After a regulatory action has been completed, Executive Order 12866 requires agencies to 

identify the substantive changes between the draft submitted to Office of Information and 

Regulatory Affairs (OIRA) for review and the action subsequently announced, and to identify 

those changes made at the suggestion or recommendation of OIRA. The document below 

provides more information. 
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[6450-01-P] 

DEPARTMENT OF ENERGY

10 CFR Part 431

[Docket Number EERE–2008–BT–STD–0015] 

RIN: 1904-AB86

Energy Conservation Program: Energy Conservation Standards for Walk-in Coolers and Freezers 

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION: Notice of proposed rulemaking (NOPR) and public meeting.

SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as amended, prescribes 

energy conservation standards for various consumer products and certain commercial and 

industrial equipment, including walk-in coolers and walk-in freezers. EPCA also requires the 

U.S. Department of Energy (DOE) to determine whether new ormore-stringent, amended 

standards would be technologically feasible and economically justified, and would save a 

significant amount of energy. In this notice, consistent with EPCA, DOE proposes amended 

energy conservation standards for walk-in coolers and walk-in freezers. The notice also 

announces a public meeting to receive comment on these proposed standards and associated 

analyses and results. 
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DATES: DOE will hold a public meeting on [Day of week, Month, Day, Year], from 9 a.m. to 4 

p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See section VII, 

“Public Participation,” for webinar registration information, participant instructions, and 

information about the capabilities available to webinar participants. 

DOE will accept comments, data, and information regarding this notice of proposed 

rulemaking (NOPR) before and after the public meeting, but no later than [INSERT DATE 60 

DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER 

PUBLICATION]. See section VII, “Public Participation,” for details.

ADDRESSES: The public meeting will be held at the U.S. Department of Energy, Forrestal 

Building, Room [NUMBER], 1000 Independence Avenue, SW., Washington, DC 20585. To 

attend, please notify Ms. Brenda Edwards at (202) 586–2945. For more information, refer to 

section VII, Public Participation.Please note that foreign nationals visiting DOE Headquarters 

are subject to advance security screening procedures. Any foreign national wishing to participate 

in the meeting should advise DOE as soon as possible by contacting Ms. Edwards to initiate the 

necessary procedures. Please also note that those wishing to bring laptops into the Forrestal 

Building will be required to obtain a property pass. Visitors should avoid bringing laptops, or 

allow an extra 45 minutes. Persons can attend the public meeting via webinar. For more 

information, refer to the Public Participation section near the end of this notice. 

Any comments submitted must identify the NOPR for Energy Conservation Standards for 

walk-in coolers and freezers, and provide docket number EERE-2008–BT–STD–0015 and/or 

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Left + 0.5", Left + 1", Left + 1.5", Left + 2",

Left + 2.5", Left + 3", Left + 3.5", Left + 4",

Left + 4.5", Left + 5", Left + 5.5", Left + 6",

Left + 6.5", Left + 7", Left + 7.5", Left + 8",

Left + 8.5", Left + 9", Left + 9.5", Left + 

10", Left + 10.5", Left + 11", Left + 11.5",

Left + 12", Left + 12.5", Left + 13", Left

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regulatory information number (RIN) number 1904-AB86. Comments may be submitted using 

any of the following methods: 

1. Federal eRulemaking Portal: www.regulations.gov. Follow the instructions for submitting 

comments. 

2. E-mail: WICF-2008-STD-0015@ee.doe.gov. Include the docket number and/or RIN in 

the subject line of the message.

3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 

Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC, 20585-0121. If possible, 

please submit all items on a CD. It is not necessary to include printed copies.

4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, Building 

Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, Washington, DC, 20024. 

Telephone: (202) 586-2945. If possible, please submit all items on a CD, in which case it is not 

necessary to include printed copies.

Written comments regarding the burden-hour estimates or other aspects of the collectionof-information requirements contained in this proposed rule may be submitted to Office of 

Energy Efficiency and Renewable Energy through the methods listed above and by e-mail to 

Christine_J._KymnChad_S_Whiteman@omb.eop.gov. 

For detailed instructions on submitting comments and additional information on the 

rulemaking process, see section VII of this document (Public Participation).

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Docket: The docket is available for review at www.regulations.gov, including, which 

includes Federal Register notices, framework documents, public meeting attendee lists and 

transcripts, comments, and other supporting documents/materials., is available for review at 

regulations.gov. All documents in the docket are listed in the www.regulations.gov index. 

However, not allsome documents listed in the index may be publicly available, such as those 

containing information that is exempt from public disclosure, may not be publicly available. 

A link to the docket webpage can be found at: [Website. THIS WEBPAGE WILL 

CONTAIN A LINK TO THE DOCKET FOR THIS NOTICE ON THE REGULATIONS.GOV 

SITE]. This webpage contains a link to the docket for this notice on the regulations.gov site. The 

regulations.gov webpage contains instructions on how to access all documents, including public 

comments, in the docket. See section VII for further information on how to submit comments 

through www.regulations.gov. 

For further information on how to submit a comment, review other public comments and 

the docket, or participate in the public meeting, contact Ms. Brenda Edwards at (202) 586-2945 

or by email: Brenda.Edwards@ee.doe.gov.

FOR FURTHER INFORMATION CONTACT: 

Mr. Charles Llenza, U.S. Department of Energy, Office of Energy Efficiency and 

Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., 

Washington, DC, 20585-0121. Telephone: (202) 586-2192. E-mail: 

Charles.Llenza@ee.doe.gov.E-mail: walk-in_coolers_and_walk-in_freezers@EE.Doe.Gov .

