Energy Conservation Standards 

Rulemaking Framework Document for 

Wine Chillers and Miscellaneous Refrigeration Products 

U.S. Department of Energy 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

February 6, 2012 

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TABLE OF CONTENTS 

1. INTRODUCTION .............................................................................................................. 2
 

1.1 The Appliances and Commercial Equipment Standards Program .......................................2
 

1.2 Scope of Coverage ...............................................................................................................4
 

1.2.1	 Coverage ................................................................................................................. 4
 

1.2.2	 Product Definitions ............................................................................................... 12
 

1.2.3	 Hybrid Products .................................................................................................... 13
 

1.2.4	 Refrigeration Products Using Either AC or DC Electricity .................................. 16
 

1.2.5	 Other Residential Refrigeration Products ............................................................. 17
 

1.2.6	 Combined Coverage of Wine Chillers used in both Residential and Commercial 

Applications .......................................................................................................... 18
 

1.2.7	 Near-Freezers........................................................................................................ 20
 

1.2.8	 Test Procedures..................................................................................................... 21
 

1.3	 Overview of the Rulemaking Process ................................................................................25
 

1.3.1 Preliminary Analysis ............................................................................................. 26
 

1.3.2	 Notice of Proposed Rulemaking ........................................................................... 28
 

1.3.3	 Final Rule.............................................................................................................. 28
 

1.3.4	 Acceleration of Rulemaking Timeline .................................................................. 29
 

2.	 OVERVIEW OF ANALYSES FOR RULEMAKING..................................................... 29
 

3.	 MARKET AND TECHNOLOGY ASSESSMENT ......................................................... 31
 

3.1	 Market Assessment ............................................................................................................31
 

3.2	 Product Classes ..................................................................................................................31
 

3.3	 Technology Assessment .....................................................................................................32
 

4.	 SCREENING ANALYSIS ............................................................................................... 34
 

5.	 ENGINEERING ANALYSIS........................................................................................... 35
 

5.1	 Engineering Analysis Overview ........................................................................................35
 

5.2	 Baseline Models.................................................................................................................36
 

5.3	 Approach for Determining the Cost-Efficiency Relationship ...........................................37
 

5.4	 Efficiency Levels ...............................................................................................................39
 

5.5	 Proprietary Designs............................................................................................................41
 

5.6	 Outside Regulatory Changes Affecting the Engineering Analysis ....................................42
 

6.	 MARKUPS FOR EQUIPMENT PRICE DETERMINATION ........................................ 42
 

7.	 ENERGY USE DETERMINATION................................................................................ 44
 

8.	 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ...................................... 46
 

8.1	 Approach for Conducting the LCC and PBP Analysis ......................................................46
 

8.2	 Electricity Prices ................................................................................................................48
 

8.3	 Maintenance, Repair, and Installation Costs......................................................................49
 

8.4	 Product Lifetimes ...............................................................................................................49
 

8.5	 Discount Rates ...................................................................................................................50
 

9.	 SHIPMENTS ANALYSIS................................................................................................ 50
 

9.1	 Base-Case Forecast ............................................................................................................51
 

9.2	 Standards Impacts on Product Shipments..........................................................................52
 

10.	 NATIONAL IMPACT ANALYSIS ................................................................................. 53
 

10.1	 Inputs to NES and NPV Forecasts .....................................................................................53
 

10.2	 National Energy Savings....................................................................................................54
 

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10.3 Net Present Value ..............................................................................................................55
 

11. LIFE-CYCLE COST SUBGROUP ANALYSIS ............................................................. 55
 

12. MANUFACTURER IMPACT ANALYSIS..................................................................... 56
 

12.1 Sources of Information for the Manufacturer Impact Analysis .........................................56
 

12.2 Industry Cash Flow Analysis.............................................................................................57
 

12.3 Manufacturer Subgroup Analysis ......................................................................................58
 

12.4 Competitive Impacts Assessment ......................................................................................58
 

12.5 Cumulative Regulatory Burden .........................................................................................59
 

13. UTILITY IMPACT ANALYSIS...................................................................................... 60
 

14. EMPLOYMENT IMPACT ANALYSIS .......................................................................... 60
 

15. EMISSIONS ANALYSIS................................................................................................. 61
 

15.1 Carbon Dioxide..................................................................................................................62
 

15.2 Sulfur Dioxide....................................................................................................................62
 

15.3 Nitrogen Oxides.................................................................................................................62
 

15.4 Mercury..............................................................................................................................63
 

15.5 Particulate Matter...............................................................................................................63
 

16. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS ...... 64
 

17. REGULATORY IMPACT ANALYSIS........................................................................... 65
 

LIST OF TABLES 

Table 1.1 Wine Chiller Sales-Weighted Average UEC Estimates 8
 

Table 1.2 Wine Chiller Shipments Estimates for 2009 8
 

Table 1.3 Wine Chiller NEC Estimates 9
 

Table 1.4 Product Definitions Applicable to Different Compartment Combinations in a Residential
 

Refrigeration Product 14
 

Table 3.1 Residential Wine Chiller and Miscellaneous Refrigeration Product Classes 32
 

Table 3.2 Wine Chiller and Miscellaneous Refrigeration Product Technologies 34
 

Table 5.1 Wine Chiller California and Canadian Energy Conservation Standards and Proposed Baseline 

Model Efficiencies 37
 

LIST OF FIGURES 

Figure 2.1 Flow Diagram of Analyses for the Wine Chiller and Miscellaneous Refrigeration Product
 

Standards Rulemaking Process 30
 

Figure 5.1 Wine Chiller Efficiency Data 40
 

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LIST OF ACRONYMS 

AEO Annual Energy Outlook 

AHAM Association of Home Appliance Manufacturers 

ANSI American National Standards Institute 

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

BT Building Technologies Program 

Btu British thermal units 

CEC California Energy Commission 

CEE Consortium for Energy Efficiency 

CFC chlorofluorocarbon 

CFR Code of Federal Regulations 

CO2 carbon dioxide 

COP Coefficient of performance 

CSL candidate standard level 

DOE U.S. Department of Energy 

DOJ U.S. Department of Justice 

EER energy efficiency ratio 

EERE Office of Energy Efficiency and Renewable Energy 

EIA Energy Information Administration 

EISA Energy Independence and Security Act of 2007 

EPACT Energy Policy Act of 2005 

EPA U.S. Environmental Protection Agency 

EPCA Energy Policy and Conservation Act 

FR Federal Register 

GRIM Government Regulatory Impact Model 

GWP global warming potential 

HCFC hydrochlorofluorocarbon 

HFC hydrofluorocarbon 

IEC International Electrotechnical Commission 

ImSET Impact of Sector Energy Technologies 

kWh kilowatt-hour 

LCC life-cycle cost 

NAECA National Appliance Energy Conservation Act of 1987 

NECPA National Energy Conservation Policy Act of 1978 

NEMS National Energy Modeling System 

NES national energy savings 

NIST National Institute of Standards and Technology 

NOPR notice of proposed rulemaking 

NOx oxides of nitrogen 

NPV net present value 

NRCan Natural Resources Canada 

PBP payback period 

PNNL Pacific Northwest National Laboratory 

R&D research and development 

RECS Residential Energy Consumption Survey 

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RoHS Reduction of Hazardous Substances directive 

SEC Securities and Exchange Commission 

SG&A selling, general, and administrative costs 

SO2 sulfur dioxide 

SWEF shipment-weighted efficiency 

TBD to be determined 

TSD technical support document 

TSL trial standard level 

TTAF test temperature adjustment factor 

TTD through-the-door 

U.S. United States 

U.S.C. United States Code 

iv 
 

Rulemaking Framework Document for 

Wine Chillers and Miscellaneous Refrigeration Products 

1. INTRODUCTION 

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

Program, within the Office of Energy Efficiency and Renewable Energy (EERE) Building 

Technologies Program (BT), develops and promulgates test procedures and energy conservation 

standards for consumer appliances and commercial equipment. The process for developing 

standards involves analysis, public notice, and consultation with interested parties. Such parties, 

known as stakeholders, 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. 

This framework document describes DOE’s anticipated procedural and analytical approaches for 

evaluating energy conservation standards for residential wine chillers and miscellaneous 

refrigeration products. 

This document is also designed to inform stakeholders of the process that DOE plans to follow 

when evaluating potential standards for residential wine chillers and miscellaneous refrigeration 

products and to encourage and facilitate stakeholder input during that process. This document 

serves as the starting point for the potential development of standards and is not a definitive 

statement about any issue that this action will determine. 

Section 1 provides an overview of the rulemaking process. Sections 2 through 17 discuss DOE’s 

projected analyses for fulfilling the statutory requirements and guidance for this potential 

standards rulemaking. 

Information about this action will be maintained on the DOE website at: 

http://www.eere.energy.gov/buildings/appliance_standards. 

DOE invites stakeholder comments on all aspects of the material presented in this 

document. This comment box and others highlight issues on which DOE seeks comment 

and requests feedback from interested parties. DOE uses these comment boxes to ask 

specific questions about the approaches that it proposes to follow for the analyses required 

for the standards rulemaking. Such requests for stakeholder feedback are numbered 

according to the section in which they appear. 

1.1 The Appliances and Commercial Equipment Standards Program 

The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163 (42 United States 

Code (U.S.C.) §§ 6291–6309), established an energy conservation program for major household 

appliances. The National Energy Conservation Policy Act of 1978 (NECPA), Pub. L. 95-619, 

2
 
 

 

amended EPCA to add Part C1 of Title III (42 U.S.C. § 6311–6317), which established an energy 

conservation program for certain industrial equipment. Additional amendments to EPCA gave 

DOE the authority to regulate the energy efficiency of several products, including residential 

refrigerators, refrigerator-freezers, and freezers, referred to as residential refrigeration products. 

The products that are the focus of this document are a subset of refrigerators and/or refrigeratorfreezers. The amendments to EPCA in the National Appliance Energy Conservation Act of 1987 

(NAECA), Pub. L. 100-12, established energy conservation standards for residential refrigeration 

products, as well as requirements for determining whether these standards should be amended. 

(42 U.S.C. § 6295(b)) 

While EPCA does not define these products, it provides certain criteria that these products must 

meet. See 42 U.S.C. § 6292(a)(1). Under this provision, these products must operate using 

alternating current electricity, use a compressor/condenser-based system that is integral with the 

cabinet assembly and be designed to be used with doors. EPCA also provides DOE with the 

authority to cover other products with energy conservation standards so long as certain other 

criteria are met. See 42 U.S.C. § 6292(b). As a result, those refrigeration products that fall 

outside of the prescribed criteria detailed in 42 U.S.C. § 6292(a)(1) could be covered through the 

provisions laid out in 42 U.S.C. § 6292(b). 

NAECA first established performance standards for residential refrigeration products, and 

further required that DOE conduct two cycles of rulemakings to determine if more stringent 

standards are justified. (42 U.S.C. § 6295(b)) On November 17, 1989, DOE published a final 

rule in the Federal Register updating the performance standards previously set by NAECA. 

Those standards became effective on January 1, 1993. 54 FR 47916. DOE updated the 

performance standards again on April 28, 1997. 62 FR 23102. The new standards became 

effective on July 1, 2001. By completing a second standards rulemaking, DOE had fulfilled its 

legislative requirement to conduct the two cycles of standards rulemakings required under 

NAECA. 

The Energy Independence and Security Act (EISA), Pub. L. No. 110-140 (December 19, 2007), 

required that DOE publish a final rule determining whether to amend the standards in effect for 

residential refrigeration products starting in 2014. Consistent with this requirement, DOE 

published a final rule on September 15, 2011. 76 FR 57516. The new standards take effect on 

September 15, 2014. 

As part of this recent rulemaking, DOE addressed the coverage of wine chillers. 75 FR 59470, 

59486 (September 27, 2010). Wine chillers currently are not covered because they are not 

designed to be capable of achieving compartment temperatures below the 39  ̊F limit specified in 

the definition for “electric refrigerator.” (see 10 CFR 430.2) DOE chose to treat wine chillers 

separately from refrigerators in part because of their different purpose and performance 

characteristics. As a result, DOE modified the definition for refrigerators to ensure sufficient 

coverage over those products that were designed to safely store food (i.e. refrigerators) and 

indicated that the coverage of wine chillers would be considered by DOE under a separate, future 

rulemaking. Id. Today’s framework document begins the process of examining the possible 

regulation of wine chillers, as well as other residential refrigeration products that are not yet 

1 Part C has been redesignated Part A-1 

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covered, but which fit the EPCA coverage requirements -- namely, those products that are 

designed to be used with doors which include a compressor and condenser unit as an integral part 

of the cabinet assembly, and which operate on alternating current electricity. (42 U.S.C. § 

6292(a)(1)). 

1.2 Scope of Coverage 

1.2.1 Coverage 

Currently, there are no energy conservation standards for wine chillers and the other types of 

related refrigeration products that fall into the categories described in 42 U.S.C. § 6292(a)(1). 

Wine chillers that use a conventional compressor/condenser system are not covered by energy 

conservation standards for refrigerators, refrigerator-freezers, and freezers, largely because they 

are not designed to be capable of achieving compartment temperatures colder than the 39  ̊F limit 

specified in the definition for electric refrigerator. As pointed out earlier, DOE opted to not 

establish energy conservation standards for wine chillers during the 2010-2011 rulemaking and 

to address those products separately. See 75 FR 59470, 59486 (September 27, 2010). However, 

many of these products are consistent with the requirements of 42 U.S.C. § 6292(a)(1) and 

hence, DOE has authority to extend coverage to and develop energy conservation standards for 

them. 75 FR at 59486. 

EPCA does not define the term “refrigerator”. To address this gap, DOE previously defined the 

term to include an upper temperature limit. DOE took this action in its 2001 final rule. 66 FR 

57845. This limit was specifically applied to clarify that the energy conservation standards for 

refrigerators did not apply to wine chillers after manufacturers of these products submitted 

petitions for exemption. Id. at p. 57846. 

DOE further modified the electric refrigerator definition in 2010. 75 FR 78810 (December 16, 

2010). This modification, which was based on recommendations suggested by stakeholders, 

established a more distinct delineation between products covered by the existing standards and 

products DOE intended to exclude from coverage at that time. Specifically, the definition makes 

clear that products that are not designed to achieve storage temperatures below 39  ̊F are 

excluded, thus avoiding unintentional non-coverage of products designed for storage 

temperatures below 39  ̊F that may reach temperatures above 39  ̊F at warm temperature settings. 

Wine chillers fall into the category of products that are not designed to achieve storage 

temperatures below 39  ̊F, as do some other refrigeration products, such as some beverage 

centers and coolers. 

The current action is examining how to address and establish coverage consistent with EPCA 

requirements for all residential refrigeration products DOE does not currently regulate. 

1.2.1.1 Potential Exclusion of Thermoelectric and Absorption Units 

Because of the limitations Congress included in the coverage provision of EPCA related to 

refrigerators, refrigerator-freezers, and freezers, DOE cannot regulate these products using those 

energy conservation standards that have already been promulgated. See 42 U.S.C. § 6292(a)(1) 

(denoting the criteria that residential refrigeration products must have, including a condenser and 

compressor integrated into the unit’s cabinetry). Because of these criteria, neither absorption nor 

4
 
thermoelectric products, would be covered because these products do not use a compressor and 

condenser system. 

Notwithstanding these limitations, however, EPCA permits DOE to add products to its coverage 

if it first makes certain findings -- that coverage is necessary and appropriate for carrying out the 

purposes of EPCA and that the products are likely to exceed an average annual energy use 

threshold per household of 100 kilowatt-hours. See 42 U.S.C. § 6292(b). Satisfying these 

elements is an initial prerequisite in order to classify a product as covered. It is through the 

application of this provision that DOE is considering the coverage of these other miscellaneous 

residential refrigeration products. 

Absorption-based refrigeration products work by using a heat source, powered either by 

electricity or fuel (e.g. natural gas or propane), to provide the energy needed to drive the cooling 

system. Absorption refrigeration products use the ammonia-water absorption cycle to cool the 

storage cabinet. These types of products have been produced for many decades. Electrically 

powered absorption refrigeration devices are used by the hotel industry for in-room refrigeration 

cabinets as they are much quieter than compressor-based units, while gas or propane units are 

designed for use in mobile applications and remote locations that do not have access to 

electricity. However, due to their specific purpose and generally higher cost (generally at least 

twice the cost as compared with vapor compression units), DOE believes it is unlikely that they 

represent any significant market share in the residential refrigeration market. 

In contrast, thermoelectric residential refrigeration products are widely available. These types of 

products are powered by electric input and operate using solid-state thermoelectric cooling 

devices. Current thermoelectric cooling systems are generally less efficient than the vapor 

compression systems used in most residential refrigeration products (e.g., see Refrigerators, 

Refrigerator-Freezers, and Freezers, Energy Conservation Rulemaking, Technical Support 

Document, Chapter 4, page 4-12, 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/refrig_finalrule_tsd.pdf) 

Thermoelectric technology is used mostly in products that do not maintain very low 

compartment temperatures, in particular wine chillers and “coolers”, although some “true” 

refrigerators (i.e. refrigerators that are capable of achieving storage temperature below 39  ̊F) use 

it as well. A number of thermoelectric wine chillers have recently been introduced to the market. 

1.2.1.2 Establishing Energy Conservation Standards for Thermoelectric Products 

DOE considered whether coverage and energy conservation standards could be established for 

thermoelectric products, under the following options: 

1.	 Initiate a rulemaking to establish standards and a test procedure for vapor compression wine 

chillers and miscellaneous residential refrigeration products under DOE’s existing authority 

for refrigerators in EPCA (42 U.S.C. § 6292 (a)(1)) and initiate a separate rulemaking to 

establish coverage for thermoelectric products under the provisions of 42 U.S.C. § 

6292(a)(20) (“Any other type of consumer product which the Secretary classifies as a 

covered product under subsection (b) of this section.”), or 

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2.	 Initiate a coverage rulemaking to establish coverage for all wine chillers and miscellaneous 

residential refrigeration products, both vapor compression and thermoelectric, and possibly 

also absorption-based products, under 42 U.S.C. § 6292(a)(20). 

As described above, many wine chillers and related refrigeration products that do not fit the 

current definition for “refrigerator” do fit the requirements of 42 U.S.C. § 6292(a)(1), and DOE 

has authority to extend coverage to and develop energy conservation standards for them. 

Specifically, DOE would do this by modifying the definitions for “refrigerator” and/or “electric 

refrigerator”. Once covered, these products are subject to energy conservation standards, as 

defined in 42 U.S.C. § 6295(b) and the Code of Federal Regulations (CFR), specifically 10 CFR 

430.32(a), although DOE must determine whether new product classes must be established to 

address the products covered through the potential coverage extension. 

In contrast, establishing coverage for refrigeration products that do not fit the requirements of 42 

U.S.C. § 6292 (a)(1) would necessitate a determination that such coverage is necessary or 

appropriate to carry out the purposes of EPCA and the average annual energy use of the product 

is 100 kWh or greater. 42 U.S.C. § 6292(b)(1) Further, additional requirements must be satisfied 

if DOE wishes to establish energy conservation standards for such products. 42 U.S.C. § 6295 

(l)(1) These requirements include: (a) a minimum average annual per household energy use 

associated with the product of 150 kWh and (b) an aggregate national annual energy use of 4.2 

billion kWh. (42 U.S.C. § 6295(l)(1)(A, B)) 

DOE’s estimates of aggregate national energy use, described in section 1.2.1.3, do not 

convincingly show that requirement (b) would be satisfied by those refrigeration products that 

cannot satisfy the design requirements of 42 U.S.C. § 6292(a)(1). While per household annual 

energy use is expected to be well above 150 kWh for these products2

, it is not apparent based 

upon available shipment data for wine chillers that aggregate national energy use reaches the 4.2 

billion kWh threshold. It is for this reason that DOE considered coverage option 2 listed 

above—in order to allow consideration of a larger group of products when evaluating aggregate 

national energy use, thus increasing the possibility of satisfying the requirement. 

However, DOE tentatively concluded that option 2 above is not viable because refrigeration 

products with integral compressors and condensers (i.e. those products that satisfy the 

requirements of 42 U.S.C. § 6292 (a)(1)) are already covered under EPCA. Accordingly, option 

2 -- coverage under 42 U.S.C. §6292(a)(20) -- does not apply.. 

1.2.1.3 Per-Unit and National Energy Use of Wine Chiller Products 

Not all information required to accurately estimate the national energy use of wine chillers, 

especially thermoelectric products, is publicly available. Because DOE is required by statute to 

determine the per-unit annual energy consumption (UEC) and the national energy consumption 

(NEC) of wine chillers in order to establish coverage for them, as well as to set energy efficiency 

2

 See, for example, information about the EdgeStar thermoelectric wine chiller model TWR215ESS, which indicates 

that this model uses 1.2 kWh per 24 hours, or 438 kWh per year 

(http://www.edgestar.com/products/winecooler/twr215ess.asp) 

6
 
 

 

standards, DOE developed preliminary UEC and NEC estimates of vapor compression and 

thermoelectric wine chillers. 

