroups. To the extent possible, DOE may obtain estimates of the variability in each input 

variable and consider this variability in its calculation of consumer impacts. It will discuss the 

variability in each input variable and likely sources of information with interested parties. 

Item 11-1 DOE seeks input as to which customer subgroups DOE should consider in the 

present rulemaking. Examples of possible subgroups DOE could consider 

appropriate for automatic commercial ice-making equipment include small 

independent grocery and convenience stores and independently owned 

restaurant and motels. 

12.0 MANUFACTURER IMPACT ANALYSIS 

DOE will collect, evaluate, and report preliminary manufacturer impact information and 

data in the preliminary analysis.28 Such preliminary manufacturer impact information includes 

the anticipated capital conversion costs by efficiency level and the corresponding, anticipated 

impacts on jobs. DOE will solicit this information during the engineering analysis manufacturer 

interviews for the preliminary analysis. 

 

27 OMB, Circular A-4: Regulatory Analysis (Sept.17, 2003). 

28 See U.S. Department of Energy. Congressional Report: Energy Conservation Standards Activities. 2006. p. 48. 

Available online at:

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/congressional_report_013106.pdf (providing 

rationale for conducting an MIA early in the process of rulemaking).
44

The analysis of impacts on manufacturers is intended to provide DOE with an assessment 

of the potential impacts of energy conservation standards on manufacturers. In addition to 

financial impacts, a wide range of quantitative and qualitative effects may occur following 

adoption of a standard that may require changes to the manufacturing practices for this 

equipment. DOE will identify these effects through interviews with manufacturers and other 

interested parties. 

12.1 Sources of Information 

Many of the analyses described earlier provide important information that DOE uses as 

inputs for the MIA. Such information includes financial parameters developed in the market 

assessment (section 3.1), manufacturing costs and prices from the engineering analysis (sections 

5.2 and 5.3), retail price forecasts (section 7.0), and shipments forecasts (section 9.1). DOE 

supplements this information with information gathered during manufacturer interviews. The 

interview process will play a key role in the MIA, as it provides an opportunity for interested 

parties to express their views on important issues. 

DOE will conduct detailed interviews with manufacturers to gain insight into the range of 

potential impacts of standards. During the interviews, DOE will solicit information on the 

possible impacts of standards on manufacturing costs, equipment prices, sales, direct 

employment, capital assets, and industry competitiveness. Both qualitative and quantitative 

information are valuable. In addition, an interview guide will be provided before the interviews 

to allow the manufacturers to gather the appropriate information. Although a written response to 

the questionnaire is acceptable, DOE prefers an interactive interview process because it helps 

clarify responses and provides the opportunity for additional issues to be identified. 

DOE will ask that interview participants identify all confidential information provided, 

both in writing and orally. While it will consider information gathered, as appropriate, in its 

decision-making process, DOE will protect confidential information from disclosure consistent 

with applicable law. 

DOE will collate the information from interviews and prepare a summary of the major 

issues and outcomes. This summary will become part of the TSD produced for this rulemaking. 

12.2 Industry Cash Flow Analysis 

The industry cash flow analysis relies primarily on the Government Regulatory Impact 

Model (GRIM). DOE uses the GRIM to analyze the financial impacts of more stringent energy 

conservation standards on the industry that produces the equipment covered by the standard. 

The GRIM analysis uses a number of factors—annual expected revenues; manufacturer 

costs such as costs of goods sold; selling, general, and administrative (SG&A) costs; taxes; and 

capital expenditures—to arrive at a series of annual cash flows beginning from the 

announcement of the new standard and continuing for several years after its implementation. 

DOE compares the results against base case projections that involve no new standards. The 

financial impact of new standards is the difference between the two sets of discounted annual 
45

cash flows. Other performance metrics, such as return on invested capital, also are available from 

the GRIM. 

DOE will gather this information from two primary sources: (1) the analyses conducted 

to this point; and (2) interviews with manufacturers and other interested parties. Information 

gathered from previous analyses will include financial parameters, manufacturing costs, price 

forecasts, and shipment forecasts. Interviews with manufacturers and other interested parties will 

be essential for supplementing this information. 