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Mr. Michael Kido, U.S. Department of Energy, Office of the General Counsel, GC-71, 

1000 Independence Avenue, SW., Washington, DC, 20585-0121. Telephone: (202) 586-8145. Email: Michael.Kido@hq.doe.gov or Ms. Elizabeth Kohl, U.S. Department of Energy, Office of 

the General Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC, 20585-0121.

Telephone: (202) 586-7796. E-mail: Elizabeth.Kohl@hq.doe.govMichael.Kido@hq.doe.gov. Formatted: Font color: Auto

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SUPPLEMENTARY INFORMATION: 

Table of Contents

I. Summary of the Proposed Rule

A. Benefits and Costs to Consumers

B. Impact on Manufacturers

C. National Benefits

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Walk-in Coolers and Freezers

III. General Discussion

A. Component Level Standards

B. Test Procedures and Metrics

1. Panels

2. Doors

3. Refrigeration

C. Prescriptive Versus Performance Standards

D. Certification, Compliance, and Enforcement 

E. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

F. Energy Savings

1. Determination of Savings

2. Significance of Savings

G. Economic Justification

1. Specific Criteria

a. Economic Impact on Manufacturers and Consumers

b. Life-Cycle Costs

c. Energy Savings

d. Lessening of Utility or Performance of Products

e. Impact of Any Lessening of Competition

f. Need of the Nation to Conserve Energy

g. Other Factors

2. Rebuttable Presumption

IV. Methodology and Discussion

A. Market and Technology Assessment

1. Definitions Related to Walk-In Coolers and Freezers

a. Display Doors

b. Passage Doors

c. Freight Doors

2. Equipment Included in this Rulemaking

a. Panels and Doors

b. Refrigeration System

3. Equipment Classes

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a. Panels and Doors

b. Refrigeration Systems

4. Technology Assessment

B. Screening Analysis

1. Technologies That Do Not Affect Rated Performance

2. Screened-Out Technologies

a. Panels and Doors

b. Refrigeration

3. Screened-In Technologies

C. Engineering Analysis

1. Representative Equipment

a. Panels and Doors

b. Refrigeration

2. Energy Modeling Methodology

a. Refrigeration

3. Cost Assessment Methodology

a. Teardown Analysis

b. Cost Model

c. Manufacturing Production Cost

d. Manufacturing Markup

e. Shipping Costs

4. Baseline Specifications

a. Panels and Doors

b. Refrigeration

5. Design Options

a. Panels and Doors

b. Refrigeration

6. Cost-Efficiency Results

a. Panels and Doors

b. Refrigeration

c. Numerical Results

D. Markups Analysis

E. Energy Use Analysis

1. Sizing Methodology for the Refrigeration System

2. Oversize Factors

3. Product Load

4. Other Issues

F. Life-Cycle Cost and Payback Period Analyses

1. Equipment Cost

2. Installation Cost

3. Annual Energy Consumption

4. Energy Prices

5. Energy Price Projections

6. Maintenance and Repair Costs

7. Product Lifetime

8. Discount Rates
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9. Compliance Date of Standards

10. Base-Case and Standards-Case Efficiency Distributions

11. Inputs to Payback Period Analysis

12. Rebuttable-Presumption Payback Period

G. National Impact Analysis – National Energy Savings and Net Present Value

1. Shipments

a. Share of Shipments and Stock Across Equipment Classes

b. Lifetimes and Replacement Rates

c. Growth Rates

d. Other Issues

2. Forecasted Efficiency in the Base Case and Standards Cases

3. National Energy Savings

4. Net Present Value of Consumer Benefit

5. Benefits from Effects of Standards on Energy Prices

H. Consumer Subgroup Analysis

I. Manufacturer Impact Analysis

1. Overview

2. Government Regulatory Impact Model Analysis

a. Government Regulatory Impact Model Key Inputs

b. Government Regulatory Impact Model Scenarios

3. Discussion of Comments

a. Cumulative Regulatory Burden

b. Inventory Levels

c. Manufacturer Subgroup Analysis

4. Manufacturer Interviews

a. Cost of testing

b. Enforcement and Compliance 

c. Profitability Impacts

d. Excessive Conversion Cost

e. Disproportionate Impact on Small Businesses

f. Refrigerant Phase-Out

J. Employment Impact Analysis

K. Utility Impact Analysis

L. Environmental Assessment

M. Monetizing Carbon Dioxide and Other Emissions Impacts

1. Social Cost of Carbon

a. Monetizing Carbon Dioxide Emissions

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

c. Current Approach and Key Assumptions

2. Valuation of Other Emissions Reductions

V. Analytical Results

A. Trial Standard Levels

1. Trial Standard Level Selection Process

2. Trial Standard Level Equations

B. Economic Justification and Energy Savings

1. Economic Impacts on Commercial Customers
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a. Life-Cycle Cost and Payback Period

b. Life-Cycle Cost Subgroup Analysis

2. Economic Impacts on Manufacturers

a. Industry Cash-Flow Analysis Results

b. Impacts on Employment

c. Impacts on Manufacturing Capacity

d. Impacts on Small Manufacturer Sub-Group

e. Cumulative Regulatory Burden

3. National Impact Analysis

a. Amount and Significance of Energy Savings

b. Net Present Value of Consumer Costs and Benefits

c. Employment Impacts

4. Impact on Utility or Performance of Equipment

5. Impact of Any Lessening of Competition

6. Need of the Nation to Conserve Energy

7. Other Factors

C. Proposed Standard

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under the Information Quality Bulletin for Peer Review

VII. Public Participation

A. Attendance at the Public Meeting

B. Procedure for Submitting Prepared General Statements For Distribution

C. Conduct of the Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

VIII. Approval of the Office of the Secretary

I. Summary of the Proposed Rule

A. Benefits and Costs to Consumers

B. Impact on Manufacturers

C. National Benefits

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Walk-in Coolers and Freezers
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III. General Discussion