Because of the limited available data regarding absorption-based products, DOE could only 

develop a broad range of UECs for vapor compression and thermoelectric products. DOE based 

the UEC of vapor compression wine chiller products on California’s maximum energy use 

standards defined by the California Energy Commission (CEC)3

 as well as sales data purchased 

from the NPD Group4, a marketing research firm. Each set of data provided DOE with insight 

into different aspects of these products. The CEC currently specifies a maximum allowable 

energy use for automatic- and manual-defrost wine chillers as a function of internal volume, 

which helped DOE in developing a picture of energy usage and internal volumes of those 

products that are already on the market. The NPD Group data, which covers 2007-2011 sales, 

also enabled DOE to deduce an internal volume for each listed model.. Therefore, DOE 

developed a range of vapor compression UECs for each model in the NPD database. 

For thermoelectric products, DOE estimated a range of UEC estimates based on assumed vapor 

compression (1.5 to 2.0 COP5

) and thermoelectric efficiencies (0.3 to 0.5 COP). Because web 

research indicated that most thermoelectric products have capacities of 30 bottles and less, DOE 

based its UEC estimates on two capacity categories -- (1) less than and equal to 30 bottles and 

(2) greater than 30 bottles. For thermoelectric products, estimates were derived only for the 30 

bottle and less capacity. The derived UECs for thermoelectric products ranged from 721 to 3938 

kWh. 

Due to the high estimate for the top-end of the estimated UEC range, DOE performed limited 

metering of four thermoelectric wine chillers consisting of six-, 12-, 15-, and 28-bottle 

capacities. The loading of each wine chiller metered by DOE varied; the six- and 12-bottle units 

were metered at full capacity (i.e., loaded with the maximum number of bottles), the 15-bottle 

unit was metered with a load of 12 bottles, and the 28-bottle unit was metered while empty (i.e., 

loaded without any bottles). Even though the metering was conducted in a non-controlled 

ambient environment with room temperatures varying between 65 °F and 78 °F, DOE believed 

such metered estimates would provide a reasonable approximation of typical thermoelectric wine 

chiller energy use. The measured daily energy use for the four units over the approximately onemonth time-period varied between 0.6 to 1.6 kWh per day, with the high value associated with 

the 28-bottle capacity wine chiller. Assuming wine chillers are powered year-round, i.e., 

consumers do not unplug the units for extended periods of time, the daily energy consumption 

translates into UECs of 218 to 598 kWh per year. 

Table 1.1 below summarizes the range of UEC estimates for vapor compression and 

thermoelectric wine chillers (sales-weighted values are also reported for vapor compression 

units). For vapor compression units, the UEC estimates represent the values deduced from the 

CEC maximum energy use standards and the NPD data. For thermoelectric products, DOE 

3 California Energy Commission, 2010 Appliance Efficiency Regulations, December 2010. CEC-400-2010-012. 

<http://www.energy.ca.gov/2010publications/CEC-400-2010-012/CEC-400-2010-012.PDF> 

4 NPD Group, Inc. <http://www.npd.com/corpServlet?nextpage=corp_welcome.html>
 5 Coefficient of Performance, defined as the system’s refrigerating capacity (in Watts) divided by the system power
 

input (in Watts). 

7
 
 

calibrated the derived UEC estimates to the metered data, which are significantly lower than the 

derived UEC estimates. Thus, DOE estimated a range extending from 218 kWh (the low-end of 

the metered UEC range) to 1978 kWh, which is the high-end of the metered UEC range (598 

kWh) multiplied by the ratio of the low-end derived UEC to the low-end metered UEC (721 

kWh divided by 218 kWh). Table 1.1 also reports the average UEC for thermoelectric units from 

the metered UEC range. These estimates indicate that both vapor compression and 

thermoelectric products exceed both the minimum average annual per household energy use of 

100 kWh6 required to establish coverage and the 150 kWh7 required for establishing energy 

conservation standards. 

Table 1.1 Wine Chiller Sales-Weighted Average UEC Estimates 

Capacity 

Unit Energy Consumption Range (kWh/yr) 

Vapor Compression Thermoelectric 

≤ 30 bottles 288 to 591 (348*) 218 to 1978 (408**) 

> 30 bottles 301 to 591 (375*) NA 

* Sales-weighted average. ** Average from metered UEC range. 

To establish the NEC of vapor compression and thermoelectric products, historical household 

shipments are needed. Two sources were considered -- (1) data provided by AHAM as part of 

the residential refrigerator/freezer standards rulemaking8

 and (2) retail sales data from the NPD 

Group. In both cases, shipments were assumed to be entirely to the residential sector. The 

estimates from these sources, however, vary widely, with NPD estimates being as much as ten 

times greater than AHAM’s estimates. Table 1.2 below summarizes the shipments estimates for 

2009. Because AHAM does not represent all wine chiller manufacturers, and not all of AHAM’s 

members necessarily reported their sales data, DOE believes that the shipments estimates from 

the NPD Group are likely to have been based on more comprehensive data and, as a result, are 

likely to be more representative. 

Table 1.2 Wine Chiller Shipments Estimates for 2009 

Capacity 

Shipments 

AHAM NPD Group 

≤ 30 bottles 73,800 469,736 to 704,603 

> 30 bottles 14,385 115,809 to 173,713 

Total 88,185 585,544 to 878,317 

Based on the above UEC and shipments estimates, DOE developed a simple stock accounting 

model to estimate the NEC of wine chiller products. A key factor to the model’s development 

was estimating historical shipments prior to 2005. DOE estimated that there were appreciable 

6 42 U.S.C. § 6292(b)(1)(B) 

7 42 U.S.C. § 6295(l)(1)(A) 

8

 “Aggregated Refrigerator-Freezer Shipments and Efficiency Data for DOE Refrigerator-Freezer Energy Efficiency 

Standards Rulemaking”, memorandum received from AHAM, January 16, 2009. 

8
 
shipments dating back to 1990, but if wine chillers have only recently become a desired 

consumer good, and/or parts of the market, such as thermoelectric wine chillers, established high 

sales levels only recently, then such an estimate of historical shipments would lead to an 

overestimate of NEC. Table 1.3 below summarizes the range of NEC estimates for vapor 

compression and thermoelectric products. The NEC estimates are based on two assumptions: (1) 

thermoelectric products represent 80% of wine chiller sales for capacities of 30 bottles and less 

and (2) product lifetime is 12 years. 

Table 1.3 Wine Chiller NEC Estimates 

Capacity 

2011 National Energy Consumption Range (billion kWh/yr)* 

AHAM Shipments NPD Group Shipments 

Vapor 

Compression 

Thermoelectric Vapor 

Compression 

Thermoelectric 

≤ 30 

bottles 

0.04 to 0.08 

(0.05**) 

0.12 to 1.08 

(0.22†

) 

0.28 to 0.87 

(0.41**) 

0.86 to 11.71 

(1.93†) 

> 30 

bottles 

0.04 to 0.08 

(0.05**) 

NA 0.49 to 1.44 

(0.73**) 

NA 

*Market Share of thermoelectric for capacities ≤ 30 bottles = 80%; Product lifetime = 12 years. 

** NEC based on sales-weighted average UEC. For NPD Group shipments, NEC also based on 

average shipments. 

†

 NEC based on average UEC value from metered range. For NPD Group shipments, NEC also 

based on average shipments. 

As evidenced from the above results, the NEC of thermoelectric products based on the shipments 

estimates from the NPD Group could potentially exceed the 4.2 billion kWh threshold required 

to pursue the establishment of standards. However, DOE recognizes that there is uncertainty 

associated with the UEC and shipment estimates for wine chillers, and has solicited comment 

and data on this matter in the proposed determination of coverage of non-compressor residential 

refrigeration products (proposed coverage determination). 76 FR 69147 (November 8, 2011). 

Based on the currently available information, it is unclear whether the national aggregate energy 

use exceeds 4.2 billion kWh. As a result, while DOE may be authorized to establish coverage for 

these products under 42 U.S.C. § 6292(a)(20), DOE may not be authorized to set energy 

efficiency standards for them in light of the minimum energy consumption threshold that must be 

met. However, as described above, DOE may instead pursue coverage of wine chillers and 

related products with vapor compression refrigeration technology under its existing authority -- 

for those products, DOE would have the authority to establish standards for those products 

without having to satisfy the 4.2 billion kWh requirement. These standards, however, would not 

apply to thermoelectric wine chillers, which cannot be immediately covered under the existing 

statutory coverage set by Congress for residential refrigeration products because thermoelectric 

products do not use a compressor or condenser as provided in the statute. See 42 U.S.C. 

6292(a)(1). 

9
 
1.2.1.4 California Standard Treatment of Thermoelectric Units 

DOE notes that the California wine chiller standards, unlike the statutory provision under which 

DOE must operate, do not make a distinction regarding the cooling technology used in the 

product. The California rule covers: 

(a) Refrigerators, refrigerator-freezers, and freezers that can be operated by alternating 

current electricity, including but not limited to refrigerated bottled or canned beverage 

vending machines, automatic commercial ice-makers, refrigerators with or without doors, 

freezers with or without doors, walk-in refrigerators, walk-in freezers, and water dispensers, 

but excluding the following types: 

1.	 consumer products with total refrigerated volume exceeding 39 ft3

; 

2.	 commercial refrigerators, commercial refrigerator-freezers, and commercial freezers 

with total refrigerated volume exceeding 85 ft3

; except that walk-in refrigerators and 

walk-in freezers are not excluded. 

3.	 blast chillers; and 

4.	 automatic commercial ice makers with a harvest rate less than 50 lbs./24 hours and 

automatic commercial ice makers with a harvest rate greater than 2500 lbs./24 hours. 

(California Code of Regulations, Title 20: Division 2, Chapter 4, Article 4, Section 1601(a)) 

The California regulations also (a) explain that the definitions for “refrigerator” and 

“refrigerator-freezer,” which do not include an upper temperature limit for the “refrigerator 

compartment,” include products that store wine and (b) clarify that a “wine chiller” is a 

refrigerator designed for the cooling and storage of wine. (Id., Section 1602) 

The language of these regulations suggest that these standards, including the maximum energy 

use levels, apply to thermoelectric wine coolers. However, in examining the CEC’s database, 

which contains a complete list of all products certified by manufacturers as satisfying 

California’s energy conservation standards, DOE has identified no thermoelectric units in that 

list. The absence of thermoelectric products in the CEC database suggests either that 

thermoelectric-based units do not meet California’s energy conservation standards or that 

manufacturers are not aware that they are covered by these standards. 

1.2.1.5 Establishing DOE Coverage for Thermoelectric Products 

The requirements for establishing coverage for new consumer products are less stringent than the 

requirements for establishing energy conservation standards. EPCA indicates that: 

The Secretary may classify a type of consumer product as a covered product if he 

determines that— 

(A) classifying products of such type as covered products is necessary or appropriate to 

carry out the purposes of this chapter, and 

(B) average annual per-household energy use by products of such type is likely to exceed 

100 kilowatt-hours (or its Btu equivalent) per year. 

(42 U.S.C. § 6293(b)(1)) 

10
 
As indicated above, the average per-household energy use of thermoelectric wine chillers is 

higher than the 100 kWh coverage threshold. However, establishing DOE coverage of 

thermoelectric wine chillers would preempt California’s standards for these products without 

establishing a national energy standard. Should DOE establish coverage over these products, it 

would be unclear whether this act alone would reduce national energy use because it would 

permit the sale in California of thermoelectric wine chillers that do not meet any energy 

conservation standards -- a result that has the potential to impact the level of energy savings that 

may already have been achieved by the California standards. In order to establish energy 

conservation standards at the Federal level, thermoelectric wine chillers must have an average 

per-household annual energy use of at least 150 kWh and an national aggregate annual energy 

use exceeding 4.2 billion kWh. 

1.2.1.6 Summary of Coverage Options 

The coverage options DOE considered for wine chillers and miscellaneous residential 

refrigeration products included the following: 

1) Establish coverage and energy conservation standards for vapor compression products 

under 42 U.S.C. § 6292(a)(1) by modifying product definitions for refrigerator and 

refrigerator-freezer to include these products, and either; 

a.	 Establish coverage for thermoelectric products under 42 U.S.C. § 6292(a)(20) 

(and preempt current California standards for such products), or 

b.	 Do not pursue coverage for thermoelectric units. 

2) Establish coverage for wine chillers and related products under 42 U.S.C. § 6292(a)(20), 

irrespective of the cooling technologies they use. This approach may preclude pursuit of 

energy conservation standards for any of these products because of the 4.2 billion kWh 

requirement. 

As discussed in section 1.2.1.2, DOE considered the first option to be more appropriate in terms 

of the regulatory structure for covered products that is established by EPCA. With regard to 

thermoelectric units, as discussed in section 1.2.1.3, DOE has published a proposal for coverage 

of non-compressor residential refrigeration products, which includes thermoelectric units. 76 FR 

69147 (November 8, 2011). Therefore, DOE plans to consider coverage of these products (suboption a, above), subject to the comments and data received in response to the proposal. 

Although DOE has tentatively decided to pursue the first option, it still seeks information and 

comments from stakeholders regarding the coverage of wine chillers. Some of these questions 

have also been asked in the coverage determination proposal. DOE may adjust its approach 

consistent with the input it receives from the public. 

Item 1-1 DOE requests shipment information from stakeholders for wine chillers and 

related refrigeration products. Segregation of such data is desired if possible by type of 

refrigeration technology (thermoelectric, vapor-compression, absorption), product size, 

product class, and any other relevant characteristics 

11
 
Item 1-2 DOE requests energy use data for wine chillers and related refrigeration 

products that is not readily available in public databases such as that of the CEC. DOE 

requests that the data identify model numbers or basic product information (e.g. cabinet 

volume) and that the method of determining the energy use be identified for such data, 

specifically to identify the test procedure used and/or to indicate that the data are 

estimates, field measurements, or determined by other methods. DOE requests that such 

data be segregated if possible according to refrigeration technology, product class, and/or 

product size. 

Item 1-3 DOE requests comment on its options for establishing coverage and energy 

conservation standards for wine chillers. 

1.2.2 Product Definitions 

Existing definitions for the term “wine chiller” include the following: 

AHAM HRF-1-2008 (section 3.4): “A cabinet designed and marketed exclusively for the cooling 

and storage of wine.” 

CEC-400-2006-002-REV2, Section 1602: ““Wine chiller” means a refrigerator designed for the 

cooling and storage of wine.” 

CSA 300-08, section 2: “a cabinet designed and marketed exclusively for the cooling and storage 

of wine.” 

Australia/New Zealand AS/NZS 4474.1:2007: 

Wine storage cabinet/compartment—An appliance or a compartment within an 

appliance which is specifically designed exclusively for the storage and/or long term 

maturation of wine. Key characteristics of wine storage cabinets/compartment 

include constant temperature over time, specific humidity characteristics and low 

vibration. They may be designed to have stratified temperature zones. Typical 

characteristics include— 

(i) the capability of maintaining continuously a nominated temperature (typically 

14°C to 16°C) at an ambient temperature either, above or below the nominated 

temperature usually with heating as well as cooling; 

(ii) the capability of maintaining temperatures within a variation over time of less 

than 0.5 K; 

(iii) control of the compartment humidity; and 

(iv) construction to reduce the transmission of vibration to the compartment, 

whether from the refrigerator compressor or from external source. 

DOE is considering the following definition for electric wine chiller: 

Electric wine chiller means a cabinet (a) designed for the refrigerated storage of 

beverages, non-perishable food products, and/or any other items, (b) not designed to be 

12
 
 

capable of achieving storage temperatures below 39 °F (3.9 °C), and (c) having a source 

of refrigeration requiring single phase, alternating current electric energy input only. 

This definition differs from the other definitions mentioned above since it (a) does not limit itself 

to wine storage usage, (b) is based on a specific temperature range rather than marketing 

characteristics, and (c) is otherwise more consistent with the existing DOE definition for 

refrigerator. DOE has already clarified that products marketed as wine chillers that are consistent 

with the definition for refrigerator, i.e. products that are designed for storage temperatures below 

39  ̊F, are considered refrigerators under the DOE test procedures and standards. (See, e.g. 75 FR 

78810, 78817 (December 16, 2010)). 

Further, DOE seeks to establish coverage for products that are not marketed exclusively for the 

cooling and storage of wine but that do not meet the definition for refrigerator (i.e. incapable of 

reaching temperatures below 39  ̊F) or any other covered product type. Such products might 

include, but not be limited to, those that are marketed as “beverage coolers” or “beverage 

centers”. In the interests of consistency, a term other than “wine chiller” may be appropriate to 

refer to these products if they have compartment temperatures warmer than 39  ̊F. DOE has not 

selected an alternative term, but requests comment regarding whether an alternative should be 

used, and what an appropriate term might be. 

DOE would also modify the definition for refrigerator as: “A refrigerator means an electric 

refrigerator or an electric wine chiller.” 

Further, DOE would modify the definition of compact refrigerator/refrigerator-freezer/freezer as 

follows to avoid establishing a separate compact category of wine chiller, since the majority of 

residential wine chiller sales are of products within the compact size range. 

Compact refrigerator/refrigerator-freezer/freezer means any refrigerator, refrigeratorfreezer or freezer with total volume less than 7.75 cubic feet (220 liters)(rated volume as 

determined in Appendix A1 and B1 of subpart B of this part) and 36 inches (0.91 meters) 

or less in height that is not an electric wine chiller. 

Item 1-4 DOE requests comment on the suggested definition for wine chiller and the 

modified definitions for refrigerator and compact products. 

Item 1-5 DOE requests comments from stakeholders regarding the selection of a term 

identifying the product category associated with wine chillers and related refrigeration 

products whose compartment temperatures are warmer than 39  ̊F—should they all just be 

called wine chillers? In addition, DOE seeks comment on whether multiple product 

categories are necessary to address such products. 

1.2.3 Hybrid Products 

During the refrigerator energy conservation standards and test procedure rulemakings, DOE 

became aware of products that combine wine storage compartments with refrigerator (fresh food) 

compartments and/or freezer compartments. 75 FR 78810, 78816-78817 (December 16, 2010). 

13
 
 

 

 

 

 

 

 

 

 

 

DOE clarified in its December test procedure notice that its refrigerator and refrigerator-freezer 

definitions applied to products that included one or more wine storage compartments but 

excluded those products that combined a wine chiller with a freezer. Id. at 78817. DOE did not 

develop a test procedure to address the wine storage compartments of products that are covered 

under the new refrigerator and refrigerator-freezer definitions. In early 2011, DOE provided 

guidance on how to test such products. (“Guidance with Respect to Scope of Coverage for 

Hybrid (Wine Storage) Refrigeration Products” (Feb. 10, 2011)) available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/refrigerator_definiti 

on_faq.pdf, p. 4). That guidance also indicated that test procedure waivers may need to be 

obtained if a product cannot be tested under the current test procedure. The guidance included a 

table showing a number of possible product configurations having different types of 

compartments, which is reproduced below as 

Table 1.44. 

Table 1.4 Product Definitions Applicable to Different Compartment Combinations in a 

Residential Refrigeration Product 

Compartment Types 

Freezer 

(“long 

term”) 

Freezer 

(“short 

term”) 

Freezer 

(“ice 

only”) 

Fresh 

Food 

“Wine 

Storage” 

Product Types 

COVERED PRODUCT COMBINATIONS 

All-Refrigerator 

 

 

  

Refrigerator other than an 

All-Refrigerator 

 

  

Refrigerator-Freezer  

  

Freezer 

EXAMPLES OF CURRENTLY UNCOVERED PRODUCT COMBINATIONS 

Wine Storage only 

Wine Storage with “long 

term” freezer 

 

Wine Storage with “short 

term” freezer 

 

Note: All-refrigerators with “ice-only” freezer compartments may have just one such 

compartment. DOE is not aware of the existence of such products with more than one “ice-only” 

freezer compartment and has not made a determination of the product type definition applicable 

for such a combination. 

The compartment types mentioned in the table were defined in the guidance document as 

follows: 

14
 
 

 

 

 

	 Freezer (“long-term”): a freezer compartment capable of 0  ̊F storage temperature. These 

compartments are typically found in refrigerator-freezers or freezers. 

	 Freezer (“short-term”): a freezer compartment larger than 0.5 cubic feet in volume 

capable of storage temperatures less than 32  ̊F but normally not less than 8  ̊F. These 

compartments are generally found in refrigerators other than all-refrigerators9. 