12.3 Manufacturer Subgroup Analysis 

It is possible that the use of average industry cost values will not adequately assess 

differential impacts among subgroups of manufacturers. DOE recognizes that smaller 

manufacturers, niche players, and manufacturers exhibiting a cost structure that differs largely 

from the industry average may be differentially impacted by the imposition of standards. Ideally, 

DOE would consider the impact on every firm individually. In highly concentrated industries, 

this may be possible. In industries having numerous participants, however, DOE will use the 

results of the market and technology assessment to group manufacturers into subgroups, as 

appropriate. 

Item 12-1 DOE seeks comment on the establishment of manufacturer subgroups for 

automatic commercial ice-making equipment, particularly small businesses and 

niche manufacturers. 

12.4 Competitive Impacts Assessment 

EPCA directs DOE to consider any lessening of competition that is likely to result from 

the imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V) and 6313(d)) It further directs the 

Attorney General to determine, in writing, the impacts, if any, of any lessening of competition. 

(42 U.S.C. 6295(o)(2)(B)(ii) and 6313(d)) 

DOE will make a determined effort to gather firm-specific financial information and 

impacts. DOE will then report the aggregated impact of the standard on manufacturers. The 

competitive impacts assessment will include a focus on the assessment of the impacts to smaller 

manufacturers. DOE will provide the Attorney General with a copy of the NOPR for 

consideration in the Attorney General’s evaluation of the impact, if any, of standards on any 

lessening of competition. DOE will base the assessment on manufacturing cost data and on 

information collected from interviews with manufacturers. One focus of the manufacturer 

interviews will be to gather information that would help in assessing asymmetrical cost increases 

to some manufacturers, whether an increased proportion of fixed costs could potentially increase 

business risks, and potential barriers to market entry (e.g., proprietary technologies). 

12.5 Cumulative Regulatory Burden 

Finally, DOE is aware that other regulations may be placed on equipment covered under 

this rulemaking as well as on other equipment manufactured by the same companies. Multiple 

regulations may result in a cumulative regulatory burden on these manufacturers. DOE will 
46

address and seek to mitigate the overlapping effects on manufacturers of amended DOE 

standards and other regulatory actions affecting the same equipment or companies. In this regard, 

DOE considers the impact of other rules with compliance dates within 3 years of the compliance 

date for this rulemaking. 

Item 12-2 What regulations or pending regulations should DOE consider in the analysis of 

cumulative regulatory burden? 

13.0 UTILITY IMPACT ANALYSIS 

The utility impact analysis will include an analysis of the electric utility industry. DOE is 

considering adapting the National Energy Modeling System produced by the EIA for this 

analysis. NEMS is a large, multi-sectoral, partial-equilibrium model of the U.S. energy sector 

that has been developed over the past decade by the EIA, primarily to prepare DOE’s AEO. In 

prior rulemakings, a variant of NEMS (currently termed NEMS-BT) was developed to better 

address the specific impacts of equipment efficiency standards.29

The NEMS produces a widely recognized baseline energy forecast for the United States 

through 2035 and is available in the public domain. The typical NEMS outputs include forecasts 

of electricity sales, price, and avoided capacity. DOE plans to conduct the utility impact analysis 

as a scenario departing from the latest AEO reference case. In other words, the energy savings 

impacts from amended energy conservation standards will be modeled using NEMS-BT to 

generate forecasts that deviate from the AEO reference case.30

Item 13-1 DOE seeks input from interested parties on its proposed use of NEMS-BT to 

conduct the utility impact analysis. 

14.0 EMPLOYMENT IMPACT ANALYSIS 

The imposition of standards can impact employment both directly and indirectly. Direct 

employment impacts are changes in the number of employees at the plants that produce the 

covered equipment, along with the affiliated distribution and service companies, resulting from 

the imposition of standards. DOE will evaluate direct employment impacts in the MIA, as 

described in section 12.0.

