1 | Energy Efficiency and Renewable Energy 

Energy Conservation Standards:

Notice of Proposed Rulemaking for

Automatic Commercial Ice Makers

April 14, 2014

Appliance St

Department of EnBuilding Technolo

EERE‐2012‐STD‐00

ACIM‐2010‐STD‐0
2

Welcome• Introductions (around the room)

• Role of the Facilitator• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete tra

this meeting.

– Be concise – share the “air‐time.”

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

conversations.

– Webinar participants turn phone on mute; “raise your hand

recognized to speak.

• Housekeeping Items• Agenda Review• Opening Remarks
3

Agenda• 9:00 – 9:20 am Welcome, Introductions, Opening State

• 9:20 – 10:15 am Overview, Scope, Market and Technolog

Assessment, Screening Analysis

• 10:15 – 10:30 am Break

• 10:30 – 11:30 am Engineering Analysis

• 11:30 – 12:00 am Markup Analysis, Energy Use, Life‐Cycle 

Payback Period Analysis

• 12:00 pm – 1:00 pm Lunch

• 1:00 am – 1:30 pm Shipments, National Impact Analysis, Re

Impact Analysis

• 1:30 – 1:45 pm Manufacturer Impact Analysis

• 1:45 – 2:00 pm Emissions Analysis, Utility Impact Analy

Employment Analysis

• 2:00 – 2:15 pm Break

• 2:15 – 2:45 pm Proposed Standard

• 2:45 – 3:00 pm Closing Remarks
4

Listening Via the Webcast• The Department is broadcasting this meeting live ov

Internet.

• DOE is providing the webcast to accommodate stake

who are unable to attend the public meeting in pers

• The webcast allows stakeholders to listen in and view 

slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
5

Purpose of the Public Meeting• Present the procedural and analytical approaches to 

energy conservation standards for automatic commemakers (ACIM).

• Invite comment on the energy conservation standard

of proposed rulemaking (NOPR).

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or

statements and raise additional issues for discussion.
6

Issues for Discussion• Issue “boxes” correspond to the list of issues for whi

Department seeks comments.

• The list of issues is in the NOPR document, available 

http://www.regulations.gov/#!documentDetail;D=

BT‐STD‐0037‐0062.

• The deadline for submitting comments is May 16, 20

Issue Box: DOE welcomes comments, data, and informconcerning its proposed standards for ACIM equipment. that correspond to those raised in DOE’s published matewill be numbered in accordance with that material. Whetinvited by an issue box or not, comments are welcome opart of DOE’s analysis.
7

How to Submit Written Comments

In all correspondence, please refer to the ACIM rulemaking by:

– Standards for Automatic Commercial Ice Makers

– Docket Number EERE‐2012‐STD‐0037

– Regulation Identification Number (RIN) 1904‐AC39

Email: ACIM‐2010‐STD‐0037@ee.doe.gov

Postal: CourierMs. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies Prog

Mailstop EE‐2J 950 L’Enfant Plaza SW, Suit

1000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585‐0121 Tel: 202 586‐2945

Comment period closes May 16, 2014, 11:59 PM 
8

Opening Remarks

Meeting participants are invited to provide open

remarks or statements at this time.
9

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment3 Engineering Analysis4 Markups and Energy Use Analysis5 Life‐Cycle Cost and Payback Period Analysis6 Shipments, NIA, RIA, and MIA Analysis

7 Emissions, Utility, and Employment Impacts8 Results and Proposed Standards
10

Regulatory History• Energy Policy and Conservation Act of 1975 (EPCA) 

– Amended by National Energy Conservation Policy Act of 19

619, to establish the “Energy Conservation Program for Cer

Equipment.”

• Energy Policy Act of 2005 (EPACT) P.L. 109‐58

– Amended EPCA to add coverage for cube type automatic co

makers between 50 and 2,500 pounds of ice per 24 hours.

– Granted DOE authority to set standards for additional type

equipment that are not covered in EPCA (includes flake and 

makers and batch type ice makers not included in the origi

definition).

– Required DOE to complete one rulemaking cycle to determ

to further amend ACIM standards.

– Final rule required no later than January 1, 2015.
11

Definition of Covered Products• EPACT defines automatic commercial ice makers as f

The term “automatic commercial ice maker” means a factory‐m

assembly (not necessarily shipped in one package) that —

(A) consists of a condensing unit and ice‐making section op

as an integrated unit, with means for making and harvestin

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

dispensing ice.
12

DOE Test Procedure• Pursuant to EPCA, on December 8, 2006, DOE publis

rule that adopted a revised method for calculating e

based on the existing ARI and ASHRAE standards.

• DOE published a test procedure final rule on January 

77 FR at 1591.

– The test procedure became mandatory for all ACIM testing 

January 7, 2013.

– The test procedure included the following revisions:

• Updated the industry test procedure references to AHRI 810‐

ANSI/ASHRAE 29‐2009.

• Expanded the scope of the test procedure to include equipm

capacities from 50 to 4,000 lb of ice per 24 hours.

• Provided test methods for continuous type ice makers.
13

Rulemaking Process Overview• New or amended standards must be designed to ach

maximum improvement in energy efficiency that is

technologically feasible and economically justified. 6295(o)(2)(A))

• DOE performs the following analyses to determine

technological feasibility:

EPCA Requirement Corresponding DOE Ana

Technological Feasibility

 Market and Technology Ass

 Screening Analysis

 Engineering Analysis
14

Rulemaking Process Overview• 42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider sev

factors when setting energy conservation standards:

EPCA Factor DOE Analysis

1. Economic impact on consumers and 

manufacturers

• Life-cycle cost analysis• Manufacturer impact ana

2. Lifetime operating cost savings • Life-cycle cost analysis3. Total projected energy savings • National impact analysis 4. Impact on utility or performance • Engineering analysis • Screening analysis5. Impact of any lessening of competition • Manufacturer impact ana6. Need for national energy conservation • National impact analysis7. Other factors the Secretary considers 

relevant

• Emissions analysis• Utility impact analysis• Employment impact anal
15

Energy Conservation Standards ‐ Rulemaking T

2010

ECS Framework 

Document Public 

Meeting

December 16, 2010

ECS Preliminary 

Analysis

Public Meeting

February 16, 2012

P

2012 2015 

TP NOPR 

Public Meeting

April 29, 2011

2011
16

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment3 Engineering Analysis4 Markups and Energy Use Analysis5 Life‐Cycle Cost and Payback Period Analysis6 Shipments, NIA, RIA, and MIA Analysis

7 Emissions, Utility, and Employment Impacts8 Results and Proposed Standards
17

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
18

Market Assessment

• Method

– Characterize the ACIM industry and market.

– Gather historical shipments and other relevant da

– Determine appropriate equipment classes.

– Identify technology options for improving efficien

• A detailed description of methodology and re

contained in chapter 3 of the NOPR technical 

document (TSD).
19

Equipment Classes• EPCA, as amended by EPACT 2005, prescribed standa

13 covered classes for ice makers. (42 U.S.C. 6313(d)

– These standards covered cube type makers.

– These standards covered capacities from 50 to 2,500 lb/24 

• In this NOPR, DOE is considering 25 covered classes.

– The proposed standards cover both batch and continuous i

– The proposed standards cover capacities from 50 to 4,000 

• The test procedure final rule established new definit

test procedures for batch and continuous ice maker 1591 (Jan. 11, 2012).