	 Freezer (“ice only”): a freezer compartment of 0.5 cubic feet capacity or less capable of 

storage temperatures less than 32  ̊F but normally not less than 8  ̊F. These compartments 

may be found in all-refrigerators. 

	 Fresh food compartment: a compartment capable of storage temperatures less than 39  ̊F, 

generally not controllable to temperatures less than 32  ̊F. 

	 “Wine storage” compartment: a compartment not capable of 39  ̊F storage temperature 

that provides warmer temperatures than 39  ̊F. Generally such compartments are designed 

for storage of wine. 

Adding a “wine storage” compartment, regardless of size, to a product that is otherwise a 

refrigerator or a refrigerator-freezer, does not change its status as a refrigerator or refrigeratorfreezer or affect its coverage. As described in the guidance, such products must be tested as 

refrigerators or refrigerator freezers, using the applicable test procedures. Depending on the 

design details of the additional “wine storage” compartment, this compartment would be tested 

as a fresh food compartment, even if it cannot attain fresh food compartment temperatures. In 

contrast, the guidance indicated that adding a wine storage compartment, regardless of size, to a 

product that is otherwise a freezer, does change its status and places it outside of coverage. This 

result is largely due to the specifics of the freezer definition and the technical operation of these 

products.10 

As indicated in the guidance, DOE recognized the limitations of its guidance and indicated that 

the agency was considering a separate rulemaking to resolve some of these limitations. This 

document initiates the process of evaluating a possible rulemaking for wine chiller products that 

would include provisions related to hybrid products. To that end, this document seeks input from 

manufacturers and other interested parties regarding hybrid products that combine wine storage 

compartments with fresh food and/or freezer compartments. 

A possible framework for addressing the issues highlighted in this section could include the 

following changes to the applicable definitions and test procedures: 

1) Setting a threshold size in cubic feet or as a percentage of total volume for a wine storage 

compartment at which a refrigerator, refrigerator-freezer, or freezer is no longer one of 

these products and becomes a “hybrid” product. 

9

 An all-refrigerator is a refrigerator that does not have a compartment for the freezing and long-term storage of food 

below 32°F, but which may have a compartment not larger than 0.5 cubic foot in size for freezing and storage of ice. 

(10 CFR part 430, subpart B, appendix A1, section 1.2) 

10 In particular, the standardized temperature for a freezer is 0  ̊F, while the standardized temperature for the fresh 

food compartment of a refrigerator-freezer is 45  ̊F under current test procedures and 39  ̊F under test procedures 

that manufacturers will need to use for compliance purposes in 2014. A wine storage compartment can be expected 

to approach a 45  ̊F temperature during testing, but approaching 0  ̊F would be extremely unlikely given the nature 

of the product. 

15
 
2) Establishing definitions for hybrid products as necessary to address product types that 

represent or are expected to soon represent significant market share. 

3) Developing test procedures for products with wine storage compartments smaller than the 

thresholds set in item (1) above for (a) setting compartment temperatures during testing, 

(b) measuring wine storage compartment temperature, (c) modifying the manner in which 

to calculate energy use based on temperatures of all compartments (which could include 

the wine storage compartment), (d) modifying the adjusted volume calculation using a 

reduced (less than 1.0) volume adjustment factor for the wine storage compartment. 

4) Applying either the current or September 2014 energy conservation standards to products 

that will remain classified as refrigerators, refrigerator-freezers, or freezers. Because of 

the operation of these products, DOE anticipates that such products will use less energy 

than products with the same volume that have no wine storage compartments. (Products 

with wine storage compartments should require less energy to chill their wine storage 

compartments because these compartments will operate at higher temperatures.) 

However, the maximum allowable energy use for the products would also be lower, due 

to the reduced adjusted volume. 

5) Developing test procedures and energy conservation standards for hybrid products falling 

out of the modified definitions for refrigerator, refrigerator-freezer, and/or freezer. 

Item 1-6 DOE requests general comments on its draft framework for addressing products 

that include fresh food and/or freezer compartments as well as wine storage compartments. 

Item 1-7 DOE seeks information regarding the types and configurations of products that 

might need to be considered under such a framework, including examples showing product 

details and information on annual shipments associated with such products. 

Item 1-8 DOE seeks comment on whether there should be a threshold size or percent of 

total volume for wine storage compartments that would push a product out of the current 

definitions for refrigerator, refrigerator-freezer, or freezer into hybrid product categories. 

If so, what should this threshold be? What types of hybrid product categories should be 

established? 

Item 1-9 DOE seeks comment on what kinds of test procedure revisions would be required 

to address these products, whether covered under the existing product categories or by new 

categories? 

Item 1-10 DOE seeks comment on whether it should develop separate definitions and 

energy conservation standards for hybrid products. 

1.2.4 Refrigeration Products Using Either AC or DC Electricity 

DOE is aware of some refrigeration products that operate using power input other than 

alternating current (AC) electricity -- e.g. direct current (DC) electricity. DOE’s ability to 

regulate these products, however, is somewhat limited by the statutory framework laid out by 

EPCA. First, many of these products are used solely in mobile applications (such as boats or 

16
 
 

recreational vehicles). Under EPCA, unless a product is designed solely for use in recreational 

vehicles or other mobile equipment, that product is potentially subject to coverage under relevant 

standards. See 42 U.S.C. § 6292(a). Second, the coverage established by EPCA with respect to 

refrigeration products is limited to those units that can operate on alternating current electricity. 

(42 U.S.C. § 6292(a)(1)). The language of this provision suggests that so long as a residential 

refrigeration product can operate on AC power, it would be covered under EPCA provided that it 

does not fall under the exclusions delineated in 42 U.S.C. § 6292(a)(1). 

Item 1-11 DOE seeks information regarding whether refrigeration products which operate 

on either alternating current (AC) or direct current (DC) electricity are distributed to any 

significant extent in commerce for personal or consumer use in stationary applications 

(e.g., in homes). What types of such products are sold, what are their annual shipment 

levels in the U.S., and what are their energy use characteristics? 

Item 1-12 DOE seeks comment on the merits of developing test procedures, definitions, and 

energy conservation standards for refrigeration products which operate on either 

alternating current (AC) or direct current (DC) electricity. 

1.2.5 Other Residential Refrigeration Products 

Section 1.1 above discusses the possibility of extending coverage and establishing energy 

conservation standards for all residential refrigeration products that DOE’s standards do not 

currently cover. While DOE presumes that wine chillers and other refrigeration products with 

storage temperatures warmer than those of refrigerators represent the key product category that 

fits this description, there may be other residential refrigeration products not yet considered. This 

section addresses the question of whether additional residential refrigeration products exist and 

the available framework for addressing these products. As part of this discussion, DOE seeks 

information regarding all such potential products, including relevant information to assist DOE 

in determining whether such products are subject to coverage and whether pursuit of coverage 

and energy conservation standards would be appropriate. 

One such product category that DOE may consider covering is residential ice makers. These 

devices consist of an insulated cabinet, a refrigeration system, and an automatic icemaker.11 

Some of these devices use automatic icemakers identical to those installed in refrigeratorfreezers while others use automatic icemakers derivative of commercial automatic ice makers, in 

which the water being frozen circulates over the evaporator mold surface while freezing, using a 

sump, pump, and water distribution system. This latter arrangement allows dissolved gases and 

solids in the water to be carried to the sump rather than trapped in the freezing ice—a portion of 

the sump water must be drained between freeze cycles to remove the dissolved solids, thus, 

preventing them from coming out of solution in the form of scale coating on the icemaker 

11 Note, in this discussion DOE is using the term “ice maker” to denote a product or equipment that includes a 

refrigeration system whose sole purpose is to make and possibly store ice. In contrast, the term “automatic 

icemaker” denotes a device or system that is installed within an ice maker or other refrigeration product and that 

does not include a complete refrigeration system but can make ice when provided with cooling from a refrigeration 

system. 

17
 
surfaces. (A typical icemaker found in a refrigerator-freezer freezes water held motionless in a 

mold.) 

EPCA sets energy conservation standards for those automatic commercial ice makers with ice 

harvest rates between 50 and 2,500 lb/day. (42 U.S.C. § 6313(d)(1)) Residential ice maker 

products typically have ice production rates of up to 50 lb/day and, thus, are not subject to these 

standards. 

Item 1-13 DOE requests information regarding whether there are any residential 

refrigeration products not yet covered by energy conservation standards, other than the 

wine chillers and related hybrid products noted earlier, that DOE should regulate through 

energy conservation standards? Assuming such products exist, what are they (i.e. types), 

what are their annual shipment levels in the U.S., and what are their energy use 

characteristics? 

Item 1-14 DOE seeks information regarding residential ice makers. Specifically, DOE 

seeks information regarding: (1) the annual sales levels for such products in the U.S,; (2) 

whether test procedures exist to address the energy use of these products; (3) information 

regarding the typical annual energy use of such a product in a residential usage setting; 

and (4) what information DOE should consider when determining whether to cover these 

products and what energy conservation standard levels to set for them? 

1.2.6	 Combined Coverage of Wine Chillers used in both Residential and Commercial 

Applications 

EPCA defines consumer product as follows: 

The term “consumer product” means any article (other than an automobile, as defined in 

section 32901 (a)(3) of title 49) of a type— 

(A) which in operation consumes, or is designed to consume, energy or, with 

respect to showerheads, faucets, water closets, and urinals, water; and 

(B) which, to any significant extent, is distributed in commerce for personal use 

or consumption by individuals; 

without regard to whether such article of such type is in fact distributed in commerce for 

personal use or consumption by an individual, except that such term includes fluorescent 

lamp ballasts, general service fluorescent lamps, incandescent reflector lamps, 

showerheads, faucets, water closets, and urinals distributed in commerce for personal or 

commercial use or consumption. 

(42 U.S.C. § 6291(1)) 

Likewise, EPCA distinguishes certain commercial equipment categories by indicating that they 

are not consumer products. For example, one of the seven attributes of a commercial refrigerator, 

refrigerator-freezer, or freezer is that it “is not a consumer product (as defined in section 6291 of 

this title)” (42 U.S.C. § 6311(9)(A)(i)) EPCA also indicates more generally that equipment can 

be defined as covered by these commercial and industrial categories if it is of a type that is, to 

18
 
 

 

any significant extent, distributed in commerce for industrial and commercial use. (42 U.S.C. § 

6311(2)). 

DOE is aware that wine chillers are used in both commercial and residential (consumer) 

applications. However, DOE is concerned that market characterization of a product as 

“commercial” does not necessarily mean that such a product qualifies as commercial equipment 

under EPCA. While DOE is aware of several attributes that could distinguish commercial types 

of wine chillers from residential types, it has insufficient information to definitively conclude 

that wine chillers with uniquely commercial features exist or what those uniquely commercial 

features would be. Furthermore, DOE does not have access to the necessary distribution chain 

information to definitively conclude that wine chillers with commercial features are not 

distributed to any significant extent for personal use. 

DOE notes that the products that could potentially be considered under this residential wine 

chiller rulemaking would be those that (a) have a compressor and condenser unit integrated with 

the cabinet, (b) operate on alternating current electricity, and (c) are designed to be used with 

doors. These criteria are specified under EPCA. See 42 U.S.C. § 6292(a)(1). 

The ongoing Commercial Refrigeration Equipment (CRE) rulemaking has adopted an approach 

in which commercial wine chillers are categorized as one of the following two equipment classes 

established for CRE equipment -- “vertical closed transparent, medium temperature, selfcontained” and “vertical closed solid, medium temperature, self-contained” (VCT.SC.M and 

VCS.SC.M).12 However, the rating temperature for such equipment is 38  ̊F -- one degree less 

than the temperature specified for residential refrigerators and refrigerator-freezers for fresh food 

storage. Most commercial wine chillers rarely operate at temperatures this low, with the design 

operating temperature generally ranging between 50  ̊F and 60  ̊F.13 DOE has not pursued 

separate equipment classes for commercial wine chillers in the CRE rulemaking because their 

market share is less than 1% of commercial refrigeration equipment. The CRE Technical Support 

Document (TSD) presents 2005 AHRI shipment data that includes 264,000 shipments.14 Hence, 

according to these industry-provided data, commercial wine chiller annual shipments are 

expected to be under 3,000. 

Under 10 CFR 430.32(a), the energy conservation standards are limited to those refrigerators and 

refrigerator-freezers with total volume no greater than 39 cubic feet and freezers with total 

volume no greater than 30 cubic feet. However, DOE may opt to alter this approach for 

residential wine chillers if it decides to establish energy conservation standards. 

12 “Preliminary Technical Support Document (TSD): Energy Conservation Program for Certain Commercial and 

Industrial Equipment: Commercial Refrigeration Equipment”, Market and Technology Assessment, Chapter 3 (CRE 

TSD Chapter 3), Table 3.2.4, page 3-16, 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/cre_pa_tsd_ch3_market.pdf 13 “Delfield Specification Line Self-Contained Solid Door Wine Cabinet Reach-In”, 

http://www.delfield.com/docs/uploaded/del/specsheets/DSSSW.pdf; “Traulsen Wine Cooler Models”, 

http://www.traulsen.com/uploadedFiles/Traulsen/Products/Special_Applications/Wine%20Cooler%20Sales%20Flye 

r.pdf 

14 CRE TSD Chapter 3, page 3-18. 

19
 
 

If necessary, DOE may also consider adjusting the wine chiller definition to help distinguish 

between consumer and commercial applications. 

Item 1-15 DOE seeks comment on what design and performance characteristics distinguish 

wine chillers used in commercial applications from residential wine chillers. DOE also 

requests comment on whether any wine chillers used in commercial applications are 

manufactured on the same product lines as residential wine chillers. Finally, DOE seeks 

information as to whether any commercial wine chillers are distributed in commerce for 

personal or consumer use. If any commercial wine chillers are in fact sold to individual 

consumers, DOE seeks details regarding the magnitude of those sales as a percentage of 

total sales of those products. 

Item 1-16 DOE requests comment on whether commercial and residential wine chillers 

should be covered under the same test procedures and energy conservation standards. 

1.2.7 Near-Freezers 

During the residential refrigeration product test procedure rulemaking, Earthjustice raised the 

issue of products sold as freezers that do not meet the standardized compartment temperature for 

freezers. 75 FR 78810, 78816 (December 16, 2010). Such products would not meet the 

regulatory definition for freezer -- “Freezer means a cabinet designed as a unit for the freezing 

and storage of food at temperatures of 0 °F or below, and having a source of refrigeration 

requiring single phase, alternating current electric energy input only.”15 Hence, under this 

definition, products sold as freezers but are not designed to store food at 0 °F or below would not 

be covered under the current definition and accompanying standards. 

In order to prevent manufacturers from avoiding the standards by designing freezers with 

temperature ranges that hover just above 0  ̊F, DOE may consider modifying the freezer 

definition. DOE notes that the test procedure interim final rule specifies that, starting in 2014, 

freezers that are unable to meet the standardized temperature with their controls set at the coldest 

setting fail the test and may not be rated. 75 FR 78810, 78868 (December 16, 2010). Hence, the 

sale of such “near-freezers” could be banned by modifying the freezer definition to ensure that it 

is not limited to products that cannot meet the 0  ̊F standardized temperature. 

Alternatively, DOE could consider modifying the freezer test procedure to allow testing of such 

products with a modified standardized temperature. Under that approach, DOE would consider 

using a modified volume adjustment factor for the tested product, which would allow for 

calculation of the adjusted volume based on the warmer standardized temperature. This method 

would lower the calculated energy standard for such a product by accounting for the reduced 

energy requirements for these products. Such changes may allow coverage and sale of nearfreezers in a way that subjects them to the existing energy conservation standards without 

requiring the development of separate product classes. DOE could also consider the further step 

of establishing separate product classes for such products with their own energy conservation 

standards. 

15 10 CFR 430.2 

20
 
 

 

Item 1-17 DOE seeks information regarding the prevalence of “near-freezer” products. 

DOE also seeks input regarding the need to revise the current freezer definition and/or test 

procedures to address such products. Further, DOE seeks input on whether it should 

include these products under existing classes or create separate product classes and 

standards for these products. If so, DOE requests comments regarding the nature of such 

needed revisions. 

1.2.8 Test Procedures 

The Code of Federal Regulations (CFR) describes the DOE test procedures for residential 

refrigeration products.16 The test procedures for products manufactured starting in 2014 appear 

in 10 CFR 430.23, Appendix A (for refrigerators and refrigerator-freezers), and Appendix B (for 

freezers). However, these test procedures do not include provisions for testing products such as 

wine chillers that do not meet the current definition for electric refrigerators. In particular, the 

standardized compartment temperatures specified in the test procedures are significantly lower 

than those typical for wine chillers. The standardized compartment temperatures provided in 

Appendix A are as follows: 

 Fresh food compartments: 39  ̊F (3.9  ̊C) 

 Freezer compartments of refrigerators: 15  ̊F (-9.4  ̊C) 

 Freezer compartments of refrigerator-freezers: 0  ̊F (-17.9  ̊C) 

Appendix A, section 3.2 

In contrast, wine storage temperatures are typically much higher. For example, the Association 

of Home Appliance Manufacturers (AHAM), the California Energy Commission (CEC), and 

Natural Resources Canada (NRCan) have each adopted a standardized compartment temperature 

of 55  ̊F (12.8  ̊C) for wine chiller testing.17 

There may also be other refrigeration products that do not meet the current definition for electric 

refrigerator, such as beverage coolers or beverage centers. These products currently are excluded 

from coverage under the standards for refrigerators if they are not designed for a 39  ̊F storage 

temperature. Hence, the current test procedure for refrigerators is also inappropriate for these 

products. 

Further, DOE was unable to find examples of industry, state, or international standards 

specifying standardized temperatures for such products, other than wine chillers. Hence, there is 

no obvious alternative temperature other than 55  ̊F that might be used for them during testing. 

However, many of the products identified as wine chillers on the CEC list of certified 

16 Title 10—Energy, Chapter II—Department of Energy, Part 430—Energy Conservation Program for Consumer 

Products. Subpart B—Test Procedures: Section 23; Appendices A1 and B1 for products manufactured prior to 

January 1, 2014; and Appendices A and B for products manufactured on or after January 1, 2014. 

17 AHAM Standard HRF-1-2008, “Energy and Internal Volume of Refrigerating Appliances”, section 5.6.2; 

“Appliance Efficiency Regulations”, CEC-400-2006-002-REV2, Section 1604(a)(1), Table A-1; “Energy 

Performance and capacity of household refrigerators, refrigerator-freezers, freezers, and wine chillers”, C300-08, 

section 5.3.6.2. 

21
 
 

refrigeration products18 are actually beverage centers or other beverage-oriented products other 

than wine chillers. 

DOE believes that the key issues in developing test procedures for wine chillers and related 

residential refrigeration products are as follows: 

 Establishing definitions for product categories and/or compartment types to clarify which 

products are subject to which test requirements. (See section 1.2.2 above.) 

 Establishing standardized compartment temperatures that are appropriate for the product 

categories. 

 Testing for hybrid products. (See section 1.2.3 above.) 

 Potential consideration of test procedures for commercial wine chillers. See section 1.2.4 

above. 

 Applying a correction factor to determine the energy use of wine chillers and related 

products. 

 Potential consideration of additional test procedure requirements to address standby 

and/or off mode energy use. 

Item 1-18 DOE seeks comment regarding whether there are any other key issues, aside 

from the ones noted in this document, that DOE should consider when developing test 

procedures for wine chillers and related refrigeration products, and, if so, what these 

issues are. 

1.2.8.1 Compartment Definitions and Standardized Compartment Temperatures 

In section 1.2.3 above, DOE discussed establishing a definition for “wine chiller” to mean 

products that are not capable of storage temperatures below 39  ̊F (3.9  ̊C). Also, in section 

1.2.3, DOE discussed so-called “hybrid” products that combine “wine storage” compartments 

with fresh food and/or freezer compartments. DOE anticipates that a new rule to establish test 

procedures for such products may include the addition of a definition for “wine storage” 

compartments and a standardized temperature for testing purposes. In establishing these test 

procedure details, DOE will consider the available test procedures that address wine chillers, e.g. 

AHAM HRF-1-2008, CSA C300-08, and CEC-400-2006-002-REV2, which all prescribe a 

standardized compartment temperature of 55  ̊F (12.8  ̊C).19 The Australia/New Zealand test 

procedures establish a similar requirement for a “cellar” compartment by prescribing a target 

temperature during energy testing of 12  ̊C (53.6  ̊F).20 

18 California Energy Commission Appliance Database, <http://www.energy.ca.gov/appliances/database/index.html>
 19 AHAM Standard HRF-1-2008, “Energy and Internal Volume of Refrigerating Appliances”, section 5.6.2;
 

“Appliance Efficiency Regulations”, CEC-400-2006-002-REV2, Section 1604(a)(1), Table A-1; “Energy 

Performance and capacity of household refrigerators, refrigerator-freezers, freezers, and wine chillers”, C300-08, 

section 5.3.6.2.
 20 “Performance of household electrical appliances—Refrigerating appliances Part 1: Energy consumption and
 

performance”, AS/NZS 4474.1:2007, section 3.7.1, table 3.5 

22
 
 

DOE recognizes that some products that are not refrigerators may control for temperatures 

different than 55  ̊F, especially if they are designed for specific purposes other than for the 

chilled storage of wine. Conversely, assuming that 55  ̊F is a reasonable test temperature for all 

such compartments, referring to them all as “wine storage” compartments may not be appropriate 

since these compartments could be capable of safely storing items other than wine. 