Indirect employment impacts from standards consist of the net jobs created or eliminated 

in the national economy, other than in the manufacturing sector being regulated, due to: (1) 

 

29 For more information on NEMS, please refer to DOE EIA documentation. A useful summary is National Energy 

Modeling System: An Overview 2009, DOE/EIA-0581 (October 2009), available at 

www.eia.doe.gov/oiaf/aeo/overview/index.html. EIA approves use of the name NEMS to describe only an official 

version of the model without any modification to code or data. Because this analysis entails some minor code 

modifications and the model is run under various policy scenarios that are variations on EIA assumptions, DOE 

refers to the model by the name NEMS-BT. BT refers to DOE’s Building Technologies Program, under the aegis of 

which this work is performed. 

30 Several descriptions of NEMS-BT models and an example of their use in a previous commercial equipment 

rulemaking (beverage vending machines,), can be found on DOE’s website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/beverage_machines_final_rule_tsd.html. 
47

reduced spending by end users on energy; (2) reduced spending on new energy supply by the 

utility industry; (3) increased spending on new products to which the new standards apply; and 

(4) the effects of those three factors throughout the economy. DOE expects the net monetary 

savings from standards to be redirected to other forms of economic activity. DOE also expects 

these shifts in spending and economic activity to affect the demand for labor in the short term. 

The combined direct and indirect employment impacts will be investigated in the employment 

impact analysis using the Pacific Northwest National Laboratory’s Impact of Sector Energy 

Technologies (ImSET) model.31 The ImSET model was developed for EERE and estimates the 

employment and income effects of energy-saving technologies in buildings, industry, and 

transportation. In comparison with simple economic multiplier approaches, ImSET allows for 

more complete and automated analysis of the economic impacts of energy conservation 

investments. 

Item 14-1 DOE requests feedback on this approach to assessing employment impacts. 

15.0 ENVIRONMENTAL ASSESSMENT 

To comply with the National Environmental Policy Act and the requirements of 42 

U.S.C. 6295(o)(2)(B)(i)(VI) and 6316(a), DOE intends to prepare an environmental assessment 

of the impacts of amended energy conservation standards for automatic commercial ice-making 

equipment on the human environment. The primary environmental effects of these standards 

would be reduced power plant emissions resulting from reduced consumption of electricity. DOE 

will assess these environmental effects by using NEMS-BT to provide key inputs to its analysis. 

The portion of the environmental assessment that will be produced by NEMS-BT considers 

carbon dioxide (CO2), nitrogen oxides (NOx), and mercury (Hg). The environmental assessment 

also considers impacts on sulfur dioxide (SO2) emissions and discusses particulate matter (PM) 

emissions. After a brief discussion of general methodology, this section will address each of the 

relevant emissions. The following section then explains how DOE plans to monetize the benefits 

associated with emissions reductions. 

15.1 Carbon Dioxide 

A DOE standard is likely to result in reductions of CO2 emissions. The CO2 emission 

reductions likely to result from a standard will be estimated using NEMS-BT and national energy 

savings estimates drawn from the NIA spreadsheet model. The net benefit of the standard is the 

difference between emissions estimated by NEMS-BT at each standard level considered and the 

AEO Reference Case. NEMS-BT tracks CO2 emissions using a detailed module that provides 

results with broad coverage of all sectors and inclusion of interactive effects. 

15.2 Sulfur Dioxide 

SO2 emissions from affected Electric Generating Units (EGUs) are subject to nationwide 

and regional emissions cap and trading programs, and DOE has preliminarily determined that 

 

31 Scott M.J., O.V. Livingston, J.M. Roop, R.W. Schultz, and P.J. Balducci. ImSET 3.1:Impact of Sector Energy 

Technologies Model Description and User’s Guide. 2009. PNNL-18412, Pacific Northwest National Laboratory, 

Richland, WA. 
48

these programs create uncertainty about the standards’ impact on SO2 emissions. Title IV of the 

Clean Air Act sets an annual emissions cap on SO2 for affected EGUs in all 50 states and the 

District of Columbia (D.C.). SO2 emissions from 28 eastern States and D.C. are also limited 

under the Clean Air Interstate Rule (CAIR, 70 Fed. Reg. 25162 (May 12, 2005)), which created 

an allowance-based trading program that would have gradually replaced the Title IV program in 

those states and D.C. Although CAIR has been remanded to EPA by the U.S. Court of Appeals 

for the District of Columbia Circuit (D.C. Circuit), see North Carolina v. EPA, 550 F.3d 1176 

(D.C. Cir. 2008), it will remain in effect until it is replaced by a rule consistent with the D.C. 