A. Component Level Standards

B. Test Procedures and Metrics

1. Panels

2. Doors

3. Refrigeration

C. Prescriptive Versus Performance Standards

D. Certification, Compliance, and Enforcement

E. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

F. Energy Savings

1. Determination of Savings

2. Significance of Savings

G. Economic Justification

1. Specific Criteria

a. Economic Impact on Manufacturers and Consumers

b. Life-Cycle Costs

c. Energy Savings

d. Lessening of Utility or Performance of Products

e. Impact of Any Lessening of Competition

f. Need of the Nation to Conserve Energy

g. Other Factors

2. Rebuttable Presumption

IV. Methodology and Discussion

A. Market and Technology Assessment

1. Definitions Related to Walk-In Coolers and Freezers

a. Display Doors

b. Freight Doors

c. Passage Doors

2. Equipment Included in this Rulemaking

a. Panels and Doors

b. Refrigeration System

3. Equipment Classes

a. Panels and Doors

b. Refrigeration Systems

4. Technology Assessment

B. Screening Analysis

1. Technologies That Do Not Affect Rated Performance

2. Screened-Out Technologies

a. Panels and Doors

b. Refrigeration

3. Screened-In Technologies

C. Engineering Analysis

1. Representative Equipment

a. Panels and Doors
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b. Refrigeration

2. Energy Modeling Methodology

a. Refrigeration

3. Cost Assessment Methodology

a. Teardown Analysis

b. Cost Model

c. Manufacturing Production Cost

d. Manufacturing Markup

e. Shipping Costs

4. Baseline Specifications

a. Panels and Doors

b. Refrigeration

5. Design Options

a. Panels and Doors

b. Refrigeration

6. Cost-Efficiency Results

a. Panels and Doors

b. Refrigeration

c. Numerical Results

D. Markups Analysis

E. Energy Use Analysis

1. Sizing Methodology for the Refrigeration System

2. Oversize Factors

3. Product Load

4. Other Issues

F. Life-Cycle Cost and Payback Period Analyses

1. Equipment Cost

2. Installation Cost

3. Annual Energy Consumption

4. Energy Prices

5. Energy Price Projections

6. Maintenance and Repair Costs

7. Product Lifetime

8. Discount Rates

9. Compliance Date of Standards

10. Base-Case and Standards-Case Efficiency Distributions

11. Inputs to Payback Period Analysis

12. Rebuttable-Presumption Payback Period

G. National Impact Analysis – National Energy Savings and Net Present Value

1. Shipments

a. Share of Shipments and Stock Across Equipment Classes

b. Lifetimes and Replacement Rates

c. Growth Rates

d. Other Issues

2. Forecasted Efficiency in the Base Case and Standards Cases

3. National Energy Savings
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4. Net Present Value of Consumer Benefit

5. Benefits from Effects of Standards on Energy Prices

H. Consumer Subgroup Analysis

I. Manufacturer Impact Analysis

1. Overview

2. Government Regulatory Impact Model Analysis

a. Government Regulatory Impact Model Key Inputs

b. Government Regulatory Impact Model Scenarios

3. Discussion of Comments

a. Cumulative Regulatory Burden

b. Inventory Levels

c. Manufacturer Subgroup Analysis

4. Manufacturer Interviews

a. Cost of testing

b. Enforcement and Compliance

c. Profitability Impacts

d. Excessive Conversion Cost

e. Disproportionate Impact on Small Businesses

f. Refrigerant Phase-Out 

J. Employment Impact Analysis

K. Utility Impact Analysis

L. Emissions Analysis

M. Monetizing Carbon Dioxide and Other Emissions Impacts

1. Social Cost of Carbon

a. Monetizing Carbon Dioxide Emissions

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

c. Current Approach and Key Assumptions

2. Valuation of Other Emissions Reductions

V. Analytical Results

A. Trial Standard Levels

1. Trial Standard Level Selection Process

2. Trial Standard Level Equations

B. Economic Justification and Energy Savings

1. Economic Impacts on Commercial Customers

a. Life-Cycle Cost and Payback Period

b. Life-Cycle Cost Subgroup Analysis

2. Economic Impacts on Manufacturers

a. Industry Cash-Flow Analysis Results

b. Impacts on Direct Employment

c. Impacts on Manufacturing Capacity

d. Impacts on Small Manufacturer Sub-Group

e. Cumulative Regulatory Burden

3. National Impact Analysis

a. Amount and Significance of Energy Savings

b. Net Present Value of Consumer Costs and Benefits

c. Employment Impacts
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4. Impact on Utility or Performance of Equipment

5. Impact of Any Lessening of Competition

6. Need of the Nation to Conserve Energy

7. Other Factors

C. Proposed Standard

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under the Information Quality Bulletin for Peer Review

VII. Public Participation

A. Attendance at the Public Meeting

B. Procedure for Submitting Prepared General Statements For Distribution

C. Conduct of the Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

VIII. Approval of the Office of the Secretary

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I. Summary of the Proposed Rule 

 DOE proposes creating new performance-based energy conservation standards for walkin coolers and walk-in freezers (collectively, “walk-ins” or “WICFs”). The proposed standards, 

which are expressed as an annual walk-in energy factor (AWEF) for refrigeration systems, the 

maximum allowable U-factor expressed as a function of the ratio of edge area to core area for 

panels, and the maximum allowable daily energy use expressed as a function of the surface area 

for non-display and display doors, are shown in Table I.1. These proposed standards, if adopted, 

would apply to all products listed in Table I.1 and manufactured in, or imported into, the United 

States on or after three3 years after the publication date of any final rule establishing energy 

conservation standards for walk-ins. Appendix 10D of the TSD lists the technologies that DOE 

assumes manufacturers will use to meet the proposed standards.