Item 1-19 DOE requests comment regarding a potential definition for compartments used 

in wine chillers and related refrigeration products that are currently not covered under the 

existing refrigeration product definitions. What compartment types should be defined and 

what should their standardized temperatures for energy testing be? 

1.2.8.2 Correction Factor 

The AHAM, CEC, and CSA test procedures for wine chillers apply a correction factor to the 

wine chiller energy use calculation to account for average product usage.21 This factor, equal to 

0.85 for all of these test procedures, reduces the measured energy use by 15% to determine the 

daily energy consumption for a given temperature setting in order to account for the expectation 

that such products would have fewer door openings, on average, than a household refrigerator, 

may not be energized at all times, or other reasons that would reduce energy use. The DOE 

freezer test procedure applies a similar factor to calculate annual energy use, using a correction 

factor of 0.85 for upright freezers and 0.7 for chest freezers. (10 CFR 430, subpart B, appendix 

B1, section 5.2.1) 

Item 1-20 DOE requests comments on whether a correction factor is appropriate for 

calculating wine chiller energy use, and if so, whether 0.85 is an appropriate value for the 

correction factor. DOE further requests information supporting the selection of any 

recommended correction factor. 

1.2.8.3 Standby and Off Modes 

EPCA, as modified by EISA, requires DOE to consider standby mode and off mode energy 

consumption when amending both its test procedures and energy conservation standards. 

Specifically, section 310 of EISA amended section 325 of EPCA (42 U.S.C. § 6295) by adding 

the following definitions and other requirements pertaining to standby and off mode energy use: 

(gg) STANDBY MODE ENERGY USE. 

(1) DEFINITIONS.— 

(A) IN GENERAL.—Unless the Secretary determines otherwise pursuant 

to subparagraph (B), in this subsection: 

21 AHAM Standard HRF-1-2008, “Energy and Internal Volume of Refrigerating Appliances”, section 5.8.2.1; 

“Appliance Efficiency Regulations”, CEC-400-2006-002-REV2, Section 1604(a)(1), Table A-1; “Energy 

Performance and capacity of household refrigerators, refrigerator-freezers, freezers, and wine chillers”, C300-08, 

section 6.3.1.2. 

23
 
 

(i) ACTIVE MODE.—The term "active mode" means the 

condition in which an energy-using product:— 

(I) is connected to a main power source; 

(II) has been activated; and 

(III) provides 1 or more main functions. 

(ii) OFF MODE.—The term "off mode" means the condition in 

which an energy-using product:— 

(I) is connected to a main power source; and 

(II) is not providing any standby or active mode function. 

(iii) STANDBY MODE.—The term "standby mode" means the 

condition in which an energy-using product:— 

(I) is connected to a main power source; and 

(II) offers 1 or more of the following user-oriented or 

protective functions: 

(aa) To facilitate the activation or deactivation of 

other functions (including active mode) by remote 

switch (including remote control), internal sensor, 

or timer. 

(bb) Continuous functions, including information or 

status displays (including clocks) or sensor-based 

functions. 

(B) AMENDED DEFINITIONS.—The Secretary may, by rule, amend the 

definitions under subparagraph (A), taking into consideration the most 

current versions of Standards 62301 and 62087 of the International 

Electrotechnical Commission (IEC). 

(2) TEST PROCEDURES.— 

(A) IN GENERAL.—Test procedures for all covered products shall be 

amended pursuant to section 323 to include standby mode and off mode 

energy consumption, taking into consideration the most current versions of 

Standards 62301 and 62087 of the International Electrotechnical 

Commission, with such energy consumption integrated into the overall 

energy efficiency, energy consumption, or other energy descriptor for each 

covered product, unless the Secretary determines that:— 

(i) the current test procedures for a covered product already fully 

account for and incorporate the standby mode and off mode energy 

consumption of the covered product,; or 

(ii) such an integrated test procedure is technically infeasible for a 

particular covered product, in which case the Secretary shall 

prescribe a separate standby mode and off mode energy use test 

procedure for the covered product, if technically feasible. 

* * * * * 

(3) INCORPORATION INTO STANDARD.— 

(A) IN GENERAL.—Subject to subparagraph (B), based on the test 

procedures required under paragraph (2), any final rule establishing or 

revising a standard for a covered product, adopted after July 1, 2010, shall 

24
 
incorporate standby mode and off mode energy use into a single amended 

or new standard, pursuant to subsection (o), if feasible. 

(B) SEPARATE STANDARDS.—If not feasible, the Secretary shall 

prescribe within the final rule a separate standard for standby mode and 

off mode energy consumption, if justified under subsection (o). 

For wine chillers and miscellaneous refrigeration products, DOE expects that any modified 

version of the existing test procedures for refrigeration products that DOE would develop for 

these products would capture standby and off mode energy use. All energy input for the test 

duration, including during compressor off cycles, would likely be captured under a modified 

version of the current procedure for refrigeration products. Hence, under the standby/off-mode 

provision, a special procedure to capture standby and off mode energy consumption would be 

unnecessary if this approach were adopted. 

Item 1-21 DOE requests input from stakeholders on its tentative conclusion that separate 

test procedures to address standby and off modes are not required for wine chillers and 

related refrigeration products. 

1.3 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 

steps for a given consumer product or commercial/industrial equipment type: (1) the publication 

of a framework document in which DOE describes the overall approach it is considering in 

developing potential energy conservation standards for a particular product or equipment; (2) the 

publication of a preliminary analysis that focuses on the analytical methodology DOE is 

considering in setting potential standards; (3) the issuance of a notice of proposed rulemaking 

(NOPR); and (4) the issuance of a final rule. At each of the first three steps, DOE holds a public 

meeting and actively solicits verbal and written comments from the public on a variety of 

relevant issues under consideration in developing potential standards. 

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. DOE’s initial 

analyses suggest that standards for the products examined in this document would likely meet the 

25
 
necessary energy consumption thresholds required under EPCA. The additional work that will 

be performed as part of DOE’s analyses will help determine whether standards for these products 

are likely to satisfy the statutory prerequisites noted above. 

A brief description of the next steps in DOE’s process follows below: 

	 Preliminary Analysis (section 1.3.1). 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 1.3.2). 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 1.3.3). 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. 

1.3.1 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) and a screening analysis (section 4). 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. This framework document, along with the accompanying public meeting 

request for public comment, initiates DOE’s dialogue with interested parties. 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 product 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 

26
 
 

 

and development (R&D) costs). As part of the preliminary analysis, DOE also conducts other 

principal analyses, many of which are described in this document, including: 

1.	 Engineering analysis (section 5); 

2.	 Consumer life-cycle cost (LCC) and payback period (PBP) analyses (section 8); 

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

consumer net present value (NPV) (section 10); and 

4.	 Preliminary manufacturer impact analysis (MIA) (section 12). DOE will present the 

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

DOE selects candidate standard levels (CSLs) from the energy efficiency or energy use levels 

considered in the preliminary analysis. Discussion of various CSLs in the preliminary analysis 

helps interested parties review the spreadsheet models that underpin the analyses. DOE uses 

comments from interested parties to refine the models for the next stage of the rulemaking 

analyses. In addition to the efficiency level corresponding to the maximum technologically 

feasible (“max-tech”) design and the efficiency level corresponding to the minimum LCC point, 

DOE generally considers 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 products or 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 

product 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 makes the spreadsheet tools and results of the preliminary analysis available on its website 

for review.22 When it publishes the preliminary analysis, DOE also makes a preliminary TSD 

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

22 All materials associated with the rulemakings for wine chiller and miscellaneous refrigeration product test 

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

 http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers.html 

27
 
the preliminary analysis, DOE provides a public comment period and holds a public meeting to 

discuss these analyses. 

1.3.2 Notice of Proposed Rulemaking 

In developing the NOPR, DOE considers all the comments it receives on the preliminary 

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

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

additional economic and environmental impact analyses. These analyses, which are described 

throughout this document, generally include: 

1. Consumer LCC subgroup analysis (section 11); 

2. Complete MIA (section 12); 

3. Utility impact analysis (section 13); 

4. Employment impact analysis (section 14); 

5. Environmental assessment (section 15); and 

6. Regulatory impact analysis (RIA) (section 17). 

DOE describes the methodology used and makes 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 presents 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 is published in 

the Federal Register document, which describes 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 product class, DOE identifies the max-tech efficiency level. If DOE proposes a lower 

level, DOE explains the reasons for eliminating higher levels, beginning with the highest level 

considered. DOE presents the analytical results in the NOPR and provides the details of the 

analysis in an accompanying TSD. 

DOE considers many factors in selecting proposed standards. These factors are prescribed by 

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

standards. 

When DOE publishes the NOPR, it provides 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 market of the products that are the subject of the rulemaking. DOJ reviews 

standard levels to help assess the impacts from 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 is followed by a public comment period that includes a public meeting. 

1.3.3 Final Rule 

After publication of the NOPR, DOE considers public comments it receives on the proposal and 

accompanying analyses. DOE reviews the engineering and economic impact analyses and any 

28
 
 

proposed standards based on these comments and consider modifications where necessary. 

Before any final rule is issued, DOE also considers DOJ’s comments on the NOPR relating to 

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

these standard levels are needed. DOE publishes 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, 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. 

1.3.4 Acceleration of Rulemaking Timeline 

DOE may consider accelerating the timeline of the potential rulemaking for an energy 

conservation standard for wine chillers and miscellaneous refrigeration products. Two options 

exist to allow for an acceleration of the timeline: 

1.	 Stakeholders negotiate appropriate efficiency levels for the standard and DOE 

publishes a direct Final Rule. This option could save 7-21 months, depending on 

how early in the process an agreement is reached. 

2.	 DOE bypasses publication of preliminary analysis documents and the preliminary 

analysis public meeting and proceeds directly to a NOPR. This option could save 6-8 

months. 

Item 1-22 DOE requests comments from stakeholders regarding the possible acceleration 

of the timeline to publish the final rule and potential implications. 

2. OVERVIEW OF ANALYSES FOR RULEMAKING 

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

conservation standards for wine chillers and miscellaneous refrigeration products. The analyses 

ensure that if standards are established, 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 1.3 of this framework document), 

which encompass the economic impacts on domestic manufacturers and consumers, national 

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

lessening of competition. 

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 

29
 
f

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 

framewo rk. 

Figure 2.1 Flow Diagram of Analyses for the Wine Chiller and Miscellaneous 

Refrigeration Product Standards Rulemaking Process 

30
 

Approaches 0 Key Inputs 0 A nalyses 0 Key Outputs 

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. 1IkI'Ii.t;:' t ...... /SiiUiiIii'>ii'O : 

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FlnaiRu. 
DOE notes that section 1 above pertains to a range of product types, including wine chillers and 

miscellaneous residential refrigeration products that use any of three different refrigeration 

technologies (vapor compression, thermoelectric, and absorption). The section also discusses 

hybrid products and commercial wine chillers. However, the discussion in the following sections 

is limited to residential vapor compression refrigeration products that are currently not covered 

under the definitions for refrigerator, refrigerator-freezer, or freezer. 

3. MARKET AND TECHNOLOGY ASSESSMENT 

The market and technology assessment provides information about the residential wine chiller 

and miscellaneous refrigeration products industries and specifics about the performance 

attributes of these products. DOE uses this assessment throughout the rulemaking. This 

assessment is particularly important at the outset of the rulemaking to determine product classes 

and to identify potential design options or efficiency levels for each product class. 

3.1 Market Assessment 

DOE qualitatively and quantitatively characterizes the structure of the residential wine chiller 

and miscellaneous refrigeration products industries and markets. DOE’s market assessment 

identifies and characterizes the manufacturers of this equipment, estimates market shares and 

trends, addresses regulatory and non-regulatory initiatives intended to improve the energy 

efficiency or reduce the energy consumption of products covered by this rulemaking, and 

explores the potential for technological improvements in the design and manufacturing of such 

equipment. 

The market assessment phase allows DOE to gather data that can help identify important issues 

later in the potential rulemaking (e.g., potential small business impacts, competitive disruptions, 

and other factors that may arise from enacting standards). For example, DOE uses historical 

equipment shipments and prices as an indicator of future shipments and prices. Market structure 

data can be particularly useful for assessing competitive impacts as part of the manufacturer 

impact analysis. This phase also allows DOE to start updating design options by reviewing 

product literature, industry publications, and company websites. 

Item 3-1 DOE requests information that would contribute to the market assessment for the 

residential wine chillers and miscellaneous refrigeration products that would be covered in 

this potential rulemaking. Examples of information sought include current product 

features and efficiencies, product-feature and efficiency trends, historical product 

shipments and prices). 

3.2 Product Classes 

For some product types, DOE develops separate product classes and formulates separate energy 

conservation standards for each class. The general criteria for separation into different classes 

include (1) type of energy used, (2) capacity, and (3) other performance-related features such as 

31
 
those that provide utility to the consumer, or others deemed appropriate by the Secretary that 

would justify the establishment of a separate energy conservation standard. (42 U.S.C. § 6295(q) 

and 6316(a)) 

DOE has identified two potential product classes for wine chillers and miscellaneous 

refrigeration products as shown in Table 3.1. While the CEC has established separate product 

classes for residential wine chillers with manual and automatic defrost, only five of the 219 units 

listed in the CEC database are categorized as manual defrost products. Further inspection of 

these units revealed that four of these five either are listed as having automatic defrost on the 

manufacturer’s website or product literature, or have been discontinued from production. DOE 

has not confirmed whether the single remaining product is a manual defrost product. Section 3.3 

asks whether any wine chiller or related refrigeration products actually use manual defrost -- if 

no such products exist, DOE would likely eliminate that class from further consideration. 

DOE also notes that a potential rulemaking may address products designed for wine storage and 

other products that do not fit the current definitions for refrigerator, refrigerator-freezer, or 

freezer. Some of these other products may not have transparent doors, which are common for 

most wine chillers. Depending on the prevalence of such solid-door products, the efficiency 

differences between solid and transparent doors, and the consumer utility associated with 

transparent doors, DOE may consider establishing separate product classes for solid-door 

products. 

Table 3.1 Residential Wine Chiller and Miscellaneous Refrigeration Product Classes 

No. Product Class 

1 Residential wine chillers and miscellaneous refrigeration products with manual defrost 

2 Residential wine chillers and miscellaneous refrigeration products with automatic 

defrost 

Item 3-2 DOE requests input from stakeholders on the proposed product classes. What 

other factors, if any, should DOE consider beyond those identified above as a basis for 

developing product classes? When answering, please explain in detail and cite specific 

examples to the extent possible. 

Item 3-3 DOE requests information on solid-door products that would fit the definitions 

anticipated for wine chillers including: the prevalence of such products, the efficiency 

differences, if any, with respect to transparent-door products versus those products with 

solid doors, and whether there is sufficient consumer utility associated with transparent 

doors to merit creating a separate product class on this basis? 

3.3 Technology Assessment 

The technology assessment centers on understanding how energy is used by the product or 

equipment and potential changes that would reduce energy consumption. DOE typically uses 

32
 
 

 

information about existing “technology options,” based on existing technologies and prototype 

designs and concepts, as input in identifying technologies that manufacturers of those products 

could use to attain higher energy efficiency levels. In consultation with interested parties, DOE 

develops a list of technologies to consider in this analysis. Initially, this list includes all those 

technologies considered to be technologically feasible and helps DOE determine the max-tech 

design, based on a review of efficiencies of available products and their features. 

Table 3.2 below provides a preliminary list of technologies that DOE will consider. These 

include (a) technologies from the residential refrigeration product standards rulemaking, (b) 

additional technologies addressing efficiency improvements associated with transparent-door 

refrigerators, (c) additional technologies described in recent trade publications, research reports, 

and manufacturer product offerings. The technologies considered in DOE’s 2011 residential 

refrigeration product rulemaking are identified in the corresponding TSD.23 Technologies not 

identified in that TSD include anti-fog films and improved thermal resistance glass and frames 

for transparent doors. DOE has specific questions related to specific technology options. 

Item 3-4 DOE requests information on whether any wine chillers or miscellaneous 

refrigeration products utilize heating (electric or otherwise) on glass surfaces or on door 

face frames to prevent condensation. If so, what types of products utilize such heating and 

what percentage of shipments do they represent? 

Item 3-5 DOE seeks clarification on whether any wine chillers or miscellaneous 

refrigeration products utilize defrost heating (i.e. automatic defrost methods other than by 

frost melting during the compressor off-cycle). If so, what types of products utilize defrost 

heating and what percentage of shipments do they represent? DOE also requests 

clarification on whether any wine chillers or miscellaneous refrigeration products utilize 

manual defrost—what types of products require manual defrost and what percentage of 

shipments do they represent? 

Item 3-6 DOE requests information regarding whether any wine chillers or miscellaneous 

refrigeration products utilize anti-sweat heating of any kind (electric resistance, refrigerant 

loop, etc.)? 

23 “Preliminary Technical Support Document (TSD): Energy Conservation Program for Consumer Products: 

Refrigerators, Refrigerator-Freezers, and Freezers”, Market and Technology Assessment, Chapter 3 (RRP TSD 

Chapter 3), Table 3.3.1, page 3-46, 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/refrig_nopr_tsd_2010-09-23.pdf. 

33 
 

 

 

Table 3.2 Wine Chiller and Miscellaneous Refrigeration Product Technologies 

Insulation Compressor 

1. Improved resistivity of insulation 11. Improved compressor efficiency 

2. Increased insulation thickness 12. Variable-speed compressors 

3. Vacuum-insulated panels 13. Linear compressors 

Gasket and Door Design Evaporator and Condenser 

4. Improved gaskets 14. Increased surface area 

5. Double door gaskets 15. Improved heat exchange 

6. Improved door face frame 

7. Anti-fog film Cycling Losses 

8. Improved thermal resistance glass and 

frames 

16. Fluid control or solenoid valve 

Anti-Sweat Heater Defrost System 

9. Hot gas or Warm Liquid 17. Compressor cycling defrost 

Fans and Fan Motor Other Technologies 

10. Fan blade and fan motor improvements 18. Alternative refrigerants 

Item 3-7 DOE seeks comment on whether any additional technologies in addition to the 

ones identified above should be considered for wine chillers and miscellaneous 

refrigeration products. 

4. SCREENING ANALYSIS 

The purpose of the screening analysis is to screen out design options that DOE will not consider 

in its potential energy conservation standard rulemaking for residential wine chillers and 

miscellaneous refrigeration products. 

As an initial matter, DOE develops a list of design options developed through its own research 

and in consultation with interested parties for consideration in the engineering analysis (section 

5). Development of the list is based on the technologies shown in Table 3.2. The identified 

candidate design options encompass all those technologies that may be technologically feasible. 

Thereafter, DOE reviews each technology option considering the following four criteria, as 

provided in sections 4(a)(4) and 5(b) of Procedures, Interpretations, and Policies for 

Consideration of New or Revised Energy Conservation Standards for Consumer Products (see 

10 CFR Part 430, Subpart C, Appendix A) and tailored to the current rulemaking: 

34
 
1. Technological feasibility. DOE does not further consider technologies that are not 

incorporated in commercially available products or in 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 time of the effective date of the standard, then it does not consider that 

technology further. 

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

technology will have a significant adverse impact on the utility of the product to 

significant subgroups of consumers, or 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 does 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 does not consider that technology 

further. 

DOE fully documents the reasons for eliminating any design options during the screening 

analysis and publishes this documentation for stakeholder review and comment as part of the 

preliminary analysis. 

Item 4-1 Are there any technologies listed in Table 3.4 that DOE should not consider 

because of any of the four screening criteria? If so, which screening criteria apply to the 

cited technology or technologies? 

5. ENGINEERING ANALYSIS 

After conducting the screening analysis described above, DOE performs an engineering analysis 

based on the remaining design options that would improve product efficiency. The engineering 

analysis consists of estimating the energy consumption and cost of products at various levels of 

increased efficiency. This section provides an overview of the engineering analysis (section 5.1), 

and discusses baseline units (section 5.2), DOE’s proposed approach for determining the costefficiency relationship (section 5.3), efficiency levels (section 5.4), proprietary designs (section 

5.5), and cumulative regulatory burdens that might affect the engineering analysis (section 5.6). 