Circuit’s earlier opinion in North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008). On July 6, 

2010, EPA proposed the Transport Rule, a replacement for CAIR, which would limit emissions 

from EGUs in 32 states, potentially through the interstate trading of allowances, among other 

options. 75 FR 45210 (Aug. 2, 2010). 

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

imposition of an efficiency standard could be used to permit offsetting increases in SO2

emissions by any regulated EGU. However, if the standard resulted in a permanent increase in 

the quantity of unused emissions allowances, there would be an overall reduction in SO2

emissions from the standards. While there remains some uncertainty about the ultimate effects of 

efficiency standards on SO2 emissions covered by the existing cap and trade system, the NEMSBT modeling system that DOE uses to forecast emissions reductions currently indicates that no 

physical reductions in power sector emissions would occur for SO2. 

15.3 Nitrogen Oxides 

NEMS-BT also has an algorithm for estimating NOx emissions from power generation. 

As with SO2 emissions, these emissions will be affected by CAIR and its replacement. The 

recent legal history surrounding CAIR, including its proposed replacement by the Transport 

Rule, is discussed above. 

Much like SO2 emissions, a cap on NOx emissions would mean that the standards for 

automatic commercial ice-making equipment may have little or no physical effect on these 

emissions in the 28 eastern states and the D.C. covered by CAIR or any states covered by the 

proposed Transport Rule. Because all states covered by CAIR opted to reduce NOx emissions 

through participation in cap-and-trade programs for electric generating units, emissions from 

these sources are currently capped across the CAIR region. 

DOE plans to use NEMS-BT to estimate the emissions reductions from possible 

standards in the states where emissions are not capped. 

15.4 Mercury 

 Similar to emissions of SO2 and NOx, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 Fed. Reg. 

28606 (May 18, 2005). CAMR would have permanently capped emissions of mercury for new 

and existing coal-fired power plants in all states by 2010. However, on February 8, 2008, the 
49

D.C. Circuit issued a decision in New Jersey v. Environmental Protection Agency, in which it 

vacated CAMR. 517 F.3d 574 (D.C. Cir. 2008). EPA has decided to develop emissions standards 

for power plants under the Clean Air Act (Section 112), consistent with the D.C. Circuit’s 

opinion on CAMR. See http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. 

Pending EPA's forthcoming revisions to the rule, DOE is excluding CAMR from its 

Environmental Analysis. In the absence of CAMR, a DOE standard would likely reduce Hg 

emissions and DOE plans to use NEMS-BT to estimate these emission reductions. However, 

DOE continues to review the impact of rules that reduce energy consumption on Hg emissions, 

and may revise its assessment of Hg emission reductions in future rulemakings. 

15.5 Particulate Matter 

DOE acknowledges that particulate matter (PM) exposure can impact human health. 

Power plant emissions can have either direct or indirect impacts on PM. A portion of the 

pollutants emitted by a power plant are in the form of particulates as they leave the smoke stack. 

These are direct, or primary, PM emissions. However, the great majority of PM emissions 

associated with power plants are in the form of secondary sulfates, which are produced at a 

significant distance from power plants by complex atmospheric chemical reactions that often 

involve the gaseous (non-particulate) emissions of power plants, mainly SO2 and NOx. The 

quantity of the secondary sulfates produced is determined by a very complex set of factors 

including the atmospheric quantities of SO2 and NOx, and other atmospheric constituents and 

conditions. Because these highly complex chemical reactions produce PM comprised of different 

constituents from different sources, EPA does not distinguish direct PM emissions from power 

plants from the secondary sulfate particulates in its ambient air quality requirements, PM 

monitoring of ambient air quality, or PM emissions inventories. For these reasons, it is not 

currently possible to determine how the amended standard impacts either direct or indirect PM 

emissions. Therefore, DOE is not planning to assess the impact of these standards on PM 

emissions. Further, as described previously, it is uncertain whether efficiency standards will 

result in a net decrease in power plant emissions of SO2 and NOx, since those pollutants are now 

largely regulated by cap and trade systems. 