From 10 CFR 431.132:

Batch ice maker – an ice maker having alternate freezing and harvesting period

Continuous ice maker – an ice maker that continually freezes and harvests ice 

time
20

Proposed Equipment Classes (Batch Type)

Equipment Type Type of Cooling Harvest Capacity Rate lb/24 hr Type of Ice Maker 

Ice‐Making Head (IMH)

Water

≥50 and <500 Batch 

≥500 and <1,436 Batch 

≥1,436 and ≤4,000 Batch 

Air

≥50 and <450 Batch 

≥450 and <875 Batch 

≥875 and <2,210 Batch 

≥2,210 and <2,500 Batch ≥2,500 and ≤4,000 Batch 

Remote Condensing (RCU)(but not remote compressor) Air ≥50 and <1,000 Batch 

≥1,000 and ≤4,000 Batch 

Remote Condensing (RCU) andRemote Compressor Air ≥50 and <934 Batch 

≥934 and ≤4,000 Batch 

Self‐Contained Unit (SCU)

Water ≥50 and <200 Batch 

≥200 and ≤4,000 Batch 

Air ≥50 and <175 Batch 

≥175 and ≤4,000 Batch 

DOE’s proposed batch equipment classes includes new IMH‐A‐B equipment ccreate a constant efficiency level at the highest capacities, while conforming 

anti‐backsliding provisions.
21

Proposed Equipment Classes (Continuous Type

Equipment Type Type of Cooling Harvest Capacity Rate lb/24 hr Type of Ice Maker 

Ice‐Making Head (IMH)

Water ≥50 and <900 Continuous 

≥900 and ≤4,000 Continuous 

Air ≥50 and <700 Continuous 

≥700 and ≤4,000 Continuous 

Remote Condensing (RCU)(but not remote compressor) Air ≥50 and <850 Continuous 

≥850 and ≤4,000 Continuous 

Remote Condensing (RCU) and

Remote Compressor Air ≥50 and <850 Continuous 

≥850 and ≤4,000 Continuous 

Self‐Contained Unit (SCU)

Water ≥50 and <900 Continuous 

≥900 and ≤4,000 Continuous 

Air ≥50 and <700 Continuous 

≥700 and ≤4,000 Continuous 

For water‐cooled equipment subject to maximum condenser water use standa

proposal would adopt a constant maximum water consumption for water coo

makers with harvest capacity rate greater than 2,500 lb/24 hr. This would cre

additional capacity‐range‐defined equipment classes.
22

ACIM Database Updates• During the NOPR analysis, DOE updated its ACIM dat

new data from:

– Manufacturer websites

– The AHRI directory (including new ice hardness data)

– Other regulatory programs

• DOE updated the max‐available product levels based 

new information:

– Batch equipment classes: In some cases, the maximum ava

equipment used technologies that DOE screened out of its 

– Continuous equipment classes: In the NOPR analysis, DOE 

only product ratings with accompanying ice hardness data.
23

Baseline Efficiency Levels

Equipment

Type

Type of

Cooling

Harvest Capacity Rate

lb/24 hr

NOPR Baseline Energy Use

kWh/100 lb ice*

Ice‐Making

Head

Water Small (<900) 8.1–0.00333H Large (≥900) 5.1

Air Small (<700) 11.0–0.00629H Large (≥700) 6.6

RemoteCondensing Air Small (<850) 10.2–0.00459H Large (≥850) 6.1

Self‐ContainedUnit

Water Small (<900) 9.1–0.00333H Large (≥900) 6.1

Air Small (<700) 11.5–0.00629H Large (≥700) 7.1

* H = Harvest capacity in lb/24 hours.

• For batch ice maker equipment classes, DOE used th

standard level as the baseline efficiency level (extend

4,000 lb/24 hr).

• For continuous ice maker equipment classes, DOE re

the baseline efficiency levels based on the NOPR dat

and the published AHRI Directory data for continuou
24

Baseline Efficiency Levels for Continuous Ice M

IMH‐A‐C Units SCU‐A‐C Un

• DOE fitted the NOPR baseline levels as closely to the 

possible.
25

Technology Assessment• DOE identified technology options from:

– Literature review

– Manufacturer brochures and specification sheets from commerci

equipment

– Comments and input from stakeholders

– Manufacturer interviews

• DOE collected updated information on technology option costs 

efficiency impacts during the NOPR phase.

• DOE considered alternative refrigerants, but did not find any ac

alternatives that have been approved by the EPA’s Significant N

Alternatives Program (SNAP).

• Chapter 3 of the NOPR TSD contains a detailed description of t

technologies.
26

Technology Assessment• DOE identified the following technology options for 

Technology Options Batch Ice Makers Continuous Ice Makers 

Compressor Improved compressor efficiency √ √

Part‐load operation √ √

Condenser

Increased surface area  √√

Enhanced fin surfaces √ √ Air‐cooled 

Increased air flow √ √ Air‐cooled 

Increased water flow √ √ Water‐coo

Brazed plate condenser √ √ Water‐coo

Microchannel condenser √ √ Air‐cooled 

Fans and Fan Motor Higher efficiency condenser fans and fan motors √ √ Air‐cooled 

Other Motors Improved auger motor efficiency √ Improved pump motor efficiency √Controls Smart Technologies √ √

Evaporator

Increased surface area √ √

Design options which reduce energyloss due to evaporator thermalcycling

√

Design options which reduceharvest meltage or reduce harvest

time

√

Insulation Improved or thicker insulation √ √

Refrigeration Line Larger diameter suction line √ √ Primarily 

equipmen

Potable Water Reduced potable water flow √ Drain water thermal exchange √
27

Screening Analysis• DOE screened out technology options based on failu

four criteria:

– Technological feasibility– Practicability to manufacture, install, and service

– Impacts on equipment utility or equipment availability

– Adverse impacts on health or safety

• DOE did not consider technologies without energy sa

were proprietary technology.

• Chapter 4 of the NOPR TSD contains descriptions of w

technologies were screened out.
28

Screening Analysis

Item 4: DOE requests comment on the screening analysand, specifically, the design options DOE screened out orulemaking analysis. Further details are available in chapof the NOPR TSD.

• DOE incorporated the following technology options i

engineering analysis:

Technology Options Batch Ice Makers Continuous Ice Makers 

Compressor Improved compressor efficiency √ √

Condenser Increased surface area  √√ Increased water flow* √ √ Water‐coo

Fans and Fan Motor Higher efficiency condenser fan

motors

√ √ Air‐cooled 

Other Motors Improved auger motor efficiency √ Improved pump motor efficiency √

Evaporator Increased surface area √ √Potable Water Reduced potable water flow √ Drain water thermal exchange √

* DOE determined that this design option was not cost-effective in the engineering analysis.
29

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment3 Engineering Analysis4 Markups and Energy Use Analysis5 Life‐Cycle Cost and Payback Period Analysis6 Shipments, NIA, RIA, and MIA Analysis

7 Emissions, Utility, and Employment Impacts8 Results and Proposed Standards
30

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
31

Engineering Analysis

Purpose

• Characterize manufacturer production cost v

efficiency for higher‐efficiency ACIM equipme

Downstream Ana

• Life‐Cycle Cost an

Payback Period A

• National Impact A

• Manufacturer Im

Analysis

Manufacturer Production Cost–

Efficiency Relationship

Manufacturer

Production Cost

Efficiency Level
32

Engineering Data Collection• For the NOPR analysis, DOE conducted testing and re

engineering on 22 additional models (41 total for all 

– The models were selected to allow development of engine

using the efficiency‐level approach.

– DOE’s selected models represented baseline and maximum 

efficiency for key equipment classes with designs not using 

technology.

– The new models extended representation to equipment cla

analyzed during the preliminary analyses.

• DOE conducted additional tests on three of these mo

inform the analysis:

– Energy use versus condenser water use

– Energy savings of a commercially available drain water hea
33

Purchased Units for the Engineering Analysis

Equipment Class

Nomenclature

Purchased For Preliminary

Analysis

(Number of Energy Tests)

Purchased for N

(Energy Tests o

IMH‐W‐Small‐B 0 3

IMH‐W‐Medium‐B 0 2

IMH‐W‐Large‐B 2 (1) 0

IMH‐A‐Small‐B 2 (2) 1

IMH‐A‐Large‐B 4 (1) 1

RCU‐***‐Small‐B 0 2

RCU‐***‐Large‐B 3(1) 1

SCU‐W‐Small‐B0 0

SCU‐W‐Large‐B 1 (1) 0

SCU‐A‐Small‐B 2 (1) 1

SCU‐A‐Large‐B 0 2

IMH‐W‐Small‐C 0 1

IMH‐W‐Large‐C0 0

IMH‐A‐Small‐C 3 (1) 0

IMH‐A‐Large‐C 0 2

RCU‐***‐Small‐C 0 2

RCU‐***‐Large‐C 1 (1) 0

SCU‐W‐Small‐C 0 1

SCU‐W‐Large‐C0 0

SCU‐A‐Small‐C 0 1

SCU‐A‐Large‐C 1 (1) 0

TOTAL 19 (10) 22 (2
34

Engineering Analysis

• DOE’s preliminary engineering analysis used a design

approach based on an energy‐use model developed f

rulemaking and cost analysis based on reverse engine

• DOE considered alternative approaches for the NOPR

engineering analysis:

– Revision of the preliminary engineering analysis to account 

raised by stakeholders.

– Efficiency‐level analysis based on performance ratings, test 

manufacturing cost analysis based on reverse‐engineering.

– Development of the cost‐efficiency relationship based on re

and energy efficiency ratings.

• DOE concluded that the revised design option analys

only viable approach to developing meaningful result
35

Summary of Alternative Engineering Approach• DOE investigated an efficiency‐level (empirical) analy

approach based on testing and reverse engineering.