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Table I-1 Proposed Energy Conservation Standards for Walk-in Coolers and Walk-in 

Freezers (Assumes Compliance Starting Three3 Years After the Publication Date of any 

Final Rule)

Equipment Class Descriptor Class Proposed Standard Level

Refrigeration EquipmentSystems Minimum AWEF (Btu/W-h))*

Dedicated Condensing, 

Medium Temperature, Indoor 

System, < 9,000 Btu/h 

Capacity

DC.M.I, < 

159,000

Btu/h 

capacity

6.63 53.41063.2 4 +×× − Q

Dedicated Condensing, 

Medium Temperature, Indoor 

System, ≥ 9,000 Btu/h 

Capacity

DC.M.I, ≥ 

159,000

Btu/h 

capacity

7.386.90

Dedicated Condensing, 

Medium Temperature, 

Outdoor System, < 9,000 

Btu/h Capacity

DC.M.O, 

< 159,000

Btu/h 

capacity

9.51 12.01034.1 3 +×× − Q

Dedicated Condensing, 

Medium Temperature, 

Outdoor System, ≥ 9,000 

Btu/h Capacity

DC.M.O, 

≥ 159,000

Btu/h 

capacity

12.8121

Dedicated Condensing, Low 

Temperature, Indoor System, 

< 9,000 Btu/h Capacity

DC.L.I, < 

7500

Btu/h 

capacity9,

000

3.09 89.11093.1 4 +×× − Q

Dedicated Condensing, Low 

Temperature, Indoor System, 

≥ 9,000 Btu/h Capacity

DC.L.I, ≥

7500

Btu/h 

capacity9,

000

3.9163

Dedicated Condensing, Low 

Temperature, Outdoor System, 

< 9,000 Btu/h Capacity

DC.L.O, < 

7500

Btu/h 

capacity9,

000

4.71 02.11070.5 4 +×× − Q

Dedicated Condensing, Low 

Temperature, Outdoor System, 

≥ 9,000 Btu/h Capacity

DC.L.O, ≥

7500

Btu/h 

capacity9,

000

7.396.15

Multiplex Condensing, 

Medium Temperature MC.M 12.8610.74

Multiplex Condensing, Low 

Temperature MC.L 6.295.53

Panels Maximum U-Factor (Btu/h-ft2-°F)*)**

Structural Panel, Medium 

Temperature SP.M 0405.0

core nf

edge nf 239.0

2

core nf

edge nf 0118.0 ×− ×+ +





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

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

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

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A

A

A

A

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041.0

core nf

edge nf 024.0

2

core nf

edge nf 012.0 ×− ×+ +







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





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



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A

A

A

A

Structural Panel, Low 

Temperature SP.L

0287.0

core nf

edge nf 172.0

2

core nf

edge nf 00847.0 ×− ×+ +

















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

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A

A

A

A

029.0

core nf

edge nf 017.0

2

core nf

edge nf 0083.0 ×− ×+ +



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

























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A

A

A

A

Floor Panel, Low Temperature FP.L

0385.0

core nf

edge nf 0214.0

2

core nf

edge nf 0108.0 ×− ×+ +

























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



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A

A

A

A

033.0

fp core 

fp edge 018.0

2

fp core 

fp edge 0091.0 ×− ×+ +























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A

A

A

A

Non-Display Doors Maximum Energy Consumption (kWh/day)**)†

Passage Door, Medium 

Temperature PD.M 000323.0 +× 217.0 nd A 0032.0 +× 22.0 And

Passage Door, Low 

Temperature PD.L 139.0 +× 30.4 nd A +× 0.414.0 And

Freight Door, Medium 

Temperature FD.M 00727.0 +× 0820.0 nd A 0073.0 +× 082.0 And

Freight Door, Low 

Temperature FD.L 117.0 +× 15.5 nd A +× 4.511.0 And

Display Doors Maximum Energy Consumption (kWh/day)***)††

Display Door, Medium 

Temperature DD.M 0610.0 +× 586.0 dd A 049.0 +× 39.0 Add

Display Door, Low 

Temperature

DD.L 251.0 +× 574.0 dd A +× 38.033.0 Add

**Q represents the system gross capacity as calculated in AHRI 1250.

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

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

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

***†† Add represents the surface area of the display door.

A. Benefits and Costs to Consumers

Table I-2 presents DOE’s evaluation of the economic impacts of the proposed standards 

on consumers of walk-in coolers and freezers, as measured by the shipment-weighted average 

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life-cycle cost (LCC) savings1 and the median payback period2. The average LCC savings are 

positive for all equipment classes. At TSL 4, the percentage of customers who experience net 

benefits or no impacts ranges from 55 to 100 percent, and the percentage of customers 

experiencing a net cost ranges from 0 to 45 percent. Chapter 11 presents the LCC subgroup 

analysis on groups of customers that may be disproportionately affected by the proposed 

standard. The installed cost increase over the 9-year analysis period (2017-2025) for the 

proposed TSL is 1.98 billion discounted at 7 percent.

 

1 Life-cycle cost (LCC) of commercial refrigeration equipment is the cost to customers of owning and operating the 

equipment over the entire life of the equipment. Life-cycle cost savings are the reductions in the life-cycle costs due 

to amended energy conservation standards when compared to the life-cycle costs of the equipment in the absence of 

amended energy conservation standards. Further discussion of the LCC analysis can be found in Chapter 8 of the 

TSD.

2 Payback period (PBP) refers to the amount of time (in years) it takes customers to recover the increased installed 

cost of equipment associated with new or amended standards through savings in operating costs. Further discussion 

of the PBP can be found in Chapter 8 of the TSD.