Item 15-1 DOE seeks input on its plans to use NEMS-BT to conduct the environmental 

impact analysis on the equipment covered by this rulemaking. DOE is 

particularly interested in whether there are any other approaches to the 

environmental assessment that it should consider and the advantages and 

disadvantages for each approach. 

16.0 MONETIZATION OF EMISSIONS REDUCTIONS 

For those emissions for which national emission reductions are anticipated (CO2, Hg, and 

NOx for 22 states), only ranges of estimated economic values based on environmental damage 

studies of varying quality and applicability are available. Therefore, DOE intends to report 

estimates of monetary benefits derived using these values and consider these benefits in 

weighing the costs and benefits of each of the standard levels considered. 

In order to estimate the monetary value of benefits resulting from reduced emissions of 

CO2, it is DOE’s intent to use in its analysis the most current Social Cost of Carbon (SCC) 
50

values developed and/or agreed to by interagency reviews. The SCC is intended to be a monetary 

measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including, 

but not limited to, net agricultural productivity loss, human health effects, property damage from 

sea level rise, and changes in ecosystem services. Any effort to quantify and to monetize the 

harms associated with climate change will raise serious questions of science, economics, and 

ethics. But with full regard for the limits of both quantification and monetization, the SCC can be 

used to provide estimates of the social benefits of reductions in GHG emissions. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2010 were $4.9, $22.3, $36.5, and $67.5 per 

metric ton in 2009 dollars. These values are then adjusted to 2009$ using the standard gross 

domestic product deflator value for 2008 and 2009. For emissions (or emission reductions) that 

occur in later years, these values grow in real terms over time. Additionally, the interagency 

group determined that a range of values from 7 percent to 23 percent should be used to adjust the 

global SCC to calculate domestic effects, although DOE will give preference to consideration of 

the global benefits of reducing CO2 emissions. To calculate a present value of the stream of 

monetary values, DOE will discount the values in each of the four cases using the discount rates 

that had been used to obtain the SCC values in each case. 

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

DOE also intends to estimate the potential monetary benefit of reduced NOx emissions 

resulting from the standard levels it considers. Available estimates suggest a very wide range of 

monetary values for NOx emissions, from $370 per ton to $3,800 per ton of NOx from stationary 

sources, measured in 2001$ (equivalent to a range of $447 to $4,591 per ton in 2009$).32 In 

accordance with OMB guidance, DOE will conduct two calculations of the monetary benefits 

derived using each of the economic values used for NOx, one using a real discount rate of 3 

percent and another using a real discount rate of 7 percent.33

DOE does not plan to monetize estimates of Hg in this rulemaking. DOE is aware of 

multiple agency efforts to determine the appropriate range of values used in evaluating the 

potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg 

in its rulemakings. 

Item 16-1 DOE invites comments on its approach to monetization of emissions. 

 

32 For additional information, refer to the OMB 2006 Report to Congress on the Costs and Benefits of Federal 

Regulations and Unfunded Mandates on State, Local, and Tribal Entities. Available online at: 

www.whitehouse.gov/sites/default/files/omb/assets/omb/inforeg/2006_cb/2006_cb_final_report.pdf. 

33 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 
51

17.0 REGULATORY IMPACT ANALYSIS 

Pursuant to section 6(a)(3) of Executive Order (E.O.) 12866, “Regulatory Planning and 

Review,” 58 FR 51735 (October 4, 1993), if DOE determines that amended energy conservation 

standards for automatic commercial ice-making equipment would constitute a significant 

regulatory action, during the NOPR stage DOE will prepare and submit to OMB (1) an 

assessment of the costs and benefits of the proposed regulation, and (2) if the proposed rule is 

also significant under section 3(f)(1) of the E.O., a regulatory impact analysis (RIA), which is 

subject to review under the Executive Order by the Office of Information and Regulatory Affairs 

at OMB. The RIA would address the potential for non-regulatory approaches to supplant or 

augment energy conservation standards to improve the energy efficiency or reduce the energy 

consumption of the automatic commercial ice-making equipment covered under this rulemaking 

in the market. 