5.1 Engineering Analysis Overview 

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

cost and energy efficiency for residential wine chillers and miscellaneous refrigeration products. 

In determining the cost-efficiency relationship, DOE estimates the increase in manufacturer cost 

35
 
 

associated with technological changes that increase the efficiency of these products relative to 

the baseline models. 

DOE may request cost information from manufacturers for the incremental costs to achieve 

specified efficiency levels for the relevant product classes and representative product adjusted 

volumes. 

DOE carries out energy modeling for products to supplement the manufacturer-supplied data. 

The energy modeling is carried out for a few important product classes. Initially, DOE carries 

out calibration of the model for baseline product designs and for relevant higher-efficiency 

designs that can be identified. DOE takes design data for these units from reverse engineering 

work. DOE carries out energy modeling for product designs incorporating energy-saving design 

options and groups of energy-saving design options to determine the efficiency impact of these 

modified product designs. 

DOE would carry out energy testing for a few selected models selected to provide a good 

representation of the market. DOE would conduct these tests according to the current energy test 

procedure used for wine chillers under existing regulations in California and Canada (see the 

discussion of existing test procedures in section 1.2.8) but may also consider any test procedure 

variant that may be appropriate for incorporation into DOE’s regulations. This testing would 

establish the actual energy use of the products and would provide additional data to support 

energy modeling work. 

DOE uses reverse engineering to identify design options used in baseline and improved 

efficiency products and to provide the basis for manufacturing cost analysis. The reverseengineering process consists of a detailed product disassembly, whereby (1) representative units 

are torn down; (2) all components, processes, assembly, and manufacturing steps are noted in a 

process-based cost model; and (3) all manufacturing costs are calculated. Representative units 

are chosen based on the range of efficiencies, design options, and capacities. 

The result is a “green-field” model24 of the subject unit and the factory in which it would be 

built. DOE can then aggregate these unit-specific factory requirements by market share, unit 

shipments, or any other method it wishes to use to derive industry-wide estimates. 

5.2 Baseline Models 

Once DOE establishes product classes, it selects a baseline model as a reference point for each 

product class subject to analysis against which it can measure changes resulting from energy 

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

common or typical equipment in that class. Typically, a baseline model would be a model that 

just meets current required energy conservation standards. 

At a subsequent stage in its analysis, DOE uses the baseline models to conduct the engineering 

analysis and the LCC and PBP analyses. To determine energy savings and changes in 

24 A green-field model estimates the cost of a product as if it were built in a brand-new facility that had just broken 

ground. 

36
 
 

 

manufacturer selling price, DOE compares each higher energy efficiency product design against 

the baseline model. 

DOE does not currently regulate residential wine chillers and miscellaneous refrigeration 

products. Standards in California and Canada are expressed as maximum annual energy 

consumption as a function of the product’s adjusted volume or total volume.25 The volume 

adjustment factor for wine chillers is equal to 1.0,26 so the total and adjusted volumes are equal. 

Table 5.1 sets forth the current California and Canadian energy conservation standards for the 

two existing product classes. 

Table 5.1 Wine Chiller California and Canadian Energy Conservation Standards and 

Proposed Baseline Model Efficiencies 

Product Class 

Equations for Maximum 

Energy Use (kWh/yr) 

Wine chillers with manual defrost. 13.7AV + 267 

0.48 av + 267 

Wine chillers with automatic defrost 17.4AV + 344 

0.61 av + 344 

AV, adjusted volume in cubic feet; av, adjusted volume in liters 

Should DOE determine that additional product classes are merited, DOE would develop baseline 

efficiency levels for these product classes based on information regarding their typical energy 

use characteristics and present these classes for public comment. 

Item 5-1 DOE seeks input from stakeholders on whether the equations for maximum 

annual energy consumption of the California and Canadian regulations are appropriate to 

represent the performance of baseline wine chillers. 

5.3 Approach for Determining the Cost-Efficiency Relationship 

DOE would likely use a combined approach for determining the cost-efficiency relationships for 

wine chillers and miscellaneous refrigeration products. The combined approach would include 

energy modeling, limited energy testing, manufacturing cost analysis supported by reverseengineering teardowns, and possibly data collected from manufacturers through AHAM. While it 

is possible that efficiency-level analysis would be feasible, depending on the range of efficiency 

levels of current products, past experience has shown that manufacturing cost estimates for 

25 “Appliance Efficiency Regulations”, CEC-400-2006-002-REV2, Section 1605.3(a)(1), Table A-4; Natural 

Resources Canada, Office of Energy Efficiency, Refrigerators, Refrigerator-Freezers and Wine Chillers, Energy 

Efficiency Regulations, http://oee.nrcan-rncan.gc.ca/regulations/product/refrigerators-freezers.cfm?attr=0 26 “Energy Performance and capacity of household refrigerators, refrigerator-freezers, freezers, and wine chillers”, 

C300-08, section 7.3. 

37
 
residential refrigeration products are too sensitive to factors not related to efficiency to correlate 

consistently with the rated efficiency levels. 

Depending on the level of support provided by AHAM and its members, DOE may request cost 

information from manufacturers for the incremental costs necessary to achieve specified 

efficiency levels for the relevant product classes and representative product adjusted volumes. 

DOE would perform energy modeling on products representing the product classes identified in 

Table 5.1 and any other product class identified during the rulemaking. DOE would base its 

energy models on engineering design data provided by manufacturers and/or determined through 

reverse-engineering teardowns for both baseline and improved-energy product designs. This 

modeling would use a range of design options to reduce energy use and then compare the results 

of this design-option analysis with any information obtained from manufacturers through 

AHAM. 

DOE would perform energy testing for a few selected models. DOE would conduct these tests 

according to the test procedure currently used by California and Canada. The results from these 

tests would establish actual energy use for the products. DOE would use additional 

instrumentation beyond that required for the test procedure to provide additional data to support 

the energy modeling work. The additional data that DOE would record include refrigeration 

circuit temperatures -- these temperatures are significant because they help to calibrate energy 

models with actual product performance. 

DOE uses reverse engineering, as described above, to identify the incremental cost and 

efficiency improvement associated with each design option or design option combination. DOE 

conducts reverse engineering through physical teardowns and testing on wine chillers and 

miscellaneous refrigeration products at key efficiency levels to determine baseline manufacturing 

costs as well as incremental manufacturing costs above the baseline. DOE proposes to perform 

reverse engineering on units rated at the baseline level and improved energy consumption levels. 

DOE sometimes supplements the reverse-engineering data with information from catalogs, 

websites, and trade publications to create a wider set of units for its efficiency-cost analysis. 

To support this analysis, DOE would likely seek incremental cost data from manufacturers 

through AHAM for each efficiency level defined for each product class. These data would be 

used to represent the shipment-weighted average, industry-wide incremental production cost 

associated with each level of efficiency improvement. DOE seeks input on whether AHAM and 

the industry are willing to support such a data collection effort and on the format of the 

information that would be provided. DOE also seeks input on whether any other stakeholders 

may have access to and are willing to provide information that is relevant to the analysis. 

To be useful in the manufacturer impact analysis, manufacturer cost information should reflect 

the variability in baseline models, design strategies, and cost structures that can exist among 

manufacturers. This information allows DOE to better understand the industry and its associated 

cost structure, and, thus, helps predict the most likely impact that new energy efficiency 

regulations would have. For example, the reverse-engineering methodology allows DOE to 

38
 
 

estimate the green-field costs of building new facilities, yet the majority of plants in any given 

industry comprise a mix of assets in different stages of depreciation. 

DOE attempts to qualify the cost-efficiency data that it generates through the reverse-engineering 

activities with industry-supplied data and information arising from consultation with 

stakeholders or technical experts. Specifically, DOE supplements these cost data with 

information obtained through follow-up manufacturer interviews. Interviews with manufacturers 

not only help DOE refine its capital expenditure estimates, but also allow DOE to refine its 

depreciation projections and other financial parameters. 

If DOE is unable to reconcile information collected during the manufacturer interviews with the 

generated or collected cost data, or with information contained in the market and technology 

assessment, it supplements the collected data through consultation with outside experts and/or 

further review of publicly available cost and performance information. 

DOE estimates the contribution of the depreciation of conversion capital expenditures to the 

incremental overhead. During the interviews, DOE gathers information about the capital 

expenditures that would be necessary to increase the efficiency of the baseline models to various 

efficiency levels (i.e., conversion capital expenditures by efficiency or energy-use level). DOE 

also requests information about the depreciation method that manufacturers use to expense the 

conversion capital. 

Item 5-2 DOE requests feedback on the use of a design-option approach based on energy 

modeling and some energy testing as needed, possibly enhanced by data collection 

organized by AHAM or other parties to determine the relationship between manufacturer 

cost and annual energy consumption. Particularly, DOE is interested in whether this 

approach is appropriate for developing a cost/efficiency relationship for use as the basis 

for standards-setting and if the industry, AHAM, or any other parties are prepared to 

provide cost-efficiency information to support the rulemaking. If the suggested approach is 

not appropriate, why is it not? 

5.4 Efficiency Levels 

For each of the product classes identified, DOE establishes potential efficiency levels and seeks 

to develop incremental cost data at each of these levels. DOE would conduct engineering, LCC, 

and PBP analyses on all representative product classes. 

Figure 5.1 below shows energy use as a function of total volume for wine chillers listed in the 

CEC database.27 Only one manual defrost model is plotted, because the status of four of the five 

models in the database listed as having manual defrost has been changed (see the discussion in 

section 3.2 above). The data show that the maximum efficiency level of currently available 

automatic defrost products is 40% (i.e. energy use is 40% lower than the baseline) and that the 

maximum efficiency level of the single manual defrost product is 0%. DOE is considering the 

27 California Energy Commission Appliance Database, <http://www.energy.ca.gov/appliances/database/index.html> 

39
 
      

possibility that manual defrost wine chillers do not exist and may eliminate this product class. 

See Item 3-5 above. Further, DOE believes that the highest-efficiency automatic defrost products 

use off-cycle defrost, and thus do not consume any energy (i.e. using an electric heater) to 

achieve defrost. Hence, there is no reason that automatic defrost wine chillers should use more 

energy than manual defrost models. For this reason, the energy use of such automatic defrost 

products with the highest level of efficiency available should be representative also of the energy 

use attainable by manual defrost products, even though no actual manual defrost units are 

commercially available at the corresponding efficiency levels. 

At a typical volume of 7 cubic feet (cu. Ft.), the manual defrost standard is 363 kWh/year. The 

automatic defrost standard is 466 kWh/year and a 40% reduction in energy use from this level is 

280 kWh/year. Hence, applying these figures, the max tech level for manual defrost products 

would be 1 - 280/363 = 23% or better. 

800
 

700
 

600
 

500
 

400
 

300
 

200
 

100
 

0

0 5 10 15 20

Automatic Defrost Manual Defrost

CEC Standard ‐ Automatic Defrost CEC Standard ‐ Manual Defrost

Total Volume (cubic feet)

Figure 5.1 Wine Chiller Efficiency Data 

DOE would expect to analyze improved efficiency levels for wine chillers and miscellaneous 

refrigeration products of up to 40% for automatic defrost products and up to 25% for manual 

defrost products (if DOE confirms that manual defrost wine chillers exist). However, these 

expected maximum levels may change, based on the results of further investigation and analysis. 

DOE notes that the maximum efficiency levels available in current products may not necessarily 

correspond to the max-tech levels. Maximum efficiency models may not incorporate all possible 

design options for increasing efficiency and, therefore, may not achieve an annual energy use as Unit Energy Consumption (UEC, kWh/year)

40
 
low as the max-tech level. It is also possible that some of the design options that have met the 

screening criteria (i.e., passed the screening analysis) may not yet be commercially available and, 

therefore, would not be found in today’s available maximum efficiency products. Given this 

potential dichotomy between max-tech and available maximum efficiency levels, and DOE’s 

obligation to analyze max-tech levels, DOE would seek stakeholder input to determine 

appropriate max-tech efficiency levels. (42 U.S.C. § 6295(p)(2)) 

It is not practicable for DOE to evaluate every product class or capacity range on the market, as 

the possible number of permutations is enormous. Instead, DOE would propose to evaluate 

several representative products in its reverse-engineering analysis that represent the majority of 

shipments and to then extrapolate the results to all products. DOE seeks comment on what to 

consider when selecting representative products. 

Item 5-3 DOE seeks input from stakeholders regarding the range of efficiency levels that 

should be examined as part of its analysis. 

Item 5-4 DOE seeks comment on how to select representative products for detailed 

analysis and on how to extrapolate such analyses to the full range of wine chiller and 

miscellaneous residential refrigeration products. 

5.5 Proprietary Designs 

DOE considers in its engineering and economic analyses all design options that are 

commercially available or present in a working prototype, including proprietary designs and 

technologies. However, DOE does not consider a proprietary design in the subsequent analyses if 

it is the only option for achieving a specific efficiency level. If the proprietary design is the only 

approach available to achieve a given efficiency level, then DOE rejects that efficiency level, as 

the analytical results would favor one manufacturer over others. 

DOE is sensitive to manufacturer concerns regarding proprietary designs and will make 

provisions to maintain the confidentiality of any proprietary data submitted by manufacturers or 

discussed during manufacturer interviews. These data may be provided under a confidentiality 

agreement with Navigant Consulting, Inc. (NCI), the DOE contractor that is responsible for this 

part of the rulemaking analysis. As in other rulemakings, NCI regularly works with confidential 

data from manufacturers and other organizations, preparing aggregated results for DOE’s 

analysis that do not divulge sensitive raw data, but that enable other stakeholders to review and 

comment on the aggregated dataset. Alternatively, stakeholders may submit confidential data to 

DOE, indicating in writing which data should remain confidential. To prevent public disclosure 

of the data due to actions taken by a third party, such as a request submitted to DOE under the 

Freedom of Information Act (FOIA), stakeholders providing confidential information to DOE 

must submit their data according to the requirements described in 10 CFR 1004.11, which 

addresses information that is exempt from public disclosure under FOIA. This information will 

provide input to the manufacturer impact analysis and other economic analyses. 

41
 
Item 5-5 Are there proprietary designs or technologies of which DOE should be aware for 

the products under consideration in this rulemaking? If so, how should DOE acquire the 

cost data necessary for evaluating these designs? 

5.6 Outside Regulatory Changes Affecting the Engineering Analysis 

In conducting an engineering analysis, DOE accounts for the effects of regulatory changes 

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

manufacturers of products addressed by the rulemaking, some of which can also affect the 

energy efficiency or energy consumption of those products. For example, because of the 

mandatory phase-out of chlorofluorocarbons (CFCs) in the mid-1990s, the industry had to 

eliminate its use of CFC-12 as a refrigerant and now uses HFC-134a (a hydrofluorocarbon). 

More recently (in 2003), the industry addressed the mandatory phase-out of HCFC-141b (a 

hydrochlorofluorocarbon), which was used as a blowing agent for polyurethane foam insulation. 

As a result, insulation is now blown with non-HCFC alternatives, including HFC-245fa, HFC134a, and cyclopentane. Both of the above changes occurred while the industry was making 

changes to address new standards; one set that became effective in 1993 and another set that 

became effective in 2001. 

During the recent residential refrigeration product rulemaking, DOE raised for discussion 

possible issues associated with an expected movement away from HFC use, which would impact 

their use as both refrigerants and insulation blowing agents. Since no regulations banning the use 

of HFCs currently exist, the consideration of such a ban as part of the analysis to set potential 

standards for regulated products would be speculative. 75 FR 59470, 59497 (September 27, 

2010) These limitations apply to any rulemaking that DOE may initiate for wine chillers and 

related refrigeration products. 

DOE will attempt to identify this and all other cumulative engineering issues that could affect the 

engineering analysis. The consideration of these issues is closely related to the cumulative 

regulatory burden assessment that DOE will carry out as part of the manufacturer impact 

analysis. Based on consideration of the comments that DOE receives on the engineering analysis 

that will accompany the upcoming preliminary analysis, DOE will make the necessary changes 

to the analysis and reflect those changes in the NOPR documentation. 

Item 5-6 Are there outside regulatory issues that DOE should consider in its analysis of 

residential wine chillers and miscellaneous refrigeration products? If so, please identify 

what they are and how DOE should consider them for purposes of its analysis. 

6. MARKUPS FOR EQUIPMENT PRICE DETERMINATION 

Because DOE would need retail (consumer) price data in order to establish the baseline 

efficiency level and all other efficiency levels under consideration for use in its lifecycle cost 

(LCC), payback period (PBP), and national impact analyses, DOE typically uses manufacturerto-consumer markups to convert the manufacturer selling price estimates from the engineering 

analysis to consumer prices. The manufacturer-to-consumer markups are in addition to the mark42
 
 

ups on production costs that DOE would use to estimate manufacturer selling price in the 

engineering analysis. To validate these markups, DOE would collect data on existing prices in 

the market by either purchasing large datasets or downloading data from retailer Internet sites. 

However, before it can develop markup information, DOE would first need to identify 

distribution channels (i.e., how the product is distributed from the manufacturer to the 

consumer). AHAM’s 2005 Fact Book (the latest available version) shows that over 93 percent of 

all appliances are distributed from the manufacturer directly to some type of retailer. Retailers 

identified in AHAM’s 2005 Fact Book include home improvement stores (such as Lowe’s or 

Home Depot), membership warehouse clubs/stores (such as Sam’s Club or Costco), department 

stores (such as Sears or Kohl’s), discount stores (such as Wal-Mart or Kmart), and appliance or 

consumer electronics stores. Because an overwhelming majority of appliances are sold through 

retail stores, DOE would analyze wine chiller product sales based on the assumption that these 

appliances are sold in a manufacturer-to-consumer distribution channel consisting of three 

parties: (1) the manufacturers producing the products; (2) retailers purchasing the products from 

manufacturers and selling them to consumers; and (3) the consumers that purchase the products. 

DOE would determine an average manufacturer markup by examining the annual Securities and 

Exchange Commission (SEC) 10-K reports filed by publicly traded manufacturers engaged in 

appliance manufacturing whose combined product range includes wine chillers and 

miscellaneous refrigeration products. DOE would determine an average retailer markup by 

analyzing both economic Census data from the U.S. Census Bureau as well as the annual SEC 

10-K reports filed by publicly traded retailers. 

In addition to developing the manufacturer and retailer markups, DOE would develop and 

include sales taxes to calculate appliance retail prices. The Sales Tax Clearinghouse28 is an 

Internet source that DOE would use to calculate applicable sales taxes. 

DOE would also use collected retail price data to validate the overall manufacturer-to-consumer 

markup. DOE has already purchased wine chiller sales data for the years 2007-2011 from NPD 

Group, Inc., which provides sales-weighted retail price data for wine chillers and miscellaneous 

refrigeration products. As an alternative to purchasing retail price data, DOE may also rely on 

retailers’ Internet sites, although the representativeness of any given price data point is unknown. 

This analysis would generate retail prices for each possible efficiency level, assuming that each 

level represents a new minimum efficiency standard. DOE would make this assumption to 

capture the effect that higher manufacturer production volumes of more efficient products from 

the standard may have on retail price. Because DOE would expect to develop a range of price 

estimates, it may describe new retail prices within a range of uncertainty. If the range of retail 

prices for each product is large enough, DOE would develop retail price probability distributions 

to use as inputs to the LCC and PBP analysis to determine the impact of the uncertainty on the 

economic feasibility of amended energy conservation standards. 

28 Sales Tax Clearinghouse, Inc., State sales tax rates along with combined average city and county rates. 

Available at http://thestc.com/STrates.stm. 

43
 
 

Item 6-1 DOE welcomes suggestions and comments concerning its proposed approach for 

developing estimates of future retail prices. 

7. ENERGY USE DETERMINATION 

The purpose of the energy use determination is to establish the annual energy consumption of the 

appliance and assess the energy-savings potential of different product efficiencies. DOE would 

use the annual energy consumption and energy-savings potential in the LCC and PBP analysis to 

establish the consumer operating savings of product efficiency levels. This section describes 

possible methodologies for developing the annual energy use of wine chillers in typical 

households. 

Typically for household appliances, DOE relies on the Energy Information Administration’s 

Residential Energy Consumption Survey29 (RECS) to estimate the appliance’s frequency of use 

or annual energy consumption. From RECS, DOE can develop a household sample that utilizes 

the appliance. From the household sample, DOE can develop not only a representative average 

annual energy use of the appliance, but the variability in appliance energy use across the 

households that utilize the product. Unfortunately, RECS has not attempted to obtain information 

on wine chillers. Therefore, DOE would need to rely on other sources of information to 

characterize wine chiller energy use. 

As described previously in section 1.2.1.3, California’s maximum energy use standards as a 

function of internal volume for auto- and manual defrost products could be combined with sales 

data from the NPD Group to estimate a range of annual energy use values for vapor-compression 

wine chillers. Because the total sales of each model in the NPD database are provided, this 

approach could yield an overall value for sales-weighted average energy consumption as well as 

a sales-weighted distribution of energy use values. 