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Table I-2 Shipment-Weighted Average Impacts of Proposed Standards (TSL 4) on 

Consumers of Walk-in Coolers and Walk-in Freezers

II. Equipment Class III. Average LCC Savings 

(20102012$)

Median Payback Period

IV. (years)

Refrigeration System Class*

DC.M.OI 2,075$611 2.54.4

DC.M.IO 864$3,195 3.12.2

DC.L.OI 2,340$1,117 3.02.7

DC.L.IO 1,420$2,664 2.53

MC.M.N $1,531724 0.35

MC.L.N 1,759$2,061 0.74

Panel Class

SP.M** 7*$8 4.35

SP.L** 61*$72 3.6

FP.L** 20$30 4.65

Non-Display Door Class

PD.M 1 $0.3 5.15

PD.L 38 $52 3.94.7

FD.M $1 5.04

FD.L (39) $136 14.02.9

Display Door Class

DD.M 38 $228 4.92.2

DD.L (99)$200 6.9N/A

*For dedicated condensing (DC) refrigeration systems, results include both capacity ranges.

**Results are per 100 square feet.

Numbers in parentheses indicate negative values.

A.B. Impact on Manufacturers

The industry net present value (INPV) is the sum of the discounted cash flows to the 

industry from the base year through the end of the analysis period (20102013 to 20452046). 

Using real discount rates of 10.5 percent for panels, 9.4 percent for doors, and 10.4 percent for 

refrigeration 3

 

3 These rates were used to discount future cash flows in the Manufacturer Impact Analysis. The discount rates were 

calculated from SEC filings and then adjusted based on cost of capital feedback collected from walk-in door, panel, 

and refrigeration manufacturers in MIA interviews. For a detailed explanation of how DOE arrived at these discount 

rates, refer to Chapter 12 of the NOPR TSD.

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, DOE estimates that the industry net present value (INPV) for manufacturers of 

walk-in cooler and freezer refrigeration systems, panels, and doors in the base case (without new 

standards) is $851 million0.84 billion in 20102012$. Under the proposed standards, DOE expects 

that manufacturers may lose upthe impact on INPV to range from no change to a 9.9 percent 
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decrease. Total industry conversion costs estimated to be $51 million are assumed to be incurred 

in the years prior to the start of their INPV, which is approximately $83 million. Additionally, 

basedcompliance with the standards. Based on DOE’s interviews with the manufacturers of 

walk-in manufacturerscoolers and walk-in freezers, DOE does not expect any plant closings or 

significant loss of employment losses. 

B.C. National Benefits4

DOE’s analyses indicate that the proposed standards would save a significant 

amount of energy over . The lifetime full-fuel-cycle energy savings for walk-in coolers and 

freezers purchased in the 30 years (2015–2044)―an estimated -year period that begins in the 

year of compliance with new standards (2017–2046) amount to 5.21 39 quadrillion British 

thermal units (quads of ). The average annual energy savings over the life of walk-in coolers and 

freezers purchased in 2017 through 2046 is 0.18 quads, which is equivalent to 14.8 percent of the 

annual U.S commercial refrigeration sector energy.5

The cumulative energy for walk-ins.

6

 

 

4 All monetary values in this section are expressed in 2012 dollars and are discounted to 2013. 5 Total U.S. commercial sector energy (source energy) used for refrigeration in 2010 was 1.21 quads. Source: U.S. 

Department of Energy–Office of Energy Efficiency and Renewable Energy. Buildings Energy Data Book, Table 

3.1.4, 2010 Commercial Energy End-Use Splits, by Fuel Type (Quadrillion Btu). 2012. (Last accessed April 23, 

2013.) 

http://buildingsdatabook.eren.doe.gov/TableView.aspx?table=3.1.4

6 The year 2015 was chosen in anticipation of the earliest potential compliance date as prescribed in EPCA. See 42 

U.S.C. 6313(f).

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The cumulative national net present value (NPV) of total consumer costs and savings of 

the proposed standards in 2010$ ranges from $9.58.6 billion (at a 7-percent discount rate) to 

$25.424.3 billion (at a 3-percent discount rate) for walk-ins.in coolers and freezers. This NPV 

expresses the estimated total value to customers of future operating- cost savings minus the 

estimated increased equipmentproduct costs for equipmentproducts purchased in 2015–2044, 

discounted to 20112017–2046. 

In addition, the proposed standards would have significant environmental benefits. The 

energy saved is in the form of electricity, and DOE expects the energy savings from the proposed 

standards to eliminate the need for approximately 3.6 gigawatts (GW) of generating capacity by 

2045. The savings would result in cumulative greenhouse gas emission reductions of 120.4298

million metric tons (MMtMt)

7

 of carbon dioxide (CO2) in 2015–2044. During this period, the 

proposed standards would result in emissions reductions of 81), 1,428 thousand tons of methane, 

379.5 thousand tons of sulfur dioxide (SO2), 443.8 thousand tons of nitrogen oxides (NOX)), and 

20.6 tons of mercury (Hg).8, 9 

 

7 A metric ton is equivalent to 1.1 short tons. Results for NOX and Hg are presented in short tons. 8 DOE calculates emissions reductions relative to the most recent version of the Annual Energy Outlook (AEO) 

2013 Reference case forecast. This forecast accounts for regulatory emissions reductions through 2010, including 

the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), but not the Clean Air Mercury Rule (CAMR, 

70 FR 28606 (May 18, 2005)). Subsequent, which generally represents current legislation and environmental

regulations, including the recently finalized transport rule, the Cross-State Air Pollution rule issued on July 6, 2011, 

do not appear in the forecast at this time. See 76 FR 48208 (Aug. 8, 2011) (publication of the Cross-State Air 

Pollution final rule). for which implementing regulations were available as of December 31, 2012. 9 DOE also estimated CO2 and CO2 equivalent (CO2eq) emissions that occur through 2030 (CO2eq includes 

greenhouse gases such as CH4 and N2O). The estimated emissions reductions through 2030 are 79 million metric 

tons CO2, 7,897 thousand tons CO2eq for CH4, and 338 thousand tons CO2eq for N2O.