DOE recognizes that voluntary or other non-regulatory efforts by manufacturers, utilities 

and other interested parties can result in substantial improvements to energy efficiency or 

reductions in energy consumption. DOE intends to consider the likely effects of non-regulatory 

initiatives on equipment energy use, consumer utility, and LCCs. DOE will base its assessment 

on the actual impacts of any such initiatives to date and will consider information presented 

regarding the impacts that any existing initiative might have in the future. 

Item 17-1 DOE seeks comment regarding programs that should be examined as optional, 

non-regulatory approaches. 
52

APPENDIX A – LIST OF ITEMS FOR COMMENT 

This appendix lists all the items for comment contained in this framework document and the 

page numbers on which those items can be found. 

Item 1-1 While DOE invites comment on all aspects of the material presented in this 

document, several specific issues on which DOE seeks comment are set out in 

comment boxes like this one. DOE uses these comment boxes to highlight issues and 

ask specific questions on the approaches DOE plans to follow to conduct the analyses 

required for the energy conservation standards rulemaking. Such requests for 

feedback are numbered sequentially throughout the document and are repeated in 

Appendix A. .................................................................................................................. 1

Item 1-2 DOE requests comment regarding the development of updated test procedures for the 

automatic commercial ice-making equipment covered under this rulemaking. ........... 8

Item 1-3 DOE requests comment on the possibility of applying the AHRI 810-2007 test 

procedure to larger capacity equipment and tube type ice-makers. If the AHRI 810-

2007 test procedure cannot be applied to larger capacity and tube type ice-makers, 

what test procedure should be applied? ........................................................................ 8

Item 1-4 DOE seeks comment on the categories of automatic commercial ice-making 

equipment. ..................................................................................................................... 9

Item 1-5 DOE seeks information concerning any entities that should be added to the interested 

parties list, in particular additional manufacturers, small business manufacturers, 

consumers, and energy conservation and environmental advocates. .......................... 12

Item 3-1 DOE seeks information on annual shipments into the U.S. market from 1995 to 2010 

(both domestic and imports) by equipment class, and the corresponding shipmentweighted average efficiency of these shipments. ........................................................ 14

Item 3-2 DOE seeks information on the proportion(s) of equipment shipped annually that 

replaces existing equipment. ....................................................................................... 14

Item 3-3 DOE requests feedback on amending the current standard for cube machines. ......... 17

Item 3-4 DOE requests feedback on extending the standard to include flake, nugget, and tube 

machines. .................................................................................................................... 17

Item 3-5 DOE requests feedback on the exclusion of block ice-makers in the standard at this 

time. DOE particularly seeks information on the potential for domestic use of 

automatic commercial block ice-makers. ................................................................... 17

Item 3-6 DOE requests feedback on tube type machines. DOE understands the machines have 

tube-shaped evaporators and/or make tube-shaped ice and that these machines operate 

cyclically like cube machines, but they do not produce clear ice. DOE requests 

comment on whether separate product classes should be established for such 

products. If yes, what are the appropriate capacity ranges for these classes? If not, 

with which of the proposed product classes should the tube machines be grouped? . 17

Item 3-7 DOE requests feedback concerning the proposed harvest rate breakdowns, and if they 

accurately reflect the current market. .......................................................................... 17

Item 3-8 DOE requests feedback on the proposed equipment classes for the automatic 

commercial ice-making equipment covered under this rulemaking, and the criteria 

used in creating the classes. ........................................................................................ 17

Item 3-9 DOE requests comment on including ice-makers with capacities greater than 4,000 

pounds per day in this rulemaking. If DOE should include standards for ice-makers 
53

with capacities larger than 4,000 pounds per day, what should the range of capacities 

be in this rulemaking? ................................................................................................. 17

Item 3-10 What technologies or designs, if any, should be added to or removed from the above 

list? If certain changes to the list are not applicable to all equipment classes, what 

equipment classes are affected? .................................................................................. 18

Item 3-11 DOE requests feedback on potable water use as a metric. ......................................... 19