However, there are at least two shortcomings to the above approach: (1) only the maximum 

possible energy use of each model in the NPD database can be defined, as opposed to its actual 

rated energy use, and (2) it is unknown as to whether the CEC test procedure provides a 

reasonable estimate of wine chiller annual energy use. To address the first issue, DOE could 

utilize the energy use of wine chiller models in CEC’s database as described in section 5.4 and 

depicted in Figure 5.2 to express the energy use of models in the NPD database with some level 

of statistical uncertainty. For a given internal volume, the uncertainty could be based on model 

availability at specific energy use values. To address the second issue, DOE would attempt to 

collect data that can validate the energy use estimates based on the CEC test procedure. 

Currently, DOE has been unable to identify sources of wine chiller energy use information. 

Because of the apparent lack of energy use data, DOE may rely on in situ field measurements as 

a means to characterize wine chiller energy use. 

29 Available at: http://www.eia.doe.gov/emeu/recs/contents.html. 

44
 
 

If the above method of developing annual energy use estimates based on the combination of 

NPD sales data, CEC model data, and California’s efficiency standards equations for establishing 

maximum energy use prove to be untenable, DOE may need to resort to characterizing wine 

chiller energy use with a sensitivity analysis to determine how high and low estimates of energy 

use might impact the economic feasibility of any amended energy conservation standards. 

Item 7-1 DOE seeks comments on the proposed approach of estimating the annual energy 

consumption of wine chillers based on a combination of NPD sales data, CEC model data, 

and California’s energy conservation standards equations for establishing maximum 

energy use. 

Item 7-2 DOE seeks input on potential data sources for establishing the annual energy 

consumption of wine chillers. 

Item 7-3 DOE seeks comments on the viability of using in situ field measurements of wine 

chiller energy use as a proposed basis for characterizing the product’s energy 

consumption. 

Item 7-4 DOE seeks comments on whether annual energy use is best characterized with a 

sensitivity analysis to determine how high and low estimates of energy use might impact the 

economic feasibility of any amended energy conservation standards. 

DOE would account for the rebound effect in its determination of annual energy consumption. 

The rebound effect occurs when a more efficient product is used more intensively because its 

increased efficiency mitigates the cost of the additional use. This effect diminishes the expected 

energy savings from the efficiency improvement. In the case of more efficient domestic 

refrigeration equipment, limited research has been conducted to show that there is no rebound 

effect for home appliances (i.e. appliances not including space-conditioning and water-heating 

equipment), although the consumer may choose to purchase larger models with more features, 

which would result in increased energy use.30 

Item 7-5 DOE seeks comments on the rebound effect associated with more efficient wine 

chillers. In other words, DOE seeks input on what portion of the energy savings resulting 

from more efficient equipment may be lost due to consumers purchasing larger or more 

feature laden equipment. 

30 L.A. Greening, D.L. Greene, and C. Difiglio. Energy efficiency and consumption – the rebound effect – a survey, 

Energy Policy 28 (2000) 389—401. Available for purchase at www.elsevier.com/locate/enpol 

45 
8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

The effects of increased energy conservation standards on a consumer of a product include a 

change in operating expense (usually decreased) and a change in purchase price (usually 

increased). DOE normally analyzes the net effect on consumers by calculating the LCC and PBP 

using the engineering performance data (as described in section 5), the equipment retail prices 

(as described in section 6), and the energy consumption data (as described in section 7). Inputs to 

the LCC and PBP calculation would include the total installed cost to the consumer (purchase 

price plus any installation cost) and operating cost (energy expenses and, if applicable, repair 

costs, and maintenance costs). Additional inputs to the LCC calculation would include energy 

price forecasts, the lifetime of the appliance or other defined period of analysis, and discount 

rates. 

8.1 Approach for Conducting the LCC and PBP Analysis 

In the preliminary analysis stage of the wine chiller rulemaking, DOE would conduct the LCC 

and PBP analysis by modeling both the uncertainty and variability in the inputs using Monte 

Carlo simulation and probability distributions. The Monte Carlo approach provides a significant 

advantage over less sophisticated approaches (e.g., an approach using typical or average values 

to characterize inputs) by identifying the percentage of consumers benefiting and being burdened 

by a prospective standard. 

DOE would develop an LCC and PBP model that incorporates both Monte Carlo simulation and 

probability distributions by using Microsoft Excel spreadsheets combined with Crystal Ball (a 

commercially available add-in program). Each Monte Carlo simulation would consist of 10,000 

LCC and PBP calculations. The model would perform each calculation using input values that 

are sampled from probability distributions or characterized with single point values. The analysis 

results would be a distribution of 10,000 data points showing the range of LCC savings and 

PBPs for a given efficiency level relative to the baseline level. 

With the exception of repair and maintenance costs, DOE would use probability distributions to 

characterize the operating cost inputs to the LCC and PBP analysis, including product lifetimes 

and consumer discount rates. As described previously in section 6, DOE would attempt to use an 

approach that relies on a combination of NPD sales data, CEC model data, and California’s 

energy conservation standards equations for maximum allowable energy use to establish the 

product’s annual energy consumption. If this approach is successful, wine chiller energy use 

would be characterized with sales-weighted probability distributions. As described below, the 

LCC and PBP analysis would capture the regional variability in electricity prices. The 

methodology for developing maintenance and repair costs is described in more detail below. 

DOE would expect to use point values to characterize most of the total installed cost inputs, 

including the manufacturer markup and the retailer markup. DOE would expect that installation 

costs would be negligible. If the manufacturer cost estimates developed in the engineering 

analysis are characterized with uncertainty or variability, DOE would use probability 

distributions to capture this uncertainty and variability; otherwise, DOE would use single point 

46
 
values for this input as well. DOE would characterize sales taxes with probability distributions to 

capture their regional variability. 

Another factor in identifying which consumers benefit from or are burdened by a prospective 

standard is the distribution of product efficiencies currently being sold in the marketplace, 

referred to as market-share efficiency data. In the case of wine chillers, product efficiency is 

expressed as annual energy use. Assuming these data are available, DOE would characterize the 

current product mix with probability distributions. DOE would determine the LCC and PBP for a 

particular standard level based on the distribution of appliance efficiencies. For example, in 

performing an iteration of the Monte Carlo simulation for a given consumer, product efficiency 

will be chosen based on its probability. If the chosen product efficiency is greater than or equal 

to the efficiency of the standard level under consideration, the LCC and PBP calculation would 

reveal that a consumer is not impacted by the standard level. By accounting for consumers who 

already purchase more-efficient products, DOE would avoid overstating the potential benefits 

from increasing product efficiency. To enable DOE to use this methodology, DOE would ask 

stakeholders — presumably either AHAM or individual manufacturers — to provide data on the 

current mix of product efficiencies, to account for those consumers already purchasing high 

efficiency products. Without such data, DOE could use the CEC model data described in section 

5.4 to develop efficiency distributions based on model availability. 

As discussed in section 7, DOE would take into account the rebound effect associated with more 

efficient wine chillers. The “take-back” in energy consumption associated with the rebound 

effect provides consumers with increased value (e.g., more refrigerator internal volume). The net 

impact on consumers is thus the sum of the change in the cost of owning the refrigeration 

equipment (i.e., life-cycle cost) and the increased value for the enhanced product features or 

usage patterns. DOE believes that if it were able to monetize the increased value to consumers 

added by the rebound effect, this value would be similar in value to the foregone energy savings. 

For this potential standards rulemaking, DOE estimates that this value would be equivalent to the 

monetary value of the energy savings that would have occurred without the rebound effect. 

Therefore, the economic impacts on consumers with or without the rebound effect, as measured 

in the LCC analysis, would be the same. 

DOE would conduct the LCC and PBP analysis only for the two representative product classes 

on which it plans to perform an engineering analysis (see section 5.2). To identify the consumers 

who benefit from or are burdened by a prospective standard, DOE requests base-case efficiency 

distributions or market-share efficiency data from the industry. 

During the NOPR stage, DOE may evaluate additional parameters not included in the 

preliminary analysis based upon information provided by stakeholders or which otherwise 

becomes available to the Department. 

Based on the results of the LCC analysis, DOE would select CSLs for the preliminary analysis. 

The range of CSLs typically includes the efficiency level with the minimum LCC, the highest 

efficiency level that is technologically feasible, and other intermediate levels DOE has not yet 

determined. 

47
 
 

The following sections discuss the methodologies DOE would use to develop several of the 

inputs to the LCC and PBP analysis, including (1) electricity prices; (2) maintenance, repair, and 

installation costs; (3) product lifetimes; and (4) discount rates. The other inputs to the LCC and 

PBP analysis—namely, manufacturer costs (section 5), markups for the determination of 

consumer retail prices (section 6), and annual energy consumption (section 7)—have been 

discussed previously. 

DOE is also required to perform a PBP analysis to determine whether the three-year rebuttable 

presumption of economic justification applies (in essence, whether the purchaser will recover the 

higher installed cost of more energy efficient equipment through lowered operating costs within 

three years). (42 U.S.C. § 6295(o)(2)(B)(iii)) To determine the rebuttable-presumption PBP, 

DOE would determine the value of the first year’s energy savings by calculating the quantity of 

those savings in accordance with DOE’s test procedure. Although DOE will examine the 

rebuttable-presumption criteria, it would determine whether selected CSLs are economically 

justified through a more detailed analysis of the economic impacts of increased efficiency 

pursuant to section 325(o)(2)(B)(i) of EPCA. (42 U.S.C. § 6295(o)(2)(B)(i)) 

In preparing the NOPR, DOE would carefully review all of the comments it receives on the 

preliminary analysis LCC analysis, make any necessary revisions to the analysis, and evaluate 

additional parameters not included in the preliminary analysis, if necessary. 

Item 8-1 DOE seeks stakeholder input on the proposed approach of using probability 

distributions and Monte Carlo simulation to conduct the LCC and PBP analysis. 

Item 8-2 DOE requests data from stakeholders to characterize the current mix of wine 

chiller efficiencies in the market. 

8.2 Electricity Prices 

DOE would develop estimates of average electricity prices using EIA data covering 13 

geographic areas — the nine U.S. Census divisions, with four large States (New York, Florida, 

Texas, and California) treated separately. For Census divisions containing one of these large 

States, DOE would calculate the regional average values, leaving out data for the large State— 

for example, the Pacific region average will not include California, and the West South Central 

region average will not include Texas. DOE would develop a discrete probability distribution 

consisting of 13 regional electricity prices based on the household population in each region. 

Therefore, DOE would be able to assess the variability of energy prices at the regional level for 

residential wine chillers. 

To calculate electricity prices for residential consumers in each of the above geographic areas, 

DOE would use information provided by electric utilities as summarized in the most recent EIA 

Form 861 data.31 These data, which cover the residential, commercial, and industrial sectors for 

every utility serving final customers, are published annually and include annual electricity sales 

in kWh, revenues from electricity sales, and number of consumers. The calculation of an average 

31 Available at http://www.eia.doe.gov/cneaf/electricity/page/eia861.html. 

48
 
 

 

residential electricity price would proceed in two steps: (1) for each utility, estimate an average 

residential price by dividing the residential revenues by residential sales; and (2) calculate a 

regional average price, weighting each utility with customers in a region by the number of 

residential consumers served in that region. 

DOE would use projections of national average electricity prices to residential consumers to 

estimate future energy prices in its LCC analysis. DOE would use the most recently available 

edition of EIA’s Annual Energy Outlook (AEO) as the default source of projections for future 

energy prices. 

Item 8-3 DOE seeks stakeholder input on the planned approach for estimating current and 

forecasted energy prices. 

8.3 Maintenance, Repair, and Installation Costs 

DOE would consider any expected changes to maintenance, repair, and installation costs for the 

wine chillers covered in this rulemaking. Typically, small incremental changes in product 

efficiency incur little or no changes in repair and maintenance costs over baseline products. 

There is a greater probability that equipment with efficiencies that are significantly higher than 

the baseline will incur increased repair and maintenance costs, since such equipment is more 

likely to incorporate technologies that are not widely available. DOE would rely on input from 

manufacturers and other stakeholders in developing appropriate repair and maintenance cost 

estimates, as necessary. 

With regard to installation costs, unless the increased efficiency levels considered for this 

rulemaking result in significantly larger or heavier products, DOE would expect that moreefficient wine chillers will not incur increased installation costs. 

Item 8-4 DOE seeks stakeholder input on the merits of its proposed analytical assumption 

that changes in maintenance, repair, and installation costs will be negligible for moreefficient residential wine chillers. If it is incorrect, DOE is interested in the reasons why 

this is so and in specific ways in which to correct this assumption. 

8.4 Product Lifetimes 

DOE has been unable to identify sources to establish an estimated generic wine chiller lifetime. 

Without data specific to wine chillers, DOE may need to rely on data specific to residential 

standard-sized and compact-sized refrigerator-freezers and freezers. For standard-sized 

refrigerator-freezers and freezers, DOE has characterized survival functions with Weibull 

distributions that have mean lifetimes of 17.4 and 22.3 years, respectively. For compact 

refrigerators and freezers, DOE has developed survival functions that have mean lifetimes of 5.6 

and 7.5 years, respectively.32 

32 U.S. DOE, Technical Support Document for Refrigerators, Refrigerator-Freezers, and Freezers. September 2010. 

< http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers.html> 

49
 
 

 

 

DOE would use information from available literature sources as well as input from 

manufacturers and other stakeholders to establish specific wine chiller lifetimes or whether the 

above product lifetimes for standard-sized and compact-sized refrigerators, refrigerator-freezers, 

and freezers are also representative of wine chillers. 

Item 8-5 DOE seeks stakeholder input on appropriate product lifetimes for wine chillers. 

Specifically, DOE seeks data sources for establishing product lifetimes and information 

regarding the merits of whether standard-sized and compact-sized refrigerator, 

refrigerator-freezer, and freezer lifetimes are representative of wine chillers. 

8.5 Discount Rates 

The calculation of consumer LCC requires the use of an appropriate discount rate. DOE would 

use the discount rate to determine the present value of lifetime operating expenses. The discount 

rate used in the LCC analysis represents the rate from an individual consumer’s perspective.33 

For residential consumers of wine chillers, DOE would use the same approach that it relied on to 

develop discount rates for its recent standards rulemakings for other residential products—i.e., 

deriving the discount rates from estimates of the interest or “finance cost” to purchase residential 

products. The finance cost of raising funds to purchase these products can be interpreted as (1) 

the financial cost of any debt incurred to purchase products (principally interest charges on debt), 

or (2) the opportunity cost of any equity used to purchase products (principally interest earnings 

on household equity). Household equity is represented by holdings in assets such as stocks and 

bonds, as well as the return on homeowner equity. Much of the data required for determining the 

cost of debt and equity comes from the Federal Reserve Board’s triennial Survey of Consumer 

Finances.

34 

Item 8-6 DOE seeks stakeholder input on the planned approach for estimating discount 

rates for residential consumers. 

Based on consideration of the comments received on the LCC and PBP analysis documented for 

the preliminary analysis, DOE would make the necessary changes to the analysis, and reflect 

those changes in the documentation of the NOPR. 

9. SHIPMENTS ANALYSIS 

Shipments forecasts are required to calculate the national impacts of standards (NES and NPV) 

and to calculate the future cash flows of manufacturers. DOE would develop shipments forecasts 

based on an analysis of key market drivers for the particular products. 

33 The consumer discount rate is in contrast to the discount rates used in the national impact analysis, which are 

intended to represent the rate of return of capital in the U.S. economy as well as the societal rate of return on 

private consumption. Refer to section 10.3 for additional information. 

34 Available at http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html. 

50
 
9.1 Base-Case Forecast 

To evaluate the various impacts of standards, DOE would develop a base-case forecast against 

which to compare forecasts for higher efficiency levels. (Higher efficiency level forecasts are 

also referred to as standards-case forecasts.) DOE would design the base-case to depict what 

would be anticipated to happen to energy consumption and costs over time if DOE does not 

adopt energy conservation standards. In determining the base-case for each set of products, DOE 

would calibrate its forecasts against historical shipments. DOE would also consider the mix of 

efficiencies sold in the absence of new standards and how that mix might change over time. As a 

result, DOE would need to collect data on historical product shipments and the market shares of 

the different efficiency levels offered in each product class. Based on detectable trends in the 

collected efficiency data, DOE would forecast base-case shipment-weighted efficiencies 

(SWEF). Forecasts of SWEFs are discussed in greater detail below in section 10.1. 

As discussed previously in section 1.2.1.3, DOE has already reviewed historical shipments data 

from two sources: (1) data provided by AHAM as part of the residential refrigerator standards 

rulemaking and (2) sales data from the NPD Group. The AHAM shipments data are for the years 

2005-2007. The NPD Group’s sales data are for the five years spanning 2007-2011, and, 

according to NPD, represent 30% to 45% of total industry sales. Unfortunately, the estimates 

from the two sources are extremely different with NPD estimates as much as ten times greater 

than AHAM’s estimates. Because AHAM does not represent all wine chiller manufacturers, and 

not all of AHAM’s members necessarily reported their sales data, DOE suspects that the 

shipments estimates from the NPD Group are more representative. Due to the limited availability 

of shipments data, DOE would be taking into consideration any other sources or data provided 

by stakeholders. Without such data, DOE would rely exclusively on the AHAM and NPD data to 

construct scenarios of historical base-case shipments. 

Because little is known regarding the adoption of wine chillers in existing and new households, 

and the limited historical data do not provide observable trends that can be relied upon to 

forecast shipments trends into the future, DOE would likely forecast base-case shipments using a 

number of scenarios. These scenarios may range from constant shipments (based either on a 

historical average observed in either the AHAM or NPD datasets or the lowest and highest 

shipments seen in the historical data) to increases in shipments tied to overall economic growth 

as indicated by the gross domestic product (GDP). 

Item 9-1 DOE seeks historical shipments data from stakeholders. If such data are 

provided, DOE requests that market share data showing the percentage of product 

shipments for compressor/condenser-based and thermoelectric-based products be 

included. 

Item 9-2 If stakeholders are unable to provide historical shipments data, DOE seeks 

comment on which data source is more representative of historical shipments, the AHAM 

shipments data or the NPD Group sales data and why. 

51
 
Item 9-3 DOE seeks input on the types of potential scenarios it should use to forecast basecase shipments and the reason(s) for the suggested scenario(s). 

9.2 Standards Impacts on Product Shipments 

DOE would develop a set of shipment forecasts for each set of efficiency levels analyzed. It 

would use these standards-case forecasts to evaluate the impacts of standards on product 

shipments. DOE would derive standards-case forecasts using the same data sets as it used for the 

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 standards, forecasted shipments 

typically deviate from the base-case. Household income also factors into consumer purchase 

decisions. Therefore, the magnitude of the difference between the standards-case and base-case 

shipment forecasts depends on the estimated purchase price increase and the operating cost 

savings caused by the standard, relative to household income. Because the purchase price tends 

to have a larger impact than operating cost on appliance purchase decisions, standards-case 

forecasts typically show a drop in product shipments relative to the base-case. 

DOE’s past standards analyses have attempted to quantify the sensitivity of shipments to 

increased purchase prices and operating cost savings as well as to changes in household income. 

For example, DOE has conducted literature reviews and analyses of historical appliance price 

and efficiency data to develop sensitivities. Although DOE would attempt to develop purchase 

price and operating cost sensitivities for wine chillers since the data required to develop these 

sensitivities are likely to be unavailable, DOE would also consider modeling standards-case 

shipments forecasts with scenarios (i.e., specified impacts to product shipments), if necessary. 

Market-pull programs, such as consumer rebate programs that encourage the purchase of moreefficient products and manufacturer tax credits that encourage the production of more-efficient 

products, also affect standards-case shipments forecasts. To the extent that such programs exist, 

DOE would consider their impact on the forecast of both base-case and standards-case 

shipments. 

Item 9-4 As part of a possible preliminary manufacturer impact analysis, DOE seeks 

input from manufacturers on the potential impact of new energy conservation standards 

on wine chiller shipments. DOE also seeks input from other stakeholders on the potential 

impact of standards on product shipments. 

Item 9-5 DOE also requests input on any market-pull programs that currently exist to 

promote the adoption of more-efficient wine chillers. 

52
 
 

10. NATIONAL IMPACT ANALYSIS 

Section 8 discusses methods for estimating the LCC savings and PBP for individual consumers. 

This section discusses DOE’s assessment of the aggregate impacts of potential efficiency 

standards at the national level. Measures of impact that DOE will report include the future NES 

from candidate standards and the NPV of total consumer life-cycle costs. 