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The value of the CO2 reductions is calculated using a range of values per metric ton of 

CO2 (otherwise known as the Social Cost of Carbon, or SCC) developed by an interagency 

process. The derivation of the SCC values is discussed in section IV.M. DOE estimates the net 

present monetary value of the CO2 emissions reduction is between $1.9 billion and $27.5 billion, 

depending on the SCC value used, over a 30-year analysis period. DOE also estimates the net 

present monetary value of the NOX emissions reduction is $243 million at a 7-percent discount 

rate and $553 million at a 3-percent discount rate over a 30-year analysis period. Over a 9-year 

analysis period, DOE estimates the net present monetary value of the CO2 emissions reduction is 

between $0.33 billion and $3.584.07 billion at a 7-percent discount rate and between $0.68

billion and $7.06 billion at a 3-percent discount rate, expressed in 2010$ and discounted to 2011. 

DOE also estimates, depending on the SCC value used, while the net present monetary value of 

the NOX emissions reduction, expressed in 2010$ and discounted to 2011, is $4570.5 million at a 

7-percent discount rate, and $10399.8 million at a 3-percent discount rate. 1011 DOE notes that 

the estimated total social benefits of the rule outweigh the costs whether a 30-year or a 9-year 

analysis period is used.

Table I-3 summarizes the national economic costs and benefits expected to result from 

the proposed standards for walk-in coolers and walk-in freezers.

 

10 DOE is aware of multiple agency efforts to determine the appropriate range of values used in evaluating the 

potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance regarding 

consistent valuation and reporting of Hg emissions before it once again monetizes Hg in its rulemakings. 11 DOE has decided to await further guidance regarding consistent valuation and reporting of Hg emissions before it 

monetizes Hg in its rulemakings.

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Table I-3 Summary of National Economic Benefits and Costs of Walk-in Cooler and Walkin Freezer Energy Conservation Standards

Category Present Value

Billion 2012$ Discount Rate

Benefits

Operating Cost Savings

12.4 7%

28.8 3%

CO2 Reduction Monetized Value (at $12.9/t case)* 1.9 5%

CO2 Reduction Monetized Value (at $40.8/t case)* 9.0 3%

CO2 Reduction Monetized Value (at $62.2/t case)* 14.4 2.5%

CO2 Reduction Monetized Value (at $117.0/t case)* 27.5 3%

NOX Reduction Monetized Value (at $2,639/Ton)**

0.24 7%

0.55 3%

Total Benefits†

21.6 7%

38.3 3%

Costs

Incremental Installed Costs

3.7 7%

7.2 3%

Net Benefits

Including CO2 and NOX Reduction Monetized Value 

17.9 7%

31.2 3%

* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are 

based on the average SCC from the integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The 

fourth set, which represents the 95th percentile SCC estimate across all three models at a 3-percent discount rate, is 

included to represent higher-than-expected impacts from temperature change further out in the tails of the SCC 

distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate an escalation 

factor.

** The value represents the average of the low and high NOX values used in DOE’s analysis.

† Total Benefits for both the 3 percent and 7 percent cases are derived using the CO2 reduction monetized value

series corresponding to average SCC with 3-percent discount rate.

The benefits and costs of today’s proposed standards, for equipment sold in 2015-–

20442017-2046, can also be expressed in terms of annualized values. The annualized monetary 

values are the sum of (1) the annualized national economic value of the benefits from consumer 

operation of equipment that meets the proposed standards (consisting primarily of operating cost 

savings from using less energy, minus increases in equipment purchase and installation costs, 

and (2) the annualized monetary value of the benefits of emission reductions, including CO2

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emission reductions.12 The value of the CO2 reductions, otherwise known as the Social Cost of 

Carbon (SCC), is calculated using a range of values per metric ton of CO2 developed by a recent 

interagency process. The derivation of the SCC values is discussed in section IV.M. 

Although combining the values of operating savings and CO2 emission reductions 

provides a useful perspective, two issues should be considered. First, the national operating 

savings are domestic U.S. consumer monetary savings that occur as a result of market 

transactions while the value of CO2 reductions is based on a global value. Second, the 

assessments of operating cost savings and CO2 savings are performed with different methods that 

use different time frames for analysis. The national operating cost savings is measured for the 

lifetime of walk-ins shipped from 2015–20442017–2046. The SCC values, on the other hand, 

reflect the present value of some future climate-related impacts resulting from the emission of 

one ton of carbon dioxide in each year. These impacts continue well beyond 2100.

Table I-34 shows the estimates of annualized values for today’sbenefits and costs of the

proposed standards. (All monetary values below are expressed in 20102012$.) The results under 

the primary estimate are as follows. Using a 7-percent discount rate for benefits and costs other 

 

12 The process that DOE used to convert the time-series of costs and benefits into annualized values is explained in 

section IV.M of this notice.

DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. 

First, DOE calculated a present value in 2013, the year used for discounting the NPV of total consumer costs and 

savings, for the time-series of costs and benefits using discount rates of three and seven percent for all costs and 

benefits except for the value of CO2 reductions. For the latter, DOE used a range of discount rates, as shown in 

Table I.3. From the present value, DOE then calculated the fixed annual payment over a 30-year period (2014 

through 2043) that yields the same present value. The fixed annual payment is the annualized value. Although DOE 

calculated annualized values, this does not imply that the time-series of cost and benefits from which the annualized 

values were determined is a steady stream of payments.