– DOE studied 9 different equipment classes using this meth

– A key issue with this approach was how to distinguish betw

impacts associated with harvest capacity as opposed to eff

– For several of the equipment classes, the analysis indicated 

efficiency models cost less than baseline models.

• DOE also investigated a retail cost analysis based on 

efficiency ratings and list prices.

– DOE collected energy and price data for 470 models.

– The analysis showed no significant trend in price versus inc

efficiency.
36

• The preliminary analysis approach was adjusted in the NO

in response to testing and feedback.

• Adjustments to the energy‐model included:

– Adjustments to account for higher harvest energy use for lower c

temperatures

– Adjustments to the compressor coefficient model parameters to c

test results

– Adjustments to component energy use based on energy testing

• DOE also made cost adjustments based on discussions wi

manufacturers and component manufacturers.

Summary of the NOPR Design Option Approac
37

Flow Diagram

Energy Testing Manufacturer Interviews Reverse Engineering Ven

Man

Inc

Cost-Efficiency 

Curves

Energy Models Energy Model Development
38

Design Options Considered in the Engineering 

Design Option Air‐Cooled? Water‐Cooled? Batch‐Type? ContCompressorEfficiency √√√Increased CondSurface Area √√√Increase CondWater Flow** √√Higher Efficiency

Cond Motors √ √

Higher EfficiencyPump Motors √√√Higher Efficiency

Auger Motors √√ 

Increased Evap

Surface* √√√

Batch Water Fill √√√Drain Water Heat

Exchanger* √√√

* Not considered in the preliminary analysis** Analysis showed this option was not cost-effective
39

Design Option Notes• Drain Water Heat Exchangers

– DOE based the efficiency increase due to drain water heat 

testing of ice makers with a commercial model installed.

• Increased Condenser Water Flow

– DOE performed an LCC analysis of the combined water and 

based on test results at different condenser water flows, an

that increasing condenser water flow is not cost effective.1

• Increased Water‐Cooled Condenser Surface Area

– DOE used increases in condenser surface area instead of in

condenser water flow, as long as the space in the ice make

condenser growth.

• Chassis Size Increases

– DOE used chassis size increases in cases where the represe

baseline had room to grow relative to commercially availab

high efficiency that don’t use proprietary technology.

1 Analysis based on national averages for water and electricity costs and a

50/50 split in once‐through and cooling tower installations.
40

Design Option Notes• Heat Exchanger Size Increases

– DOE based the heat exchanger size increases on the size di

in the inspections of the baseline and high‐efficiency units, 

by the space available in the chassis.

• Compressors Efficiency Improvements

– DOE based compressor efficiency improvements on the cu

for compressors available from component manufacturers. 

the analyzed compressor levels to compressors that manuf

identified as acceptable for use in ice makers.

• Motor Efficiency Improvements

– Motor efficiency improvements were based on reductions 

input from the baseline motor. DOE performed measureme

input power of baseline motors in tested ice makers, and m

adjustments to the analysis based on the efficiencies of ava

types.
41

Engineering Analysis: Design Options

Item 18: DOE requests comment and data on the efficiegains associated with each set of design options.Item 14: DOE requests comment and data on any utility impacts associated with each set of design options, such potential ice-style changes.
42

Efficiency Levels for Batch Machines

Designation*

Harvest Capacity 

Range 

lb/day

EL2 EL3 EL4 EL5 EL6 M

IMH-W-Small-B < 500 10% 15% 20% 25% 

IMH-W-Med-B ≥ 500 and < 1,436 10% 15% 20% 

IMH-W-Large-B ≥ 1,436 10% 15% 

IMH-A-Small-B < 450 10% 15% 20% 25% 30% 

IMH-A-Large-B ≥ 450 and < 1,600 10% 15% 20% 25% 

IMH-A-Extended-B** ≥ 1,600 10% 15% 20% 

RCU-***-Small-B < 1,000 / < 934 9% 15% 20% 

RCU-***-Large-B ≥ 1,000 / ≥ 934 9% 15% 20% 

SCU-W-Small-B < 200 Not Analyzed 

SCU-W-Large-B ≥ 200 7% 15% 20% 25% 30% 

SCU-A-Small-B < 175 7% 15% 20% 25% 30% 

SCU-A-Large-B ≥ 175 7% 15% 20% 25% 30% 

* Max-available, not considering units with proprietary technology or tube ice configurations.** Max-available is based on the max-available unit greater than 1,200 lb/24 hr that does not use a tube-ice configutechnology.
43

Efficiency Levels for Continuous Machines

Designation*

Harvest Capacity 

Range 

lb/day

EL2 EL3 EL4 EL5 EL6 

IMH-W-Small-C < 900 Not Analyzed 

IMH-W-Large-C ≥ 900 Not Analyzed 

IMH-A-Small-C < 700 10% 15% 20% 25% 30% 

IMH-A-Large-C ≥ 700 10% 15% 20% 25% 30% 

RCU-Small-C < 850 Not Analyzed 

RCU-Large-C ≥ 850 Not Analyzed 

SCU-W-Small-C < 900 Not Analyzed 

SCU-W-Large-C ≥ 900 Not Analyzed 

SCU-A-Small-C < 700 7% 15% 20% 25% 

SCU-A-Large-C ≥ 700 Not Analyzed 

* Max-available based on units in the AHRI directory (as of 11-16-2012) with a rated ice hardness factor.

** DOE was unable to find any products on the market in this proposed equipment class, as of 11-16-2012
44

Cost‐Efficiency Results – Batch Ice Makers

Equipment 

Class Max Available

Representative 

Harvest 

Capacity 

lb/24 hr

EL2* EL3 EL4 EL5 EL6

IMH-W-***-B 10% 15% 20% 25% 30%Small 25% 300 $20 $37 $72 $136 Medium 16% 850 $26 $53 $279 Large

8% 1,500 $46 $359 

8% 2,600 $64 $520 

IMH-A-***-B 10% 15% 20% 25% 30%Small 24% 300 $26 $45 $64 $86 $316 Large

21% 800 $24 $39 $78 $121 

17% 1,500 $35 $118 $429 

RCU-***-***-B 9% 15% 20% 25% 30%Small 25% 700 Not Directly Analyzed

Large

15% 1,500 $28 $76 $386 16% 2,400 $89 $198 $701 

SCU-W-***-B 7% 15% 20% 25% 30%Small 22% 110 Not Directly AnalyzedLarge 28% 300 $30 $48 $62 $88 $304 SCU-A-***-B 7% 15% 20% 25% 30%Small 27% 110 $14 $32 $44 $56 $90 Large 26% 200 $19 $40 $68 $79 $118 

* EL = efficiency level; EL1 is the baseline efficiency level while EL2 through EL6 represent increased efficiency leve
45

Cost‐Efficiency Results – Continuous Ice Maker

Equipment Class Max Available Representative Harvest Capacity lb/24 hr EL2** EL3 EL4 EL5 EL6 

IMH-W-***-C 10% 15% 20% 25% 30%Small 17% 800 Not Directly AnalyzedLarge 12% 1,000 Not Directly Analyzed 9% 1,800 Not Directly Analyzed

IMH-A-***-C 10% 15% 20% 25% 30%

Small 25% 310 $26 $39 $57 $190 $495 Large 17% 820 $30 $46 $61 $98 $500 

8% 1,800 Not Directly Analyzed

RCU-***-***-C 7% 17% 22% 26% 30%Small 18% 700 Not Directly AnalyzedLarge 18% 1,500 Not Directly Analyzed

SCU-W-***-C 3% 10% 16% 20% 25%Small 23% 300 Not Directly Analyzed

Large NA* Not Directly Analyzed

SCU-A-***-C 7% 15% 20% 25% 30%Small 24% 110 $10 $28 $45 $362 Large NA* Not Directly Analyzed* DOE was unable to find any products on the market in this proposed equipment class, as of 11-16-2012.** EL = efficiency level; EL1 is the baseline efficiency level while EL2 through EL6 represent increased efficiency 
46

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment3 Engineering Analysis

4 Markups and Energy Use Analysis

5 Life‐Cycle Cost and Payback Period Analysis6 Shipments, NIA, RIA, and MIA Analysis

7 Emissions, Utility, and Employment Impacts8 Results and Proposed Standards
47

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
48

DOE applies markups to equipment manufactur

price (MSP) to determine the customer purchas

analyzed equipment.• DOE used baseline markups, applied to the M

base case, and incremental markups, applied 

incremental difference in MSP in each standa

• DOE used state level sales tax values in the LC

and a 7.2 percent national average sales tax r

NIA.