10.1 Inputs to NES and NPV Forecasts 

Analyzing impacts of Federal energy conservation standards for wine chillers requires a 

comparison of projected U.S. energy consumption with, and without, new or amended energy 

conservation standards. The forecasts contain projections of annual appliance shipments (section 

9), the purchase price of new appliances (section 6), and the annual energy consumption of new 

appliances (section 7). 

A key component of DOE’s estimates of NES and NPV are the product energy efficiencies 

forecasted over time for the base-case (without new standards) and each of the standards cases. 

For wine chillers, the forecasted efficiencies represent the annual shipment-weighted annual 

energy consumption of the products under consideration over the forecast period (i.e., from the 

assumed compliance date of a new standard to 30 years after that date). Because key inputs to the 

calculation of the NES and NPV (annual energy consumption for the NES, and retail prices and 

annual operating costs for the NPV) depend on the estimated efficiencies, these efficiencies are 

very important to the analysis. 

For past home appliance standards rulemakings, DOE relied on stakeholder input, particularly 

AHAM and appliance manufacturers, to develop base-case historical SWEF estimates. Although 

DOE hopes that AHAM and manufacturers will provide similar historical SWEF data for wine 

chillers, because of the apparent lack of information for this product, DOE may need to rely on 

other sources to develop such data. One option might be for DOE to use CEC data and develop 

average historical efficiencies for each year that such data are available. 

To develop SWEFs for the various standards cases, DOE hopes to develop market-share 

efficiency data (i.e., data on the distribution of product shipments by efficiency) for the wine 

chiller product classes DOE is currently considering. As discussed in section 8.1, these are the 

same market-share efficiency data (otherwise known as base-case efficiency distributions) that 

DOE is requesting for the LCC and PBP analysis so DOE can accurately quantify the percent of 

consumers that benefit from an increase in the minimum energy conservation standard. Realizing 

that this information may not be available, DOE could use the CEC model data described in 

section 5.4 to develop efficiency distributions based on model availability. 

The market-share efficiency data will allow DOE to estimate the efficiency impact that standards 

may have in the year manufacturers must begin to comply with them. For example, DOE has 

assumed a “roll-up” scenario for past standards rulemakings.35 Under this scenario, DOE 

35 For example, the residential central air conditioner standards rulemaking considered a “roll-up” scenario when 

estimating the impact of standards. Refer to the Chapter 7 of the central air conditioner TSD for more details, 

which is available at 

http://www.eere.energy.gov/buildings/appliance_standards/residential/ac_central_1000_r.html. 

53
 
 

assumes (1) product efficiencies in the base-case that do not meet the standard level under 

consideration would “roll up” to meet the new standard level; and (2) product efficiencies above 

the standard level under consideration would not be affected. Once DOE establishes the 

shipment-weighed efficiency for the assumed effective date of the standard, it could estimate 

future shipment-weighted efficiencies using the same rate of forecasted efficiency growth as in 

the base-case efficiency trend. 

Item 10-1 DOE seeks historical SWEF data for wine chillers. DOE also seeks historical 

market share data showing the percentage of product shipments by efficiency level. 

10.2 National Energy Savings 

DOE intends to calculate national energy consumption for each year beginning with the expected 

effective date of the standards. It will calculate national energy consumption 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 shipment forecasts by unit energy savings, 

accounting for the stock of appliances affected by standards. 

In response to comments by stakeholders who asked for a simple, transparent model, DOE has 

developed NES spreadsheet models for its standards rulemakings since 1996, to forecast energy 

savings and to demonstrate how the growth in efficiency can be accounted for over time.36 

Although these models are specific to each product, DOE believes their general structure is 

applicable to the wine chiller market. DOE expects the NES spreadsheet model it develops for 

this rulemaking to provide a credible, stand-alone forecast of NES and NPV for residential wine 

chillers. 

As discussed in section 7, DOE intends to take into account the rebound effect associated with 

more efficient wine chillers. DOE will incorporate the rebound effect utilized in the energy use 

analysis into its calculation of national energy savings. 

Based on consideration of the comments DOE may receive on the preliminary analysis, DOE 

will make any necessary changes to the analysis. It will reflect those changes in the 

documentation for the NOPR. 

Item 10-2 DOE seeks input on its plan to develop NES spreadsheet models for estimating 

national impacts of amended energy conservation standards for wine chillers. For 

example, are spreadsheet models still the preferred approach for estimating national 

impacts? 

36 Several NES spreadsheet models from previous rulemakings, including the rulemaking for residential clothes 

washers, can be found on DOE’s website at www.eere.energy.gov/buildings/appliance_standards. 

54 
10.3 Net Present Value 

DOE calculates the national NPV of energy conservation standards in conjunction with the NES. 

It calculates annual energy expenditures from annual energy consumption by incorporating 

forecasted energy prices, using the shipment and average energy efficiency forecasts described in 

section 9. DOE calculates annual equipment expenditures by multiplying the price per unit by 

the number of forecasted shipments. The difference between a base-case and a standards-case 

scenario gives the national energy bill savings and increased equipment expenditures in dollars. 

The difference each year between energy bill savings and increased equipment expenditures is 

the net savings (if positive) or net costs (if negative). DOE discounts these annual values to the 

present time and sums them to give a net present value. Consistent with guidelines set by the 

U.S. Office of Management and Budget (OMB), DOE will conduct two NPV calculations, one 

using a real discount rate of three percent and another using a real discount rate of seven percent 

(OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). The discount rates for the 

determination of NPV are in contrast to the discount rates used in the LCC analysis (which are 

developed from a consumer’s perspective). The seven percent real value is an estimate of the 

average before-tax rate of return to private capital in the U.S. economy. The three percent real 

value represents the “societal rate of time preference,” which is the rate at which society 

discounts future consumption flows to their present value. Based on consideration of the 

comments received on the preliminary analysis, DOE will make any necessary changes to the 

analysis and the CSLs. 

As noted above in section 10.2, DOE intends to take into account the rebound effect associated 

with more efficient wine chillers in its determination of national energy savings. As discussed 

section 8, because the rebound effect provides consumers with increased value, DOE believes 

that if it were able to monetize the increased value to consumers added by the rebound effect, 

this value would be similar in value to the foregone energy savings. For this standards 

rulemaking, DOE estimates that this value is equivalent to the monetary value of the energy 

savings that would have occurred without the rebound effect. Therefore, the economic impacts 

on consumers with or without the rebound effect, as measured in the NPV, are the same. 

11. LIFE-CYCLE COST SUBGROUP ANALYSIS 

This section describes how DOE analyzes the consumer impact of any new standards by dividing 

consumers into subgroups and accounting for variations in key inputs to the LCC analysis. A 

consumer subgroup comprises a subset of the population that is likely, for one reason or another, 

to be affected disproportionately by new or revised energy conservation standards. The purpose 

of a subgroup analysis is to determine the extent of this disproportional impact. DOE will work 

with stakeholders early in the rulemaking process to identify any subgroups for consideration. 

However, DOE will not analyze the consumer subgroups until the NOPR stage of the analysis. 

In comparing potential impacts on the different consumer subgroups, DOE will evaluate 

variations in regional electricity prices, energy use profiles, and purchase prices that might affect 

the LCC of an energy conservation standard to certain consumer subgroups. To the extent 

possible, DOE may obtain estimates of the variability in each input variable and consider this 

55
 
variability in its calculation of consumer impacts. DOE will discuss with stakeholders the 

variability in each input variable and likely sources of information. 

Item 11-1 DOE requests input as to what, if any, consumer subgroups are appropriate in 

considering standards for wine chillers. 

12. MANUFACTURER IMPACT ANALYSIS 

DOE conducts its manufacturer impact analyses consistent with the Report to Congress, “Energy 

Conservation Standards Activities” (Jan. 31, 2006) (required report under Section 141 of the 

Energy Policy Act of 2005) (Standards Activities), available at 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/congressional_report_013106.p 

df. 

DOE had not previously reported any manufacturer impact analysis results during the 

preliminary analysis phase; however, under the new format, DOE collects, evaluates, and reports 

preliminary information and data in the preliminary analysis. (See Standards Activities, p. 54.) 

Such preliminary information includes the anticipated conversion capital expenditures by 

efficiency level and the corresponding anticipated impacts on employment. DOE solicits further 

information during the preliminary analysis phase through the manufacturer interviews 

conducted as part of that phase’s engineering analysis. A draft set of questions to be used for 

those interviews is contained in Appendix A. 

DOE intends manufacturer impact analyses to help assess the potential impacts of energy 

conservation standards on manufacturers of products subject to new or revised energy standards. 

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 

these products. DOE identifies these effects through interviews with manufacturers, as well as 

other stakeholders and experts. 

For the NOPR, DOE supplements the results of the preliminary MIA conducted as part of the 

preliminary analysis with more detailed analyses, described in sections 12.1 through 12.5. 

Specifically, DOE carries out an industry-wide cash flow analysis using the Government 

Regulatory Impact Model (GRIM), identifies and analyzes subgroups of manufacturers whose 

business varies significantly from the industry as a whole, perform a competitive impacts 

assessment, and review the cumulative regulatory burden for the industry. 

12.1 Sources of Information for the Manufacturer Impact Analysis 

Many of the analyses described earlier provide important information that DOE uses as inputs 

for the manufacturer impact analysis. Such information includes financial parameters developed 

in the market assessment (section 3.1), manufacturing costs and prices from the engineering 

analysis (section 5.3), retail price forecasts (section 6), and shipments forecasts (section 9). DOE 

supplements this information with information gathered during manufacturer interviews. 

56
 
 

DOE conducts detailed interviews with manufacturers to gain insight into the range of potential 

impacts of standards. The interview process plays a key role in the manufacturer impact analysis 

by providing an opportunity for directly affected parties to express their views on important 

issues. During the interviews, DOE solicits 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 terms of this 

analysis. DOE schedules interviews well in advance to provide every opportunity for key 

individuals to be available to participate. In addition, DOE provides manufacturers with the 

questionnaire before the interviews to facilitate the gathering of the appropriate information. 

Although a written response to its questionnaire is acceptable, DOE prefers an interactive 

interview process, because it helps clarify responses and provides the opportunity to identify 

additional issues. 

DOE asks interview participants to identify all confidential information provided in writing or 

orally, and DOE determines whether the information submitted is entitled to confidential 

treatment. It considers information gathered, as appropriate, in the energy conservation standards 

decision-making process. However, DOE does not make confidential information available in 

the public record. DOE also asks participants to identify all information that they wish to have 

included in the public record but that they do not want to have associated with their interview 

that would identify that particular manufacturer; DOE incorporates this information into the 

public record, but reports it without attribution. 

DOE collates the completed interview questionnaires and prepares a summary of the major 

issues and outcomes. This summary becomes part of the TSD produced in a rulemaking. 

12.2 Industry Cash Flow Analysis 

The industry cash flow analysis relies primarily on the GRIM. DOE uses the GRIM to analyze 

the financial impacts of new or more stringent energy conservation standards on the industries 

that produce the products covered by the standard. 

The GRIM analysis uses a number of inputs—annual expected revenues; manufacturer costs 

such as costs of goods sold; selling, general, and administrative costs; taxes; and capital 

expenditures (both ordinary capital expenditures and those related to standards)—to determine 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 basecase projections that involve no new standards. The financial impact of new standards is the 

difference between the two sets of discounted annual cash flows. Other performance metrics, 

such as return on invested capital, also are available from the GRIM. 

DOE gathers the inputs needed for the GRIM from two primary sources: (1) the analyses 

conducted to this point; and (2) interviews with manufacturers and other stakeholders. 

Information gathered from previous analyses includes financial parameters, manufacturing costs, 

price forecasts, and shipments forecasts. Interviews with manufacturers and other stakeholders 

are essential in supplementing this information. 

57
 
12.3 Manufacturer Subgroup Analysis 

It is possible that the use of average industry cost values may not adequately assess differential 

impacts among subgroups of manufacturers. DOE recognizes that smaller manufacturers, niche 

players, and manufacturers exhibiting a cost structure that differs significantly from the industry 

average may be affected differently 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 uses the results of the market and 

technology assessment to group manufacturers into subgroups, as appropriate. 

Small businesses, as defined by the Small Business Administration (SBA) for household 

refrigerator and home freezer manufacturers, are enterprises with 1000 employees or fewer. 

Small business size standards are listed by North American Industry Classification System 

(NAICS) code and industry description. Household refrigerator and home freezer manufacturing 

is classified under NAICS 335222. A search of small businesses of this NAICS code listed in the 

U.S. Small Business Association website indicates that there may be thirteen small businesses 

that manufacture wine chillers and related products that would potentially be covered by this 

potential rulemaking. However, as this NAICS code covers all household refrigerator and home 

freezer manufacturing, it is not clear how many of these manufacturers produce residential wine 

chillers and other miscellaneous refrigeration products. As part of its subgroup analysis, DOE 

would identify small businesses that manufacture these products and interview small businesses 

affected by the rulemaking to determine if there are differential impacts on these companies that 

may result from new energy conservation standards. DOE examines publicly available data and 

contacts manufacturers, when needed, to determine if they meet the SBA’s definition of a small 

manufacturing facility and if their manufacturing facilities are located within the United States. 

The detailed manufacturer subgroup impact analysis entails calculating cash flows separately for 

each defined class of manufacturer. 

Item 12-1 DOE seeks comment on the appropriate manufacturer subgroups, if any, for 

residential wine chillers and miscellaneous refrigeration products that DOE should 

consider in a manufacturer subgroup analysis. 

12.4 Competitive Impacts Assessment 

EPCA directs DOE to consider any lessening of competition that is likely to result from an 

imposition of standards. (42 U.S.C. § 6295(o)(2)(B)(i)(V) and 6316(a)) 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 6316(a)) 

DOE makes a determined effort to gather and report firm-specific financial information and 

impacts, and it will then report the aggregated impact of the standard on manufacturers. The 

competitive impacts analysis focuses on assessing the impacts to smaller, yet significant, 

manufacturers. DOE bases the assessment on manufacturing cost data and on information 

collected from interviews with manufacturers. These interviews focus on gathering information 

that will help in assessing asymmetrical cost increases to some manufacturers, increased 

58
 
 

 

proportion of fixed costs potentially increasing business risks, and potential barriers to market 

entry (e.g., proprietary technologies). DOE provides the Attorney General with a copy of the 

NOPR for consideration in his/her evaluation of the impact of standards on the lessening of 

competition. 

12.5 Cumulative Regulatory Burden 

DOE is aware that other regulations may apply to products which may be covered under this 

potential rulemaking, as well as to other products made by the same manufacturers covered 

under this potential rulemaking. Multiple regulations may result in a significant, cumulative 

regulatory burden on these manufacturers. Accordingly, DOE analyzes and seeks to mitigate the 

overlapping effects of amended DOE standards and other regulatory actions on manufacturers of 

residential refrigeration products. DOE is aware that home appliance manufacturers and trade 

groups have issued public comments concerning the excessive regulation of the home appliance 

industry in comparison to others and will consider these concerns during the manufacturer 

impact analysis. 

Regulations that could affect the industries affected by this potential rulemaking include: 

•	 DOE standards for residential refrigeration products  Manufacturers have previously 

gone through redesign cycles mandated by standards for residential refrigeration products 

enacted since 1990; 

•	 Phaseout of HCFC blowing agents in 2003—Manufacturers predominantly switched to 

HFC-245fa blowing agent when HCFC-141b was phased out in 2003. However, different 

manufacturers may have chosen alternative approaches and as a result may be in differing 

positions with regard to foam insulation conductivity levels achieved in their production 

lines. 

•	 Reduction of Hazardous Substances (RoHS) directive – The Directive on the Restriction 

of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment was 

adopted in February 2003 by the European Union (EU) and became effective July 1, 

2006.37 RoHS identifies specific categories of products that can contain no more than 

threshold amounts of mercury, lead, cadmium, hexavalent chromium, and two fire 

retardants. Although this legislation does not currently extend to residential refrigeration 

products in the U.S., domestic manufacturers selling to the EU market must produce 

RoHS-compliant appliances. These manufacturers may choose to include the associated 

design changes across their entire product line. 

•	 Legislation limiting use of Greenhouse Gases – The possibility of legislation to limit the 

use of greenhouse gases was discussed as part of the recent refrigeration product 

rulemaking. 76 FR 57516 (Sept. 15, 2011). While no such legislation has been enacted, if 

such legislation is enacted prior to the end of this rulemaking, it will impose impacts on 

manufacturers, who will need to consider converting both refrigerants and foam 

insulation blowing agents to alternative substances that have less global warming impact. 

Such changes may require capital expenditures, but may also impact product design 

options. 

37 http://ec.europa.eu/environment/waste/weee/index_en.htm. 

59
 
 

 

Item 12-2 What other regulations or pending regulations should DOE consider in its 

examination of cumulative regulatory burden? 

13. UTILITY IMPACT ANALYSIS 

To estimate the impacts that energy conservation standards for residential wine chillers and other 

miscellaneous residential refrigeration products would have on electric utility industries, DOE 

plans to use a variant of the EIA’s National Energy Modeling System (NEMS), called NEMSBT. BT refers to DOE’s Building Technologies Program. NEMS is a large, multi-sectoral, 

partial-equilibrium model of the U.S. energy sector that EIA has developed over several years, 

primarily for the purpose of preparing the AEO. NEMS produces a widely recognized reference 

case forecast for the United States through 2035 and is available in the public domain.38 

The utility impact analysis is a comparison between the NEMS-BT model results for the basecase and standards-cases. Outputs of the utility impact analysis usually parallel results that 

appear in the latest AEO, with some additions. Typical outputs of the utility impact analysis 

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, 

DOE will model the energy savings impacts from amended energy conservation standards using 

NEMS-BT to generate forecasts that deviate from the AEO reference case.39 

Item 13-1 DOE seeks input from stakeholders on its plans to use NEMS-BT to conduct the 

utility impact analysis. Examples of the type of input sought by DOE include, but are not 

limited to, whether the NEMS-BT model is appropriate for assessing the utility impacts of 

efficiency standards — and if not, what would be a more appropriate model to use? 

14. EMPLOYMENT IMPACT ANALYSIS 

DOE estimates the impacts of standards on employment for equipment manufacturers, relevant 

service industries, energy suppliers, and the economy in general. This analysis covers both direct 

and indirect employment impacts. Direct employment impacts would result if standards led to a 

38 For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary is National	Energy	Modeling	System:		An	Overview	2000, 

DOE/EIA-0581(March 2000) and is available at http://tonto.eia.doe.gov/ftproot/forecasting/05812000.pdf. 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 whose aegis this work has been performed). 

39 Several descriptions of NEMS-BT models from previous rulemakings, including residential furnaces and boilers, 

can be found on DOE’s website at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/fb_fr_tsd/chapter_13.pdf. 

60
 
change in the number of employees at manufacturing plants and related supply and service firms. 

DOE will evaluate direct employment impacts in the manufacturer impact analysis, as described 

in section 12. 

Indirect employment impacts are impacts on the national economy other than in the 

manufacturing sector being regulated. Indirect impacts may result both from expenditures 

shifting among goods (the substitution effect) and changes in income that lead to a change in 

overall expenditure levels (the income effect). DOE defines indirect employment impacts from 

standards as net jobs eliminated or created in the general economy as a result of increased 

spending driven by the increased equipment prices and reduced spending on energy. 

DOE will investigate the combined direct and indirect employment impacts in the employment 

impact analysis using the Pacific Northwest National Laboratory (PNNL)’s “Impact of Sector 

Energy Technologies” (ImSET) model. PNNL developed ImSET for DOE’s Office of Planning, 

Budget, and Analysis. The model 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 efficiency investments. Although DOE intends to use ImSET for its analysis 

of employment impacts, it welcomes input on other tools and factors it might consider. 

Item 14-1 DOE welcomes feedback on its planned approach for assessing national 

employment impacts, both direct and indirect, and it is interested in whether other tools or 

factors should be considered as part of its analysis. If other tools or factors should be 

considered, please identify them and explain why, and how, they should be integrated into 

DOE's analysis. 

15. EMISSIONS ANALYSIS 

In the emissions analysis, DOE will estimate the reduction in power sector emissions of 

carbon dioxide (CO2), nitrogen oxides (NOx), and mercury (Hg) using the NEMS-BT computer 

model. In the emissions analysis, NEMS-BT is run similarly to the AEO NEMS, except that 

wine chiller and other miscellaneous residential refrigeration product energy use is reduced by 

the amount of energy saved (by fuel type) due to each considered standard level. The inputs of 

national energy savings come from the NIA spreadsheet model, while the output is the forecasted 

physical emissions. The net benefit of each considered standard level is the difference between 

the forecasted emissions estimated by NEMS-BT at that level and the AEO 2011 Reference 

Case. 