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than CO2 reduction, for which DOE used a 3-percent discount rate along with the average SCC 

series corresponding to a value of $21.4/ton in 2010that uses a 3-percent discount rate, the cost 

of the standards proposed in today’s rule is $378 367 million per year in increased equipment 

costs, while the annualized benefits are $1.335225 billion per year in reduced equipment 

operating costs, $118499 million in CO2 reductions, and $424 million in reduced NOX emissions. 

In this case, the net benefit amounts to $957 million1.382 billion per year. Using a 3-percent 

discount rate for all benefits and costs and the average SCC series corresponding to a value of 

$21.4/ton in 2010, the cost of the standards proposed in today’s rule is $466399 million per year 

in increased equipment costs, while the benefits are $1.887606 billion per year in reduced 

operating costs, $118499 million in CO2 reductions, and $531 million in reduced NOX emissions. 

In this case, the net benefit amounts to $1.420737 billion per year. 
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Table I-4 Annualized Benefits and Costs of Proposed Standards for Walk-in Coolers and 

Walk-in Freezers 

V.

Discount 

RatePrimary 

Estimate

(million 

2010$)

Low Net 

BenefitsPrimary

Estimate*

(million 2010$)

HighLow

Net 

Benefits 

Estimate*

(million 

2010$)

Discount 

RateHigh 

Net 

Benefits 

Estimate*

(million 2012$/year)

Benefits

Operating Cost Savings 1,1457% 7371,225 9261,188 7%1,279

1,7643% 1,340606 1,649544 3%1,687

CO

2 Reduction Monetized Value (at 

$4.7/Metric Ton)*12.9/t case)** 315% 31142 31142 5%142

CO

2 Reduction Monetized Value (at 

$21.4/Metric Ton)*40.8/t case)** 1183% 118499 118499 3%499

CO

2 Reduction Monetized Value (at 

$35.1/Metric Ton)*62.2/t case)** 2.50%185 185739 185739 7392.50%

CO

2 Reduction Monetized Value (at 

$64.9/Metric Ton)*117.0/t case)** 3603% 3601,534 3601,534 3%1,534

NO

X Reduction Monetized Value (at 

$2,543639/Ton)*)**

47%424424 7%24

53%531531 3%31

Total Monetary Benefits **† 

1,3357% plus 

CO

2 range

9271,748 1,116712 7%1,803

7% 1,249 1,212 1,303

1,8873% 1,463637 1,772574 3%1,718

3% plus CO

2

range 2,136 2,074 2,217

Costs

Total Incremental Installed Costs 3787% 535367 535377 7%357

4663% 475399 475414 3%385

Net Benefits/Costs

Including NO

x and CO2 ** 957 392 580 7%

Total† 1,4207% plus 

CO

2 range

9881,382 1,297335 3%1,446

7% 883 835 946

3% 1,238 1,160 1,333

3% plus CO

2

range 1,737 1,660 1,832

* These values represent global values (in 2010$) of the social cost of CO

2 emissions in 2010 under several 

scenarios. The values of $4.7, $21.4, and $35.1 per ton are the averages of SCC distributions calculated using 5-

percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $64.9 per ton represents the 95th

percentile of the SCC distribution calculated using a 3-percent discount rate. See section IV.M.1 for details. For 

NO

x

, an average value ($2,543) of the low ($451) and high ($4,635) values was used.

** Total Monetary Benefits for both the 3 percent and 7 percent cases utilize the central estimate of social cost of 

NO

x and CO2 emissions calculated at a 3

-percent discount rate (averaged across three Integrated Assessment Models 

(IAMs)), which is equal to $21.4/ton in 2010 (in 2010$).

* This table presents the annualized costs and benefits associated with walk-in coolers and freezers shipped in 

2017−2046. These results include benefits to consumers which accrue after 2046 from the walk-in coolers and 

freezers purchased in 2017−2046. Costs incurred by manufacturers, some of which may be incurred in preparation 

for the rule, are not directly included, but are indirectly included as part of incremental equipment costs. The 

Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the AEO2013

Reference case, Low Estimate, and High Estimate, respectively. In addition, incremental product costs reflect a 

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medium decline rate for projected product price trends in the Primary Estimate, a low decline rate for projected 

product price trends using a Low Benefits Estimate, and a high decline rate for projected product price trends using 

a High Benefits Estimate. 

** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are 

based on the average SCC from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. 

The fourth set, which represents the 95th percentile SCC estimate across all three models at a 3-percent discount 

rate, is included to represent higher-than-expected impacts from temperature change further out in the tails of the 

SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate an 

escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis.

† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average 

SCC with 3-percent discount rate. In the rows labeled “7% plus CO2 range” and “3% plus CO2 range,” the operating 

cost and NOX benefits are calculated using the labeled discount rate, and those values are added to the full range of 

CO2 values.

DOE has tentatively concluded that the proposed standards represent the maximum 

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

DOE further notes that manufacturers already produce commercially available equipment that 

achieve these levels for most, if not all, equipment classes covered by today’s proposal. Based on 

the analyses described above, DOE has tentatively concluded that the benefits of the proposed 

standards to the Nation (energy savings, positive NPV of consumer benefits, consumer LCC 

savings, and emission reductions) would outweigh the burdens (loss of INPV for manufacturers). 

DOE also considered more-stringent energy useand less-stringent efficiency levels as trial 

standard levels (TSLs), and is still considering them in this rulemaking. However, DOE has 

tentatively concluded that the potential burdens of the more-stringent energy useefficiency levels 

would outweigh the projected benefits. Based on consideration of the public comments DOE 

receives in response to this notice and related information collected and analyzed during the 

course of this rulemaking effort, DOE may adopt energy useefficiency levels presented in this 

notice that are either higher or lower than the proposed standards, or some combination of 

level(s) that incorporate the proposed standards in part. 

Comment [A1]: Subsequent breaking out of data 

in later sections (by component) were in response to 

comments from OIRA.