• DOE used two distribution chains: 2‐party and • DOE did not use a manufacturer‐direct chain.

Markup Analysis
49

Wholesaler

Dealer

(Includes 

Wholesaler)

National 

Account 

Overal

Average 

ACIM E

Distribution ChannelMarkup

1.36/1.10 2.00/1.31 NA / NA 1.7

Markup(Incl. Sales Tax) 1.45/1.18 2.14/1.40 NA / NA 1.8

Weighted-Average Markups (Baseline / Incremen

Markup Analysis
50

• Presented in detail in TSD chapter 6.

Item 6: DOE welcomes comment on the assumptions anvalues used for the markups analysis.

Markup Analysis
51

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
52

• DOE engineering analysis based on test procedure in

combination with energy consumption model presen

engineering discussion.

• Engineering analysis estimates energy and water usag

100 lb/24 hr.

• LCC and NIA models require kilowatt‐hour usage and 

water used per year.

• DOE assumed the equipment runs at 50 percent of ca

half of the time).

• DOE assumed condenser water is used in single‐pass 

installations.

• DOE assumed a standby power draw of 5 watts durin

when machines are not making ice.

Energy Use Analysis
53

Item 2: DOE welcomes input on the assumptions underlyenergy and water usage calculations.

• Presented in detail in TSD chapter 7.

Energy Use Analysis
54

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment3 Engineering Analysis

4 Markups and Energy Use Analysis5 Life‐Cycle Cost and Payback Period Analysis

6 Shipments, NIA, RIA, and MIA Analysis

7 Emissions, Utility, and Employment Impacts8 Results and Proposed Standards
55

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
56

Purpose• Estimate life‐cycle cost (LCC) savings and payback per

for higher‐efficiency equipment compared to the bas

Methodology• Used Monte Carlo simulation to estimate the life‐cyc

a population (10,000 trials), implemented in an Excel

spreadsheet using Crystal Ball.

• LCC: Equipment‐installed price plus lifetime operating 

• LCC savings: Base‐case LCC minus standards‐case LCC• PBP: Equipment‐incremental installed price divided b

operating cost savings.

• LCC is discounted; PBP is not discounted (“simple” PB

Life‐Cycle Cost & Payback Period Analysis
57

LCC and PBP Analysis: Analysis Flowchart

Baseline 

Manufacturer 

Selling Price

Std-Level 

Manufacturer 

Selling Price

Distributor 

Markup

Contractor 

Markup

Sales 

Tax

Energy and 

Water 

Consumption

Electricity and 

Water Prices

From

Engineering 

Analysis 

(Price is a 

Function of 

Efficiency)

From Markups 

for Equipment 

Price 

Determination 

Analysis

From Energy 

Use Analysis

Installation 

Cost

Customer

Price

Total Installed 

Cost

Repair 

Cost

Maintenance 

Cost

Annual Energy 

and Water Cost

Lifetime

Discount 

Rates

Annual 

Operating 

Expense 

Electricity and 

Water Price 

Trends

Paybac

Period

L

Op

E

D

In

O

Equipment Price 

Trends
58

• Installation Costs

– Based on conversations with installing vendors and RS Mean

– Varied mainly by size of machine with small machines set at 

very large machines set at $1,500.

– Varied by state based on an index developed using RS Mean

• Annual Repair Costs

– Estimated based on components installed in the equipment

would be repaired in the event of component failure (rathe

replacing the machine).

– Varied by equipment class and efficiency levels.

• Annual Maintenance Costs

– Based on conversations with installing vendors and RS Mean

– Ranged from a low of $400 to a high of $1,050.

– Varied by equipment class; did not increase with efficiency 

LCC Inputs
59

Electricity and Water Prices• Base year (2012) electricity prices based on Energy I

Administration (EIA) Form 826 data ‐ specific to state 

• Growth rates based on EIA’s 2013 Annual Energy Out

2013).

• Energy prices extended to building type using Comm

Building Energy Consumption Survey data.

• Current water and wastewater prices based on Ame

Works Association rate survey.

• Water and wastewater price growth based on consu

index for water utility costs.
60

• Experiential learning was introduced to capture histo

observed decreases in MSP.

• For the LCC and PBP analysis, MSP was adjusted from 

current year to the year when the standards take effe

(approximately 0.38 percent decline, total for the inteperiod).

Experiential (Price) Learning
61

Discount Rates• Based on weighted average cost of capital.• Different rates by establishment type: Lodging, Healt

Food Sales, Foodservice, Retail, Education, and Office

Equipment Lifetime• Lifetime ‐ average lifetime of 8.5 years used for all eq

• Modeled as a distribution, from 4 to 12 years, averag

years through the probability of selection.

Documentation• Inputs and analyses presented in detail in TSD chapte

Other Inputs
62

• Used Monte Carlo analyses to vary key inputs:

– Installation costs

– Markups– Electricity costs– Discount rate– Equipment lifetimes

– Base‐case efficiency level distribution

Uncertainties in Input Values
63

Item 8: DOE welcomes stakeholder input and additional information to improve these estimates of installation cosItem 7: DOE welcomes further input on the average equlifetimes for the LCC analysis and NIA.

Item 20: DOE welcomes stakeholder input and additionainformation to improve these estimates of maintenance arepair costs. 

LCC Input Values
64

• For ACIM, DOE presents 5 composite trial standard le

- TSL 5: The max‐tech efficiency level

- TSL 4: Intermediate level between the max‐tech le

maximum customer NPV level, subject to the requ

that the TSL 4 NPV at 7% must be positive

- TSL 3: Highest NPV possible at a 7% discount rate

- TSL 2: Intermediate level between TSL 3 and TSL 1- TSL 1: 2012 ENERGY STAR level for each covered b

equipment class, and similar levels set for non‐covequipment (7‐10%)

• The baseline efficiency level would be TSL 0.

Trial Standard Levels
65

Equipment Class

Standard Level

2012$*

TSL1 TSL2 TSL3 TSL4 TS

IMH-W-Small-B $199 $215 $328 $328 IMH-W-Med-B $464 $464 $587 $405 IMH-W-Large-B $833 $833 $833 $550 

IMH-W-Large-B-1 $701 $701 $701 $583 

IMH-W-Large-B-2 $1,260 $1,260 $1,260 $442 

IMH-A-Small-B $254 $259 $396 $170 IMH-A-Large-B $648 $633 $1,127 $994 

IMH-A-Large-B-1 $590 $572 $1,168 $1,062 IMH-A-Large-B-2 $960 $960 $908 $627 

RCU-***-Large-B $875 $875 $983 $870 

RCU-***-Large-B-1 $847 $847 $963 $857 RCU-***-Large-B-2 $1,298 $1,298 $1,277 $1,070 

SCU-W-Large-B $483 $687 $694 $143 SCU-A-Small-B $103 $198 $396 $106 SCU-A-Large-B $140 $522 $502 $240 IMH-A-Small-C $315 $314 $391 $307 IMH-A-Large-C $660 $744 $1,026 $524 SCU-A-Small-C $93 $140 $146 $146 * LCC savings for IMH-W-Large-B, IMH-A-Large-B, and RCU-***-Large-B are weighted averagethe two sub-equipment class level typical units.

Summary of LCC Savings by Equipment Class
66

Equipment Class

Standard Level*

years

TSL1 TSL2 TSL3 TSL4 TSL

IMH-W-Small-B 1.07 1.26 2.27 2.27 5IMH-W-Med-B 0.63 0.63 0.85 3.33 3IMH-W-Large-B 0.69 0.69 0.69 3.59 3

IMH-W-Large-B-1 0.72 0.72 0.72 3.75 3

IMH-W-Large-B-2 0.58 0.58 0.58 3.10 3

IMH-A-Small-B 1.07 1.22 1.42 4.32 4IMH-A-Large-B 0.46 0.49 0.84 2.16 2

IMH-A-Large-B-1 0.46 0.50 0.82 2.08 2IMH-A-Large-B-2 0.42 0.42 0.94 2.58 2

RCU-***-Large-B 0.41 0.41 0.65 2.39 2

RCU-***-Large-B-1 0.38 0.38 0.62 2.37 2RCU-***-Large-B-2 0.75 0.75 1.00 2.70 2

SCU-W-Large-B 0.67 0.76 1.00 3.01 3SCU-A-Small-B 1.40 1.52 1.56 4.79 4SCU-A-Large-B 1.37 1.17 1.49 3.72 3IMH-A-Small-C 0.90 0.90 0.97 2.59 6IMH-A-Large-C 0.52 0.53 0.69 3.25 3SCU-A-Small-C 1.13 1.53 1.85 1.85 19* PBP results for IMH-W-Large-B, IMH-A-Large-B, and RCU-***-Large-B are shown separately for the two sequipment class level typical units. The class-level results are weighted averages of the typical units.