61
 
 

15.1 Carbon Dioxide 

In the absence of any Federal emissions control regulation of power plant emissions of CO2, a 

DOE standard is likely to result in reductions of these 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 these 

programs create uncertainty about the potential standards’ impact on SO2 emissions. Title IV of 

the Clean Air Act sets an annual emissions cap on SO2 for affected EGUs in the 48 contiguous 

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. 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 remains in effect temporarily, 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, 2011 EPA issued a replacement for CAIR, the Cross-State Air Pollution Rule. 76 FR 

48208 (August 8, 2011). (See http://www.epa.gov/crossstaterule/). On December 30, 2011, 

however, the D.C. Circuit stayed the new rules while a panel of judges reviews them, and told 

EPA to continue enforcing CAIR (see EME Homer City Generation v. EPA, No. 11-1302, Order 

at *2 (D.C. Cir. Dec. 30, 2011)). 

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 NEMS-BT 

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 

Under CAIR, there is a cap on NOx emissions in 28 eastern states and the District of Columbia. 

All these States and D.C. have elected to reduce their NOx emissions by participating in capand-trade programs for EGUs. Therefore, energy conservation standards for wine chillers and 

other miscellaneous residential refrigeration products may have little or no physical effect on 

62
 
 

these emissions in the 28 eastern states and the D.C. for the same reasons that they may have 

little or no physical effect on NOX emissions. DOE is using the NEMS-BT to estimate NOx 

emissions reductions from possible standards in the States where emissions are not capped. 

15.4 Mercury 

In the absence of caps, a DOE energy conservation standard could reduce Hg emissions and 

DOE plans to use NEMS-BT to estimate these emission reductions. On December 21, 2011, 

EPA announced national emissions standards for hazardous air pollutants (NESHAPs) for 

mercury and certain other pollutants emitted from coal and oil-fired EGUs.40 The NESHAPs do 

not include a trading program and, as such, DOE’s energy conservation standards would likely 

reduce Hg emissions. For the emissions analysis for this rulemaking, DOE plans to estimate 

mercury emissions reductions using NEMS-BT based on AEO2011, which does not incorporate 

the NESHAPs. DOE expects that future versions of the NEMS-BT model will reflect the 

implementation of the NESHAPs. 

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 (nonparticulate) 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, which are now largely regulated by cap and trade systems. 

Item 15-1 DOE seeks input on its plans to use NEMS-BT to analyze emissions associated 

with the products covered by this potential rulemaking. 

40 http://epa.gov/mats/pdfs/20111216MATSfinal.pdf. 

63 
 

16. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS 

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the standard levels 

considered. 

In order to estimate the monetary value of benefits resulting from reduced emissions of CO2, 

DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or agreed 

to by an interagency process. 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, expressed in 2010$, were $4.9, $22.3, $36.5, and 

$67.6 per metric ton avoided. For emissions 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. For NOx emissions, available estimates suggest a very wide 

range of monetary values for NOX emissions, ranging from $450 to $4,623 per ton in 2010$.41 In 

accordance with U.S. Office of Management and Budget (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.42 

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 

41 For additional information, refer to U.S. Office of Management and Budget, Office of Information and Regulatory 

Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on
 

State, Local, and Tribal Entities, Washington, DC. 42 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 

64
 
regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg 

in its rulemakings. 

17. REGULATORY IMPACT ANALYSIS 

In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis that will 

address the potential for non-regulatory approaches to supplant or augment energy conservation 

standards to improve the efficiency of residential wine chillers on the market. DOE recognizes 

that voluntary or other non-regulatory efforts by manufacturers, utilities, and other interested 

parties can result in substantial efficiency improvements. DOE intends to analyze the likely 

effects of non-regulatory initiatives on product energy use, consumer utility, and LCCs. DOE 

will attempt to base its assessment on the actual impacts of any such initiatives to date, but will 

also consider information presented regarding the impacts that any existing initiative might have 

in the future. 

If DOE proposes energy conservation standards for wine chillers and the NOPR constitutes a 

significant regulatory action, DOE would prepare and submit to OMB for review the assessment 

of costs and benefits required under section 6(a)(3) of Executive Order 12866, “Regulatory 

Planning and Review,” 58 FR 51735 (October 4, 1993). 

65
 
 

APPENDIX A – DRAFT PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

QUESTIONAIRE 

1 Issues 

1.1	 What are the key issues for your company regarding a possible future product rulemaking? 

2 Shipment Projections 

2.1	 What is your company’s approximate market share? 

2.2	 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficiency levels? 

2.3	 How would you expect shipments to change for the industry as a whole as a function of 

standards and why? 

2.4	 Looking at price/cost effects only, how would you expect shipments to change for a 5 

percent, 10 percent, 25 percent, or 50 percent manufacturer price/cost increase? 

3 Conversion Costs 

3.1	 What level of capital expenditure and product conversion costs would you anticipate to 

make at higher standard levels? Please describe what they are and provide your best 

estimate of their respective magnitudes. 

3.2	 How would the imposition of new energy conservation standards affect capacity utilization 

and manufacturing assets at your domestic production facilities? Would a new standard 

result in stranded capital assets? Would any facilities be closed or downsized? Added or 

upgraded? 

3.3	 How might a new standard impact product innovation? 

4 Product Mix and Profitability 

4.1	 How would your company’s product mix and marketing strategy change with changes in 

the efficiency standard? 

4.2	 What distribution channels are used from the manufacturer to the retail outlet? What is the 

share of product going through each distribution channel? 

4.3	 Generally, how would new product standards affect your customer mix, distribution 

channels, and corresponding profit margins? 

4.4	 How might a new standard affect the ENERGY STAR program, and consequently your 

firm? 

5 Market Shares and Industry Consolidation 

5.1	 In the absence of new standards, do you expect any industry consolidation? 

5.2	 How would new standards affect your ability to compete? 

5.3	 Could new standards disproportionately advance or harm the competitive positions of 

some firms? 

66
 
5.4	 Are there concerns over intellectual property? 

5.5	 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups? 

5.6	 Beyond price and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product functionality, utility, or 

other features? 

6 Cumulative Regulatory Burden 

6.1	 Are there recent or impending regulations on your specific product or other products that 

impose a cumulative burden on the industry? 

6.2	 If so, what is the total expected impact of those other regulations? 

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APPENDIX B – SUMMARY OF ITEMS FOR STAKEHOLDER COMMENT 

Summary of all items for stakeholder comment contained in the framework document. 

Item 1-1	 DOE requests shipment information from stakeholders for wine chillers and related 

refrigeration products. Segregation of such data is desired if possible by type of 

refrigeration technology (thermoelectric, vapor-compression, absorption), product 

size, product class, and any other relevant characteristics ........................................ 11 

Item 1-2	 DOE requests energy use data for wine chillers and related refrigeration products 

that is not readily available in public databases such as that of the CEC. DOE 

requests that the data identify model numbers or basic product information (e.g. 

cabinet volume) and that the method of determining the energy use be identified for 

such data, specifically to identify the test procedure used and/or to indicate that the 

data are estimates, field measurements, or determined by other methods. DOE 

requests that such data be segregated if possible according to refrigeration 

technology, product class, and/or product size. ......................................................... 12 

Item 1-3	 DOE requests comment on its options for establishing coverage and energy 

conservation standards for wine chillers. .................................................................. 12 

Item 1-4	 DOE requests comment on the suggested definition for wine chiller and the modified 

definitions for refrigerator and compact products..................................................... 13 

Item 1-5	 DOE requests comments from stakeholders regarding the selection of a term 

identifying the product category associated with wine chillers and related 

refrigeration products whose compartment temperatures are warmer than 39  ̊F— 

should they all just be called wine chillers? In addition, DOE seeks comment on 

whether multiple product categories are necessary to address such products. .......... 13 

Item 1-6	 DOE requests general comments on its draft framework for addressing products that 

include fresh food and/or freezer compartments as well as wine storage 

compartments. ........................................................................................................... 16 

Item 1-7	 DOE seeks information regarding the types and configurations of products that 

might need to be considered under such a framework, including examples showing 

product details and information on annual shipments associated with such products.

 16 

Item 1-8	 DOE seeks comment on whether there should be a threshold size or percent of total 

volume for wine storage compartments that would push a product out of the current 

definitions for refrigerator, refrigerator-freezer, or freezer into hybrid product 

categories. If so, what should this threshold be? What types of hybrid product 

categories should be established? .............................................................................. 16 

Item 1-9	 DOE seeks comment on what kinds of test procedure revisions would be required to 

address these products, whether covered under the existing product categories or by 

new categories? ......................................................................................................... 16 

Item 1-10	 DOE seeks comment on whether it should develop separate definitions and energy 

conservation standards for hybrid products. .............................................................. 16 

Item 1-11	 DOE seeks information regarding whether refrigeration products which operate on 

either alternating current (AC) or direct current (DC) electricity are distributed to 

any significant extent in commerce for personal or consumer use in stationary 

68
 
applications (e.g., in homes). What types of such products are sold, what are their 

annual shipment levels in the U.S., and what are their energy use characteristics? .. 17 

Item 1-12	 DOE seeks comment on the merits of developing test procedures, definitions, and 

energy conservation standards for refrigeration products which operate on either 

alternating current (AC) or direct current (DC) electricity. ...................................... 17 

Item 1-13	 DOE requests information regarding whether there are any residential refrigeration 

products not yet covered by energy conservation standards, other than the wine 

chillers and related hybrid products noted earlier, that DOE should regulate through 

energy conservation standards? Assuming such products exist, what are they (i.e. 

types), what are their annual shipment levels in the U.S., and what are their energy 

use characteristics? .................................................................................................... 18 

Item 1-14	 DOE seeks information regarding residential ice makers. Specifically, DOE seeks 

information regarding: (1) the annual sales levels for such products in the U.S,; (2) 

whether test procedures exist to address the energy use of these products; (3) 

information regarding the typical annual energy use of such a product in a residential 

usage setting; and (4) what information DOE should consider when determining 

whether to cover these products and what energy conservation standard levels to set 

for them?.................................................................................................................... 18 

Item 1-15	 DOE seeks comment on what design and performance characteristics distinguish 

wine chillers used in commercial applications from residential wine chillers. DOE 

also requests comment on whether any wine chillers used in commercial applications 

are manufactured on the same product lines as residential wine chillers. Finally, 

DOE seeks information as to whether any commercial wine chillers are distributed in 

commerce for personal or consumer use. If any commercial wine chillers are in fact 

sold to individual consumers, DOE seeks details regarding the magnitude of those 

sales as a percentage of total sales of those products. ............................................... 20 

Item 1-16	 DOE requests comment on whether commercial and residential wine chillers should 

be covered under the same test procedures and energy conservation standards. ...... 20 

Item 1-17	 DOE seeks information regarding the prevalence of “near-freezer” products. DOE 

also seeks input regarding the need to revise the current freezer definition and/or test 

procedures to address such products. Further, DOE seeks input on whether it should 

include these products under existing classes or create separate product classes and 

standards for these products. If so, DOE requests comments regarding the nature of 

such needed revisions. ............................................................................................... 21 

Item 1-18	 DOE seeks comment regarding whether there are any other key issues, aside from 

the ones noted in this document, that DOE should consider when developing test 

procedures for wine chillers and related refrigeration products, and, if so, what these 

issues are. ................................................................................................................... 22 

Item 1-19	 DOE requests comment regarding a potential definition for compartments used in 

wine chillers and related refrigeration products that are currently not covered under 

the existing refrigeration product definitions. What compartment types should be 

defined and what should their standardized temperatures for energy testing be? ..... 23 

Item 1-20	 DOE requests comments on whether a correction factor is appropriate for calculating 

wine chiller energy use, and if so, whether 0.85 is an appropriate value for the 

correction factor. DOE further requests information supporting the selection of any 

recommended correction factor. ................................................................................ 23 

69
 
Item 1-21	 DOE requests input from stakeholders on its tentative conclusion that separate test 

procedures to address standby and off modes are not required for wine chillers and 

related refrigeration products. ................................................................................... 25 

Item 1-22	 DOE requests comments from stakeholders regarding the possible acceleration of the 

timeline to publish the final rule and potential implications. .................................... 29 

Item 3-1	 DOE requests information that would contribute to the market assessment for the 

residential wine chillers and miscellaneous refrigeration products that would be 

covered in this potential rulemaking. Examples of information sought include 

current product features and efficiencies, product-feature and efficiency trends, 

historical product shipments and prices). .................................................................. 31 

Item 3-2	 DOE requests input from stakeholders on the proposed product classes. What other 

factors, if any, should DOE consider beyond those identified above as a basis for 

developing product classes? When answering, please explain in detail and cite 

specific examples to the extent possible. ................................................................... 32 

Item 3-3	 DOE requests information on solid-door products that would fit the definitions 

anticipated for wine chillers including: the prevalence of such products, the 

efficiency differences, if any, with respect to transparent-door products versus those 

products with solid doors, and whether there is sufficient consumer utility associated 

with transparent doors to merit creating a separate product class on this basis? ...... 32 

Item 3-4	 DOE requests information on whether any wine chillers or miscellaneous 

refrigeration products utilize heating (electric or otherwise) on glass surfaces or on 

door face frames to prevent condensation. If so, what types of products utilize such 

heating and what percentage of shipments do they represent? ................................. 33 

Item 3-5	 DOE seeks clarification on whether any wine chillers or miscellaneous refrigeration 

products utilize defrost heating (i.e. automatic defrost methods other than by frost 

melting during the compressor off-cycle). If so, what types of products utilize defrost 

heating and what percentage of shipments do they represent? DOE also requests 

clarification on whether any wine chillers or miscellaneous refrigeration products 

utilize manual defrost—what types of products require manual defrost and what 

percentage of shipments do they represent? .............................................................. 33 

Item 3-6	 DOE requests information regarding whether any wine chillers or miscellaneous 

refrigeration products utilize anti-sweat heating of any kind (electric resistance, 

refrigerant loop, etc.)? ............................................................................................... 33 

Item 3-7	 DOE seeks comment on whether any additional technologies in addition to the ones 

identified above should be considered for wine chillers and miscellaneous 

refrigeration products. ............................................................................................... 34 

Item 4-1	 Are there any technologies listed in Table 3.2 that DOE should not consider because 

of any of the four screening criteria? If so, which screening criteria apply to the cited 

technology or technologies? ...................................................................................... 35 

Item 5-1	 DOE seeks input from stakeholders on whether the equations for maximum annual 

energy consumption of the California and Canadian regulations are appropriate to 

represent the performance of baseline wine chillers. ................................................ 37 

Item 5-2	 DOE requests feedback on the use of a design-option approach based on energy 

modeling and some energy testing as needed, possibly enhanced by data collection 

organized by AHAM or other parties to determine the relationship between 

manufacturer cost and annual energy consumption. Particularly, DOE is interested in 

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whether this approach is appropriate for developing a cost/efficiency relationship for 

use as the basis for standards-setting and if the industry, AHAM, or any other parties 

are prepared to provide cost-efficiency information to support the rulemaking. If the 

suggested approach is not appropriate, why is it not? ............................................... 39 

Item 5-3	 DOE seeks input from stakeholders regarding the range of efficiency levels that 

should be examined as part of its analysis. ............................................................... 41 

Item 5-4	 DOE seeks comment on how to select representative products for detailed analysis 

and on how to extrapolate such analyses to the full range of wine chiller and 

miscellaneous residential refrigeration products. ...................................................... 41 

Item 5-5	 Are there proprietary designs or technologies of which DOE should be aware for the 

products under consideration in this rulemaking? If so, how should DOE acquire the 

cost data necessary for evaluating these designs? ..................................................... 42 

Item 5-6	 Are there outside regulatory issues that DOE should consider in its analysis of 

residential wine chillers and miscellaneous refrigeration products? If so, please 

identify what they are and how DOE should consider them for purposes of its 

analysis. ..................................................................................................................... 42 

Item 6-1	 DOE welcomes suggestions and comments concerning its proposed approach for 

developing estimates of future retail prices. .............................................................. 44 

Item 7-1	 DOE seeks comments on the proposed approach of estimating the annual energy 

consumption of wine chillers based on a combination of NPD sales data, CEC model 

data, and California’s energy conservation standards equations for establishing 

maximum energy use. ................................................................................................ 45 

Item 7-2	 DOE seeks input on potential data sources for establishing the annual energy 

consumption of wine chillers. ................................................................................... 45 

Item 7-3	 DOE seeks comments on the viability of using in situ field measurements of wine 

chiller energy use as a proposed basis for characterizing the product’s energy 

consumption. ............................................................................................................. 45 

Item 7-4	 DOE seeks comments on whether annual energy use is best characterized with a 

sensitivity analysis to determine how high and low estimates of energy use might 

impact the economic feasibility of any amended energy conservation standards. .... 45 

Item 7-5	 DOE seeks comments on the rebound effect associated with more efficient wine 

chillers. In other words, DOE seeks input on what portion of the energy savings 

resulting from more efficient equipment may be lost due to consumers purchasing 

larger or more feature laden equipment. ................................................................... 45 

Item 8-1	 DOE seeks stakeholder input on the proposed approach of using probability 

distributions and Monte Carlo simulation to conduct the LCC and PBP analysis. ... 48 

Item 8-2	 DOE requests data from stakeholders to characterize the current mix of wine chiller 

efficiencies in the market. ......................................................................................... 48 

Item 8-3	 DOE seeks stakeholder input on the planned approach for estimating current and 

forecasted energy prices. ........................................................................................... 49 

Item 8-4	 DOE seeks stakeholder input on the merits of its proposed analytical assumption that 

changes in maintenance, repair, and installation costs will be negligible for moreefficient residential wine chillers. If it is incorrect, DOE is interested in the reasons 

why this is so and in specific ways in which to correct this assumption. ................. 49 

Item 8-5	 DOE seeks stakeholder input on appropriate product lifetimes for wine chillers. 

Specifically, DOE seeks data sources for establishing product lifetimes and 

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information regarding the merits of whether standard-sized and compact-sized 

refrigerator, refrigerator-freezer, and freezer lifetimes are representative of wine 

chillers. ...................................................................................................................... 50 

Item 8-6	 DOE seeks stakeholder input on the planned approach for estimating discount rates 

for residential consumers. .......................................................................................... 50 

Item 9-1	 DOE seeks historical shipments data from stakeholders. If such data are provided, 

DOE requests that market share data showing the percentage of product shipments 

for compressor/condenser-based and thermoelectric-based products be included. ... 51 

Item 9-2	 If stakeholders are unable to provide historical shipments data, DOE seeks comment 

on which data source is more representative of historical shipments, the AHAM 

shipments data or the NPD Group sales data and why. ............................................. 51 

Item 9-3	 DOE seeks input on the types of potential scenarios it should use to forecast basecase shipments and the reason(s) for the suggested scenario(s). ............................... 52 

Item 9-4	 As part of a possible preliminary manufacturer impact analysis, DOE seeks input 

from manufacturers on the potential impact of new energy conservation standards on 

wine chiller shipments. DOE also seeks input from other stakeholders on the 

potential impact of standards on product shipments. ................................................ 52 

Item 9-5	 DOE also requests input on any market-pull programs that currently exist to promote 

the adoption of more-efficient wine chillers. ............................................................ 52 

Item 10-1	 DOE seeks historical SWEF data for wine chillers. DOE also seeks historical market 

share data showing the percentage of product shipments by efficiency level. .......... 54 

Item 10-2	 DOE seeks input on its plan to develop NES spreadsheet models for estimating 

national impacts of amended energy conservation standards for wine chillers. For 

example, are spreadsheet models still the preferred approach for estimating national 

impacts? ..................................................................................................................... 54 

Item 11-1	 DOE requests input as to what, if any, consumer subgroups are appropriate in 

considering standards for wine chillers. .................................................................... 56 

Item 12-1	 DOE seeks comment on the appropriate manufacturer subgroups, if any, for 

residential wine chillers and miscellaneous refrigeration products that DOE should 

consider in a manufacturer subgroup analysis. ......................................................... 58 

Item 12-2	 What other regulations or pending regulations should DOE consider in its 

examination of cumulative regulatory burden? ......................................................... 60 

Item 13-1	 DOE seeks input from stakeholders on its plans to use NEMS-BT to conduct the 

utility impact analysis. Examples of the type of input sought by DOE include, but are 

not limited to, whether the NEMS-BT model is appropriate for assessing the utility 

impacts of efficiency standards — and if not, what would be a more appropriate 

model to use?............................................................................................................. 60 

Item 14-1	 DOE welcomes feedback on its planned approach for assessing national employment
 

impacts, both direct and indirect, and it is interested in whether other tools or factors 

should be considered as part of its analysis. If other tools or factors should be 

considered, please identify them and explain why, and how, they should be 

integrated into DOE's analysis. ................................................................................. 61 

Item 15-1	 DOE seeks input on its plans to use NEMS-BT to analyze emissions associated with 

the products covered by this potential rulemaking. ................................................... 63 

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