Item 3-12 DOE requests comment on the relationship between potable water use and energy 

efficiency. Specifically, to what degree is potable water efficiency likely to increase 

with increased stringency of energy efficiency requirements for the ice-makers 

covered under this rulemaking without explicit potable water efficiency 

requirements? .............................................................................................................. 22

Item 3-13 DOE seeks feedback on including total water use in the technological assessment. . 22

Item 3-14 DOE seeks input on what technologies or designs should be considered to improve 

water efficiencies. ....................................................................................................... 22

Item 3-15 DOE welcomes comment on standby and off mode energy consumption as it relates 

to automatic commercial ice-making equipment. ....................................................... 24

Item 3-16 DOE seeks information that would confirm or deny the presence of secondary cooling 

in automatic commercial ice-maker applications. ...................................................... 24

Item 3-17 DOE seeks feedback on the proposed baselines. ........................................................ 26

Item 4-1 DOE welcomes comments on the above four screening criteria. ............................... 26

Item 5-1 DOE seeks comments from stakeholders providing insights regarding such trade-offs.

..................................................................................................................................... 27

Item 5-2 DOE requests comments on the best ways to collect such information from the 

industry. DOE anticipates that such data might be collected and aggregated by AHRI 

for submittal to DOE. .................................................................................................. 27

Item 5-3 DOE requests input on appropriate categories and questions to be included on such 

requests for data. ......................................................................................................... 27

Item 5-4 DOE seeks comment on simplifying assumptions that may be made to reduce the 

potential complexity of maximizing benefits associated with both water and energy 

use reductions.............................................................................................................. 27

Item 5-4A DOE seeks comments and recommendations regarding the potential data collection 

efforts that might be made by industry participants to support this rulemaking, and the 

possible structure of data request forms that could be used to assist such efforts. ..... 27

Item 5-5 DOE is also interested in receiving equipment test data (test procedure used, rating 

conditions, harvest rate, voltage, integrated average product temperature, daily energy 

consumption, etc.). Test data representative of the baseline model in each equipment 

class is particularly important. .................................................................................... 28

Item 5-6 DOE requests feedback on the use of a combined analysis approach that uses multiple 

information sources to determine the relationship between manufacturer selling price 

and energy consumption for automatic commercial ice-makers. ............................... 28

Item 5-7 DOE seeks comment on which information sources may be the best for developing 

estimates of manufacturer selling prices. .................................................................... 29

Item 5-8 Are there proprietary designs that DOE should consider in the analyses for any of the 

equipment under consideration by this rulemaking? If so, how should DOE acquire 

the cost data necessary for evaluating these designs? Conversely, are there proprietary 

designs that should not be considered? Which products use these designs? .............. 29
54

Item 5-9 DOE requests feedback on the suggested representative sizes for cube ice machines. 

Should multiple sizes be considered for any of the product classes? ......................... 30

Item 5-10 Can any of the product groups (i.e., combination of equipment type and condenser 

cooling type) be represented by consideration of fewer representative products than 

the group’s number of product classes? ...................................................................... 30

Item 5-11 Can flake and nugget machines be represented by fewer representative products than 

cube machines? ........................................................................................................... 30

Item 5-12 DOE welcomes comments on which product classes could be selected for focused 

analysis, and for which product classes the analyses could be extrapolated. ............. 30

Item 5-13 Are there outside regulatory issues that DOE should consider in its engineering 

analysis of commercial automatic ice-makers? .......................................................... 31

Item 6-1 DOE seeks data or data sources that could be used to characterize the energy use of 

automatic commercial ice-making equipment. ........................................................... 31

Item 6-2 DOE seeks feedback on the assumption that commercial ice-making machine 

operation has a negligible impact on the building space-conditioning loads. ............ 31

Item 7-1 DOE requests information on the proposed distribution channels for the commercial 

ice-making equipment covered under this rulemaking. .............................................. 33

Item 7-2 DOE requests information on whether the distribution channels differ by the types of 

buildings that comprise the market for automatic commercial ice-makers, namely, 

food sales establishments, food service establishments, health care facilities, lodging 

facilities, and others. ................................................................................................... 33