Summary of Payback Periods by Equipment Cla
67

Life‐Cycle Cost Subgroup Analysis• The customer subgroup analysis evaluates impacts o

identifiable groups of customers of ACIM equipment be disproportionately affected by amended standard

• DOE examined small foodservice and lodging busine

Foodservice experience higher electricity prices and 

capital costs than the national average. Lodging facehighest capital costs of the businesses studied.

• DOE found the difference in LCC savings between the 

average and the foodservice subgroup is typically a fwhile the lodging subgroup LCC savings were 9 to 13 

lower for TSLs 1 – 3. The proposed standard remains effective for both subgroups.

• Documented in TSD chapter 11.
68

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

6 Shipments Analysis, NIA, RIA, and MIA

3 Engineering Analysis4 Markups and Energy Use Analysis5 Life‐Cycle Cost and Payback Period Analysis

2 Market and Technology Assessment

7 Emissions, Utility, and Employment Impacts8 Results and Proposed Standards
69

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
70

Purpose• Estimate future stock and shipments of ACIM equipment by equ

• Estimate efficiency mix of stock over the 30 year analysis period

Methodology• DOE estimated historical shipments data for the year 2010 usin

– Shipments for 2010 submitted by AHRI for this rulemaking

– U.S. Census Bureau Current Industrial Reports

– North American Association of Food Equipment Manufactu

2010 report

• Future shipments are based on historical shipments and growth 

based on commercial floor space construction forecast from AE

Documentation• Details of the shipment analysis can be found in chapter 9 of th

Shipments: Background and Data Sources
71

Percentage of shipments, by equipment classes, 

ratios developed from 2010 AHRI shipments dat

Equipment Class Percentage of Shipments Equipment Class Percenta

Shipm

IMH‐W‐Small‐B 4.54% SCU‐W‐Large‐B 0.22

IMH‐W‐Med‐B 2.90% SCU‐A‐Small‐B 13.85

IMH‐W‐Large‐B 0.00% SCU‐A‐Large‐B 6.56

IMH‐W‐Large‐B1 0.37% IMH‐W‐Small‐C 0.68

IMH‐W‐Large‐B2 0.11% IMH‐W‐Large‐C 0.17

IMH‐A‐Small‐B 27.08% IMH‐A‐Small‐C 3.53

IMH‐A‐Large‐B 0.00% IMH‐A‐Large‐C 1.07

IMH‐A‐Large‐B‐1 13.61% RCU‐Small‐C 0.83

IMH‐A‐Large‐B‐2 2.53% RCU‐Large‐C 0.87

RCU‐Small‐B 5.43% SCU‐W‐Small‐C 0.15

RCU‐Large‐B 0.00% SCU‐W‐Large‐C 0.00

RCU‐Large‐B‐1 5.80% SCU‐A‐Small‐C 8.75

RCU‐Large‐B‐2 0.27% SCU‐A‐Large‐C 0.00

SCU‐W‐Small‐B 0.68% Total 100.0

Shipments: Breakdown by Equipment Class
72

Shipments: Annual Shipments for Selected Yea• Total cumulative shipments of 6,677,548 throughout 

analysis period.

• Total stock in 2018 was estimated as 1.44 million uni

 ‐

50,000

100,000150,000200,000250,000300,000

2018 2020 2025 2030 2035 2040 2045 

New Replacements
73

National Impact Analysis (NIA)

Purpose• To assess the impacts at the national level at each efficiency level as me

– National Energy Savings (NES)

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

Method• For each year, for both the base case and standards cases, DOE calculat

– National energy consumption (energy use per unit multiplied by to

– Total customer expenditures on automatic commercial ice makers:

• National equipment expenditures

• National operation and maintenance costs

• Electricity Site‐to‐Source Full‐Fuel Cycle Conversion Factors.

• Difference between base case and standards cases in each year gives N

customer economic impacts.

Documentation• Details of the national impact analysis can be found in chapter 10 of the 
74

• NIA distributes shipments across efficiency levels based on analyses o

availability.

• Efficiency distributions for standards cases are based on roll‐up scena

Equipment Class Market Share by Efficiency Level

Level 1 Level 2 Level 3 Level 4 Level 5 Level 

IMH‐W‐Small‐B 39.1% 26.1% 23.9% 10.9% 0.0% 0.0

IMH‐W‐Med‐B 69.0% 16.7% 11.9% 0.0% 2.4%

IMH‐W‐Large‐B

IMH‐W‐Large‐B‐1 71.4% 0.0% 4.8% 23.8%

IMH‐W‐Large‐B‐2 33.3% 50.0% 0.0% 16.7%

IMH‐A‐Small‐B 37.0% 31.5% 25.9% 5.6% 0.0% 0.0

IMH‐A‐Large‐B

IMH‐A‐Large‐B‐1 41.5% 43.9% 7.3% 7.3% 0.0% 0.0

IMH‐A‐Large‐B‐2 33.3% 26.7% 26.7% 13.3%

RCU‐***‐Large‐B

RCU‐***‐Large‐B‐1 42.9% 39.3% 8.9% 0.0% 8.9%

RCU‐***‐Large‐B‐2 27.3% 45.5% 9.1% 0.0% 18.2%

SCU‐W‐Large‐B 28.6% 0.0% 14.3% 0.0% 42.9% 0.0SCU‐A‐Small‐B 17.1% 40.0% 5.7% 11.4% 14.3% 11.4SCU‐A‐Large‐B 28.6% 35.7% 0.0% 7.1% 21.4% 7.1IMH‐A‐Small‐C 22.9% 22.9% 14.3% 8.6% 17.1% 2.9

IMH‐A‐Large‐C 35.0% 20.0% 15.0% 15.0% 0.0% 5.0

SCU‐A‐Small‐C 26.7% 20.0% 16.7% 13.3% 3.3% 20.0

NIA: Efficiency Distributions
75

NIA: Shipments Data Inputs

Item 21: DOE welcomes information from stakeholders twould aid in improving estimated market shares of efficielevels.Item 10: DOE’s shipments forecast is based on a single snapshot of shipments by the type of equipment. DOE welcomes information indicating how the mix of shipmenequipment class mix might change over time.Item 17: DOE requests comment and supporting dataon the overall market share of these units designed for ucompressor racks and any expected market trends. 
76

• DOE developed projections of future equipment pric

over the analysis period.

– The reference was derived using inflation adjusted historica

price index from the Bureau of Labor Statistics, PPI series R

Air Conditioning, and Warm Air Heating Equipment.

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

Issue 22: DOE invites comment on methods to improve its equipment price forecasting, as well as any data supporting alternative methods. 

NIA: Price Trends

0.9000.9200.9400.9600.9801.000

2018 2023 2028 2033 2038 2043

Price Factor Indices

Year

Reference PriceConstant Price
77

Other Inputs• Discount Factor

– Used 7 percent and 3 percent real discount rates from the 

Management and Budget’s Regulatory Analysis Guideline A

– Future expenses are discounted to 2013.

• Electricity Site‐to‐Source Conversion Factors

– Used to convert on‐site energy consumption to primary (or 

energy generation.

– For NOPR, a new analysis was performed to develop factor

NEMS.
78

NIA: Cumulative National Energy Savings Resu

National Energy Savings for Equipment Purchased in 201

Equipment Class

National Energy Savings by TSL

FFC energy quads

TSL 1 TSL 2 TSL 3 TSL 4 

IMH‐W‐Small‐B 0.002 0.004 0.010 0.010 

IMH‐W‐ Med ‐B 0.006 0.006 0.009 0.014 

IMH‐W‐Large‐B 0.001 0.001 0.001 0.002 

IMH‐W‐Large‐B‐1 0.001 0.001 0.001 0.002 

IMH‐W‐Large‐B‐2 0.000 0.000 0.000 0.001 

IMH‐A‐Small‐B 0.017 0.033 0.077 0.100 

IMH‐A‐Large‐B 0.025 0.045 0.096 0.124 

IMH‐A‐Large‐B‐1 0.020 0.041 0.087 0.108 

IMH‐A‐Large‐B‐2 0.005 0.005 0.009 0.016 

RCU‐Large‐B 0.013 0.013 0.030 0.046 

RCU‐Large‐B‐1 0.013 0.013 0.029 0.044 

RCU‐Large‐B‐2 0.001 0.001 0.002 0.003 

SCU‐W‐Large‐B 0.000 0.000 0.000 0.000 

SCU‐A‐Small‐B 0.002 0.013 0.025 0.038 

SCU‐A‐Large‐B 0.002 0.010 0.018 0.022 

IMH‐A‐Small‐C 0.002 0.003 0.006 0.008 

IMH‐A‐Large‐C 0.001 0.003 0.006 0.008 

SCU‐A‐Small‐C 0.001 0.004 0.007 0.007 

Total 0.073 0.136 0.286 0.380 
79

NIA: Cumulative Net Present Value Results

Equipment Class

Net Present Value by TSL

billon 2012$

TSL 1 TSL 2 TSL 3 TSL 4 

IMH‐W‐Small‐B 0.013 0.023 0.057 0.057 

IMH‐W‐Med‐B 0.034 0.034 0.054 0.042 

IMH‐W‐Large‐B 0.009 0.009 0.009 0.007 

IMH‐W‐Large‐B1 0.007 0.007 0.007 0.006 

IMH‐W‐Large‐B2 0.002 0.002 0.002 0.001 

IMH‐A‐Small‐B 0.094 0.176 0.394 0.163 

IMH‐A‐Large‐B 0.152 0.275 0.653 0.596 

IMH‐A‐Large‐B1 0.123 0.245 0.602 0.546 

IMH‐A‐Large‐B2 0.030 0.030 0.051 0.050 

RCU‐Large‐B 0.081 0.081 0.178 0.174 

RCU‐Large‐B1 0.078 0.078 0.169 0.165 

RCU‐Large‐B2 0.004 0.004 0.009 0.009 

SCU‐W‐Large‐B 0.001 0.002 0.002 0.001 

SCU‐A‐Small‐B 0.009 0.064 0.190 0.062 

SCU‐A‐Large‐B 0.010 0.086 0.118 0.062 

IMH‐A‐Small‐C 0.009 0.019 0.031 0.027 

IMH‐A‐Large‐C 0.009 0.016 0.034 0.018 

SCU‐A‐Small‐C 0.008 0.021 0.030 0.030 

Total 0.430 0.806 1.751 1.238 

NPV at a 3-percent Discount Rate for Equipment Purchased in 
80

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
81

Regulatory Impact Analysis• Purpose

– To investigate the national impacts of non‐regulatory altern

mandatory amended energy conservation standards.

– The non‐regulatory alternatives that may be considered inc

regulatory action, early replacement, prescriptive standard

tax credits, manufacturer tax credits, customer rebates, vo

efficiency targets, and bulk government procurement.

• Method

– The NIA spreadsheet model is modified to consider differen

– The variables that may be modified include energy prices a

factors, implicit market discount rates, customer purchase 

operating cost, income elasticities, and equipment stock da

• Output

– NES and NPV for the non‐regulatory alternatives.
82

Regulatory Impact Analysis ‐ Results• For this analysis, DOE estimated the benefits associa

consumer tax credits and rebates, targeting an efficie

threshold equal to TSL 3.

– For rebates, DOE assumed 60 percent of shipments would 

exceed the efficiency threshold.

– For tax credits, DOE assumed 48 percent of shipments wou

exceed the efficiency threshold (80 percent of the rebate re

– For this analysis, DOE assumed a market‐driven production 

occur, given that a small percentage of currently available m

meet TSL 3 levels.

• The results show the energy savings equivalent to 52 

the standards‐case energy savings for a tax credit pro64 percent for rebate programs. NPVs are also reducthe rebate and the tax credit programs.
83

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
84

• Purpose

– Assess the impacts of standards on manufacturers.

– Identify and estimate impacts on manufacturer subgroups that ma

severely affected than the industry as a whole.

– Examine the direct employment, competition, manufacturing capa

cumulative regulatory impacts on the industry.

• Methodology

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

Government Regulatory Impact Model (GRIM).

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

analyses, and address qualitative issues.

MIA: Overview
85

• Phase 1

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

important issues that require further investigation.

• Phase 2

– DOE prepares an industry cash flow model and an interview questi

guide subsequent discussions with manufacturers.

• Phase 3

– DOE interviews manufacturers and refines its analysis, assessing th

standards both quantitatively (using the GRIM) and qualitatively (e

impacts on employment, competition, manufacturing capacity, and burden).

MIA: Methodology

Industry profile

Develop straw-man GRIM

Develop interview guide

Interviews& industrysubgroupanalyses

Assess on empcompetcapacitregulatburden

Phase 1 Phase 2 Phase 3
86

• Price Sensitivity

– Manufacturers characterized the market as extremely price sensitive

new and amended standards will result in decreased profit margins 

unable to pass through costs relating to standards compliance. Manon to report that while energy efficiency is important, it is not a feat

customers would pay a premium.

• Enforcement

– Several domestic manufacturers expressed concern about the enfor

amended energy efficiency standard for automatic commercial ice m

produced overseas. Manufacturers believe that insufficient enforcem

to market distortions, as companies that do make the necessary inv

meet amended standards would be at a distinct pricing disadvantag

those that do not comply.

• Reliability Impacts

– Manufacturers expressed concerns that future energy conservation 

would adversely affect reliability, which they believe to be one of th

important features of their products.

MIA: Key Issues (1 of 2)
87

• Impacts on Innovation

– Several manufacturers expressed concerns over the imbalance of in

engineering resources brought about by the regular revision and int

energy conservation standards. As energy use has become increasinmanufacturers have had to shift engineering and support resources 

other initiatives, adversely affecting product innovation outside of e

efficiency. Where the R&D effort required for compliance is intermitinnovation is impacted without adding to overall employment.

MIA: Key Issues (2 of 2)

Item 11: DOE requests additional comment on the magnof investment in R&D efforts directed at compliance with energy conservation standards. 
88

• DOE modeled two markup scenarios:

– Preservation of Gross Margin (Percentage of Revenues)

– Preservation of Earnings Before Interest and Taxes (EBIT)

Manufacturer Impact Analysis: Markup Scenar

Lower Bound

Profitability Scenario

(Most Severe for Manufacturers)

Upper Bound

Profitability Scenario

(Least Severe for Manufactu

Preservation of EBIT Markup Scenario Preservation of Gross Margin S
89

Manufacturer Impact Analysis: Industry INPV R

Summary of TSL 3:

• Expected INPV change of ‐23.5 percent.

• Conversion costs total $42.2M for the industry.

• Over 90 percent of conversion costs at TSL 3 can be attribut

capital investments. As such, the lack of significant recapita

TSL 3 mitigates the risk of disruption to manufacturing capa

up to the standards compliance date.

Summary of Results

Units Base Case

Trial Standard Level

1 234

INPV 2012$ Millions $101.8 $93.1 to $93.4 $88.2 to $89.0 $77.9 to $80.9 $71.3 t

$82.2 

Change in

INPV

2012$ Millions ‐ $(8.4) to $(8.7) $(12.8) to $(13.6) $(20.9) to $(23.9) $(19.6) 

$(30.5

(%) ‐ (8.2)% to (8.5)% (12.6)% to (13.4)% (20.5)% to (23.5)% (19.2)% 

(30.0)% 

Total

Conversion

Costs

2012$ Millions ‐ $17.4 $26.6 $42.2 $51.2 
90

• The Small Business Administration (SBA) has set a size threshold 

employees or less for the category “Air‐Conditioning and Warm A

Equipment and Commercial and Industrial Refrigeration Equipme

Manufacturing,” which includes ice‐making machinery manufactu

• DOE searched several publicly available databases to identify any 

domestic small business manufacturers.

– SBA, DOE’s Compliance Certification Management System (CCMS), v

association lists, and Hoovers.

• DOE identified seven domestic small business manufacturers of A

Manufacturer Impact Analysis: Small Business 
91

• Using the GRIM, DOE modeled the impacts on small business ma

– Expected INPV change of up to ‐78.6 percent (‐23.5 percent for the 

industry).

– Driven by lower shipment volumes relative to investments.

– The estimated impact on small business manufacturers is offset by t

energy conservation standards regulations only affect the portion of 

business revenues attributed to covered equipment. Where most sm

are primarily engaged in the production of industrial ice making equ

falls outside the scope of this rulemaking, the level of impact on tot

business revenues is expected to be lower.

Manufacturer Impact Analysis: Small Business 
92

Manufacturer Impact Analysis: Small Business 

Item 13: DOE requests comment on the magnitude of poimpacts of amended standards on small business manufacturers of automatic commercial ice makers.

Item 13: DOE requests comment on estimated capital aequipment conversion costs for small business manufacof automatic commercial ice makers.Item 13: DOE requests comment on estimated shipmenautomatic commercial ice makers produced by small busmanufacturers.
93

• At TSL 3, the vast majority of design options consist of componen

does not expect any significant change in employment if total ind

shipments remain stable. As a result, DOE expects minimal chang

employment.