Item 7-3 DOE requests feedback on its proposal to use incremental distribution channel 

markups for the LCC analysis. .................................................................................... 33

Item 7-4 DOE seeks comment on sources of food service equipment distribution chain data 

that could be used to characterize markups for the food service equipment industry. 33

Item 7-5 DOE seeks comment on appropriate transportation and shipping costs to include in 

the analysis and whether those costs are likely to vary for higher efficiency 

equipment. ................................................................................................................... 33

Item 8-1 DOE seeks comment on the proposed approaches for estimating current and 

forecasted energy prices. ............................................................................................. 36

Item 8-2 DOE seeks comment on the proposed approaches for estimating discount rates for 

consumers of the equipment covered under this rulemaking. ..................................... 36

Item 8-3 DOE seeks answers to the question: What are the typical installation, maintenance, 

and repair costs and practices during the life cycle of an originally manufactured 

automatic commercial ice-making machine?.............................................................. 37

Item 8-4 What is a typical time period between the sale of a new product and the first 

maintenance or repairs? What are the typical cycles of maintenance and repairs? .... 37

Item 8-5 DOE seeks feedback on whether and how routine maintenance, repair, and 

installation costs will change for products that are more energy and water efficient. 37

Item 8-6 If it is not appropriate to assume that changes in maintenance, repair, or installation 

costs would be negligible for more-efficient products, DOE seeks feedback on 

appropriate methodologies for assessing changes to each of these costs. .................. 37

Item 8-7 DOE seeks comment on appropriate equipment lifetimes for the classes of equipment 

covered in this rulemaking. ......................................................................................... 37

Item 8-8 DOE seeks input on the proposed methodology for developing estimates of national 

water costs and potential savings associated with the proposed rule.......................... 38
55

Item 9-1 DOE seeks information on historical shipments of automatic commercial ice-making 

equipment for each equipment class covered under this rulemaking, as well as 

industry-trend data regarding relative growth in each equipment class. .................... 39

Item 9-2 DOE seeks information on representative saturation rates for each equipment class 

covered under this rulemaking, as well as industry-trend data regarding relative 

growth in each equipment class. ................................................................................. 39

Item 9-3 DOE requests input from manufacturers on the potential impact of new energy 

conservation standards on equipment shipments. Other interested parties are also 

welcome to provide input. DOE also requests input on any market-pull programs that 

currently exist to promote the adoption of more-efficient equipment. ....................... 40

Item 10-1 DOE requests information on whether a rebound effect exists and should be 

incorporated in the NIA. ............................................................................................. 41

Item 10-2 DOE welcomes comments from interested parties on the use of NIA spreadsheet 

models for estimating national impacts of amended energy and water conservation 

standards for automatic commercial ice-making equipment. ..................................... 42

Item 11-1 DOE seeks input as to which customer subgroups DOE should consider in the present 

rulemaking. Examples of possible subgroups DOE could consider appropriate for 

automatic commercial ice-making equipment include small independent grocery and 

convenience stores and independently owned restaurant and motels. ........................ 43

Item 12-1 DOE seeks comment on the establishment of manufacturer subgroups for automatic 

commercial ice-making equipment, particularly small businesses and niche 

manufacturers. ............................................................................................................. 45

Item 12-2 What regulations or pending regulations should DOE consider in the analysis of 

cumulative regulatory burden? ................................................................................... 45

Item 13-1 DOE seeks input from interested parties on its proposed use of NEMS-BT to conduct 

the utility impact analysis. .......................................................................................... 46

Item 14-1 DOE requests feedback on this approach to assessing employment impacts. ............ 47

Item 15-1 DOE seeks input on its plans to use NEMS-BT to conduct the environmental impact 

analysis on the equipment covered by this rulemaking. DOE is particularly interested 

in whether there are any other approaches to the environmental assessment that it 

should consider and the advantages and disadvantages for each approach. ............... 49

Item 16-1 DOE invites comments on its approach to monetization of emissions. ...................... 50

Item 17-1 DOE seeks comment regarding programs that should be examined as optional, nonregulatory approaches. ................................................................................................ 51