Manufacturer Impact Analysis: Employment Im

Summary of Results

Units Base Case

Trial Standard Level

1234

Domestic Production Employment

in 2018 (#) 268 268 268 269 26

Item 23: DOE requests comment on the estimated impadomestic production employment for manufacturers of automatic commercial ice makers.
94

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment3 Engineering Analysis

4 Markups and Energy Use Analysis5 Life‐Cycle Cost and Payback Period Analysis6 Shipments, NIA, RIA, and MIA Analysis

7 Emissions, Utility, and Employment Impacts

8 Results and Proposed Standards
95

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
96

Emissions Analysis• DOE estimates the cumulative emissions reductions resu

amended energy conservation standards. DOE considers 

cycle emissions. Thus, both power plant emissions and “u

emissions are included in the analysis.

• Emissions analysis detail can be found in TSD chapter 13.

Emissions

TSL

12 3 4 

CO2 (million metric tons) 3.72 6.94 14.57 19.37 

NOx (thousand tons) 2.22 4.14 8.69 11.56 Hg (tons) 0.01 0.01 0.02 0.03 N2O (thousand tons) 0.08 0.15 0.32 0.42 CH4 (thousand tons) 19.36 36.09 75.77 100.75 1SO2 (thousand tons) 5.35 9.98 20.95 27.86 
97

Emissions Analysis: Monetization• DOE uses the most current Social Cost of Carbon (SCC) values d

interagency process.

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

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

productivity loss, human health effects, property damage from ris

and changes in the ecosystem.

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

for emissions in 2015 are $11.8, $39.7, $61.2, and $117.0 per m

avoided (2012 dollars).

– The SCC in constant dollars increases over time.

• DOE also monetizes the NOx emissions reductions resulting fro

standards. The medium estimate is $2,639 per ton of NOx.

• Emissions Monetization Analysis details can be found in TSD ch
98

Emissions Analysis: Monetization

Item 16: DOE solicits comment on the application of the SCC values used to determine the social benefits of COemissions reductions over the rulemaking analysis perio(The rulemaking analysis period covers from 2018 to 204plus the appropriated number of years to account for the lifetime of the equipment purchased between 2018 and 2In particular, the agency solicits comment on the agencyderivation of SCC values after 2050 where the agency athe average annual growth rate of the SCC estimates in 2040−2050 associated with each of the four sets of valu
99

Emissions Monetization Results

Global Present Value of CO2 Reduction (million 20

* For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, 

and $117.0 per metric ton (2012$).

TSL

SCC Case*

5% discount

rate, average*

3% discount

rate, average*

2.5% discount

rate, average*

3% 

ra

pe

Million 2012$

1 26.1 118.2 187.4 2 48.7 220.4 349.3 3 102.3 462.6 733.2 14 136.0 615.1 974.9 15 143.4 648.8 1,028.3 2
100

Emissions Monetization Results

Present Value of NOx Reduction (million 2012

Note: Based on medium estimate: $2639 per ton

TSL

3% discount rate 7% discount rate

Million 2012$

1 2.5 0.82 4.6 1.43 9.6 3.04 12.8 4.05 13.5 4.3
101

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
102

Utility Impact Analysis• Purpose

– To estimate the changes in electric installed capacity and g

result for each TSL.

• Method

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

period.

– NEMS is modified to represent the impacts of DOE’s standa

(modified code is known as NEMS‐BT).

• Output

– Reductions in total electricity generation.

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

– Changes to the mix of electricity generation by fuel type.

– Changes to total installed capacity.

• Utility analysis details can be found in TSD chapter 15.
103

Utility Impact Analysis ‐ Results

TSL

123 4 5

Installed Capacity Reduction

MW

2020 4 7 14 19 202025 16 30 63 83 882030 27 51 107 142 1502035 41 76 159 211 2232040 69 128 269 358 377

Electricity Generation Reduction

GWh

2020 100 186 391 520 5492025 271 504 1,059 1,408 1,4852030 277 516 1,083 1,440 1,5192035 285 530 1,114 1,481 1,5622040 294 548 1,150 1,529 1,613
104

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

NationalImpactAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

Final

Rule

Framework

Document

Preliminary

Analysis

NOPR
105

Employment AnalysisPurpose• To estimate the net jobs created or eliminated nationally as a c

of amended energy conservation standards. This includes direc

employment impacts.

Method• Uses the ImSET (Impact of Sector Energy Technologies) model f

evaluation of indirect employment impacts.

• The changes in equipment and energy expenditures are taken f

national impact analysis.

• Direct employment impacts to the ACIM industry are develope

manufacturer impact analysis (TSD chapter 12).

Output• Change to commercial and energy sector employment as a con

amended energy conservation standards.
106

Employment Analysis ‐ Results

Net Short‐Term Changes in Employment 2018 an

* Compliance date of standard levels is 2018.

Documentation• Employment analysis details can be found in TSD chapter 16.

Trial Standard Level 2018* 2022

1 19 to 20 100 to 1

2 36 to 40 192 to 1

3 75 to 87 431 to 4

4 44 to 91 506 to 5

5 34 to 90 518 to 5
107

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Market and Technology Assessment3 Engineering Analysis

4 Markups and Energy Use Analysis5 Life‐Cycle Cost and Payback Period Analysis6 Shipments, NIA, RIA, and MIA Analysis

7 Emissions, Utility, and Employment Impacts8 Results and Proposed Standards
108

Trial Standard Levels• TSLs are ordered in terms of energy savings.

• For ACIM equipment, DOE presents 5 composite TSL

– TSL 5: The max‐tech efficiency level

– TSL 4: Intermediate level between the max‐tech level and t

customer NPV level, subject to the requirement that the TS

must be positive

– TSL 3: Highest NPV possible at a 7% discount rate

– TSL 2: Intermediate level between TSL 3 and TSL 1

– TSL 1: 2012 ENERGY STAR level for each covered batch equ

and similar levels set for non‐covered equipment (7‐10%)

• The baseline efficiency level would be TSL 0, against 

1 through 5 are measured.
109

TSL to Efficiency Level Mapping

Equipment Class Baseline TSL1 TSL2 TSL3 TSL4 TS

IMH-W-Small-B Level 1 Level 2 Level 3 Level 5 Level 5 LevIMH-W-Med-B Level 1 Level 2 Level 2 Level 3 Level 4 LevIMH-W-Large-B*

IMH-W-Large-B-1 Level 1 Level 2 Level 2 Level 2 Level 3 Lev

IMH-W-Large-B-2 Level 1 Level 2 Level 2 Level 2 Level 3 Lev

IMH-A-Small-B Level 1 Level 2 Level 3 Level 5 Level 6 LevIMH-A-Large-B*

IMH-A-Large-B-1 Level 1 Level 2 Level 3 Level 5 Level 6 LevIMH-A-Large-B-2 Level 1 Level 2 Level 2 Level 3 Level 4 Lev

RCU-***-Large-B*

RCU-***-Large-B-1 Level 1 Level 2 Level 2 Level 3 Level 4 LevRCU-***-Large-B-2 Level 1 Level 2 Level 2 Level 3 Level 4 Lev

SCU-W-Large-B Level 1 Level 2 Level 3 Level 5 Level 6 LevSCU-A-Small-B Level 1 Level 2 Level 4 Level 6 Level 7 LevSCU-A-Large-B Level 1 Level 2 Level 4 Level 6 Level 7 LevIMH-A-Small-C Level 1 Level 2 Level 3 Level 4 Level 5 LevIMH-A-Large-C Level 1 Level 2 Level 3 Level 5 Level 6 LevSCU-A-Small-C Level 1 Level 2 Level 3 Level 4 Level 4 Lev*Standards were based on efficiency improvements at the level of the typical units.
110

TSL/Design Option Mapping

Equipment Class Baseline TSL 1 TSL 2 TSL 3 TSL 4 

Design Options for Each TSL (options are cumulative – TSL5 includes all preceding options)IMH-W-Small-B No BW Fill, 

PSC PM

Increase Comp EER, Increase Cond

Same as previous Increase Cond, BW 

Fill

BW Fill, Increase Evap, ECM PM

IMH-W-Med-B BW Fill, PSC 

PM

Increase Comp EER

Same as previous Increase Comp EER, 

Increase Cond

Increase Comp EER, ECM PM, DWHX

IMH-W-Large-B1 BW Fill, PSC 

PM

Increase Comp EER, Increase Cond

Same as previous Same as previous Increase Cond, ECM 

PM, DWHX

IMH-W-Large-B2 BW Fill, PSC 

PM

Increase Comp EER, Increase Cond

Same as previous Same as previous ECM PM, DWHX 

IMH-A-Small-B BW Fill, PSC 

PM, SPM FM

Increase Comp EER, Increase Cond, Increase Evap

Increase Evap Increase Evap, PSC 

FM, ECM FM, Increase Cond

Increase Cond, ECM PM, DWHX

IMH-A-Large-B1 BW Fill, PSC 

PM, SPM FM

PSC FM, Comp EER

Increase Comp EER

Increase Comp EER, BW Fill, ECM PM, ECM FM, Increase Cond

Increase Cond, DWHX

IMH-A-Large-B2 BW Fill, PSC 

PM, SPM FM

Increase Comp EER, PSC FM

Same as previous PSC FM, Increase 

Cond

ECM FM, ECM PM, DWHX

SPM = Shaded Pole MotorPSC = Permanent Split Capacitor MotorECM = Electronically Commutated MotorFM = Fan Motor (Air-Cooled Units)PM = Pump Motor (Batch Units)

BW Fill = Batch Water Fill Option Included Increase Cond = Increase in Condenser SizeIncrease Evap = Increase in Evaporator SizeIncrease Comp EER = Increase in Compressor EER

DWHX = Addition of DrainwaExchangerAM = Auger Motor (Continuo
111

TSL/Design Option Mapping

Equipment Class Baseline TSL 1 TSL 2 TSL 3 TSL 4 

Design Options for Each TSL (options are cumulative – TSL5 includes all preceding options)RCU-Large-B1 BW Fill, PSC 

PM, PSC FM

Increase Comp 

EER

Same as previous Increase Comp EER, 

Increase Cond, ECM 

FM

ECM FM, Increase 

Cond, ECM PM, 

DWHX

RCU-Large-B2 BW Fill, PSC 

PM, PSC FM

Increase Comp 

EER, Increase 

Cond

Same as previous ECM PM

Increase Cond

Increase Cond, 

ECM FM, DWHX

SCU-W-Large-B No BW Fill, 

PSC PM

BW Fill BW Fill, Increase 

Comp EER, 

Increase Cond

Increase Cond, ECM 

PM

ECM PM, DWHX 

SCU-A-Small-B No BW Fill, 

PSC PM, SPM 

FM

PSC FM, 

Increase Cond

Increase Cond, Increase Comp 

EER

Increase Comp EER, 

BW Fill

BW Fill, ECM PM, 

ECM FM, DWHX

SCU-A-Large-B No BW Fill, 

PSC PM, SPM 

FM

Increase Comp 

EER

Increase Comp 

EER, Increase 

Cond, BW Fill

BW Fill, PSC FM, 

ECM FM, ECM PM

ECM PM, DWHX 

IMH-A-Small-C PSC AM, SPM 

FM

PSC FM, 

Increase Comp 

EER

PSC FM, Increase 

Comp EER

Increase Comp EER, 

Increase Cond, ECM 

FM

ECM FM, ECM AM 

IMH-A-Large-C PSC AM, SPM 

FM

Increase Cond, Increase Comp 

EER

Increase Comp 

EER

Increase Comp EER, 

PSC FM, ECM FM

ECM FM, ECM AM 

SCU-A-Small-C PSC AM, SPM 

FM

Increase Cond Increase Cond, 

Increase Comp 

EER

Increase Comp EER, 

PSC FM

Same as previous 

SPM = Shaded Pole MotorPSC = Permanent Split Capacitor MotorECM = Electronically Commutated MotorFM = Fan Motor (Air-Cooled Units)PM = Pump Motor (Batch Units)

BW Fill = Batch Water Fill Option Included Increase Cond = Increase in Condenser SizeIncrease Evap = Increase in Evaporator SizeIncrease Comp EER = Increase in Compressor EER

DWHX = Addition of DrainwAM = Auger Motor (Continuo
112

TSL/Design Option Mapping

Item 18: Section V.A.1 of the NOPR discusses the desigoptions associated with each TSL, for each analyzed proclass. DOE requests comment and data related to the reequipment size increases associated with the design opat each TSL levels. Chapter 5 of the NOPR TSD containdescriptions of the design options and DOE’s analyses fequipment size increase associated with the design optiselected. DOE also requests comments and data on the efficiency gains associated with each set of design optioChapter 5 of the NOPR TSD contains DOE’s analyses oefficiency gains for each design option considered. FinalDOE requests comment and data on any utility impacts associated with each set of design options, such as poteice-style changes.
113

Proposed Standards for Batch Type Equipment

Equipment 

Type

Type of 

Cooling

Harvest Rate

lb ice/24 hr

Maximum Energy Use

kilowatt-hours (kWh)/100 

lb ice*

Maximum Conde

Water Use

gal/100 lb ice

Ice-Making Head

Water <500 5.84 – 0.0041H 200-0.022H

≥500 and <1,436 3.88 – 0.0002H 200-0.022H

≥1,436 and 

<2,500

3.6 200-0.022H

≥2,500 and 

<4,000

3.6 145

Ice-Making Head

Air <450 7.70 – 0.0065H NA

≥450 and <875 5.17 – 0.0008H NA

≥875 and <2,210 4.5 NA

≥2,210 and 

<2,500

6.89 – 0.0011H

≥ 2,500 and 

<4,000

4.1

Remote Condensing (but not remote compressor)

Air <1,000 7.52 – 0.0032H NAAir ≥1,000 and 

<4,000

4.3 NA

Remote Condensing and Remote Compressor

Air <934 7.52 – 0.0032H NAAir ≥934 and <4,000 4.5 NA

Self-Contained Water <200 8.55 – 0.0143H 191-0.0315H

≥200 and <2,500 5.7 191-0.0315H

≥2,500 and 

<4,000

5.7 112

Self-Contained Air <175 12.6 – 0.0328H NA

≥175 and <4,000 6.9 NA

* H = harvest rate in pounds per 24 hours, indicating the water or energy use for a given harvest rate. Source: 42 U.S.C. ** Water use is for the condenser only and does not include potable water used to make ice.
114

Proposed Standards for IMH‐A‐B Equipment
115

Proposed Standards for Continuous Type Equip

Equipment Type

Type of 

Cooling

Harvest Rate

lb ice/24 hr

Maximum Energy Use

kWh/100 lb ice*

Maximum C

gal/10

Ice-Making Head Water <900 6.08 – 0.0025H 160-

≥900 and <2,500 3.8 160-

≥2,500 and 

<4,000

3.8 

Ice-Making Head Air <700 9.24 – 0.0061H 

≥700 and <4,000 5.0 

Remote Condensing (but not remote compressor)

Air <850 7.5 – 0.0034H 

≥850 and <4,000 4.6 

Remote Condensing and Remote Compressor

Air <850 7.65 – 0.0034H 

≥850 and <4,000 4.8 

Self-Contained Water <900 7.28 – 0.0027H 153-

≥900 and <2,500 4.9 153-

≥2,500 and 

<4,000

4.9 

Self-Contained Air <700 9.2 – 0.0050H 

≥700 and <4,000 5.7 

* 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).

** Water use is for the condenser only and does not include potable water used to make ice.
116

How to Submit Written Comments

In all correspondence, please refer to the ACIM rulemaking by:

– NOPR for Energy Conservation Standards for Automatic Com

Makers

– Docket Number EERE‐2010‐BT‐STD‐0037

– Regulation Identification Number (RIN) 1904‐AC39

Email: ACIM‐2010‐STD‐0037@ee.doe.gov

Postal: CourierMs. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies Prog

Mailstop EE‐2J 950 L’Enfant Plaza SW, Suit

1000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585‐0121 Tel: 202 586‐2945

Comment period closes May 16, 2014, 11:59 PM 
117

Supporting Slides

SUPPORTING SLIDES
118

Technology Assessment – Alternative Refrigera• Most ACIM equipment uses R‐404A refrigerant (with 

contained units (SCU) using R‐134A); DOE conducted 

using R‐404A in its models.

• Stakeholders commented on whether hydrocarbon r

can be considered a design option, but DOE notes th

refrigerants have not been approved by the U.S. Env

Protection Agency SNAP program and cannot be con

• DOE acknowledges there are government‐wide effor

reduce emissions of hydrofluorocarbons, and such a

being pursued through both international diplomacy 

domestic actions.
119

Technology Assessment – Alternative Refrigera

Item 24: To the extent that there has been experience the industry, domestically or internationally, with the usalternative low global warming potential refrigerants, Drequests any available information, specifically cost anefficiency information relating to use of alternative refrig