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VI.II. Introduction

The following section briefly discusses the statutory authority underlying today’s 

proposal, as well as some of the relevant historical background related to walk-ins. 

A. Authority

Title III, Part C of the Energy Policy and Conservation Act of 1975 (EPCA or the Act),, 

Pub. L. 94-163 (42 U.S.C. 6311-6317, as amended, sets forth a variety of provisions designed to 

improve energy efficiency. Part B ofcodified), added by Pub. L. 95-619, Title III (42 U.S.C. 

6291–6309) provides for IV, section 441(a), established the Energy Conservation Program for 

Consumer Products Other Than Automobiles. Part C of Title III (42 U.S.C. 6311– 6317) 

established an energy conservationCertain Industrial Equipment, a program forcovering certain 

industrial equipment, including which includes the walk-ins, which in coolers and walk-in 

freezers that are the subjectfocus of this rulemaking.notice. 13,14 (42 U.S.C. 6311(1), (20), 6313(f) 

and 6314(a)(9)) Walk-ins consist of two major pieces – the structural “envelope” within which 

items are stored and a refrigeration system that cools the air in the envelope’s interior.

DOE’s energy conservation program for covered equipment generally consists of four 

parts: (1) testing; (2) labeling; (3) the establishment of Federal energy conservation standards; 

and (4) certification and enforcement procedures. For walk-ins, DOE is responsible for the 

 

13 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012). 14 UponFor editorial reasons, upon codification in Title 42 of the U.S. Code, these parts were subsequently 

redesignated as PartsPart C was re-designated Part A and A–-1, respectively, for editorial reasons. 

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entirety of this program. The DOE test procedures for walk-ins, including those prescribed by 

Congress in EISA 2007 and those established by DOE in the test procedure final rule, currently 

appear at title 10 of the Code of Federal Regulations (CFR) part 431, section 304. 

Any new or amended performance standards that DOE prescribes for walk-ins must

achieve the maximum improvement in energy efficiency that is technologically feasible and 

economically justified. (42 U.S.C. 6313(f)(4)(A)) For purposes of this rulemaking, DOE also

plans to adopt those standards that are likely to result in a significant conservation of energy that 

satisfies both of these requirements. See 42 U.S.C. 6295(o)(3)(B). 

Technological feasibility is determined by examining technologies or designs that could 

be used to improve the efficiency of the covered equipment. DOE considers a design to be 

technologically feasible if it is in use by the relevant industry or if research has progressed to the 

development of a working prototype. 

In ascertaining whether a particular standard is economically justified, DOE considers, to 

the greatest extent practicable, the following factors: 

1. The economic impact of the standard on manufacturers and consumers of the equipment 

subject to the standard;

2. The savings in operating costs throughout the estimated average life of the covered equipment 

in the type (or class) compared to any increase in the price, initial charges, or maintenance 

expenses for the covered equipment that are likely to result from the imposition of the standard; 
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3. The total projected amount of energy or, as applicable, water savings likely to result directly 

from the imposition of the standard;

4. Any lessening of the utility or the performance of the covered equipment 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 and water conservation; and

7. Other factors the Secretary of Energy (Secretary) considers relevant. (42 U.S.C. 

6295(o)(2)(B)(i) (I)–(VII))

DOE does not plan to prescribe an amended or new standard if interested persons have 

established by a preponderance of the evidence that the standard is likely to result in the 

unavailability in the United States of any covered product type (or class) of performance 

characteristics (including reliability), features, sizes, capacities, and volumes that are 

substantially the same as those generally available in the United States. Further, under EPCA’s 

provisions for consumer products, there is a rebuttable presumption that a standard is 

economically justified if the Secretary finds that the additional cost to the consumer of 

purchasing a product complying with an energy conservation standard level will be less than 

three times the value of the energy savings during the first year that the consumer will receive as 

a result of the standard, as calculated under the applicable test procedure. (42 U.S.C. 

6295(o)(2)(B)(iii)) For purposes of its walk-in analysis, DOE plans to account for these factors. 

Comment [A2]: Edit per OIRA.

Comment [A3]: Edit per OIRA.
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Additionally, when a type or class of covered equipment such as walk-ins has two or 

more subcategories, in promulgating standards for such equipment, DOE often specifies more 

than one standard level. DOE generally will adopt a different standard level than that which 

applies generally to such type or class of products for any group of covered products that have 

the same function or intended use if DOE determines that products within such group (A) 

consume a different kind of energy than that consumed by other covered products within such 

type (or class) or (B) have a capacity or other performance-related feature that other products 

within such type (or class) do not have, and which justifies a higher or lower standard. Generally, 

in determining whether a performance-related feature justifies a different standard for a group of 

products, DOE considers such factors as the utility to the consumer of the feature and other 

factors DOE deems appropriate. In a rule prescribing such a standard, DOE typically includes an 

explanation of the basis on which such higher or lower level was established. DOE plans to 

follow a similar process in the context of today’s rulemaking.

DOE notes that since the inception of the statutory requirements setting standards for 

walk-ins, Congress has since made one additional amendment to those provisions. That 

amendment provides that the wall, ceiling, and door insulation requirements detailed in 42 

U.S.C. 6313(f)(1)(C) do not apply to the given component if the component’s manufacturer has 

demonstrated to the Secretary’s satisfaction that “the component reduces energy consumption at 

least as much” if those specified requirements were to apply to that manufacturer’s component. 

American Energy Manufacturing Technology Corrections Act, Pub. L. No. 112-210, Sec. 2 

(Dec. 18, 2012) (codified at 42 U.S.C. 6313(f)(6)) (AEMTCA). Manufacturers seeking to avail 

themselves of this provision must “provide to the Secretary all data and technical information 
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necessary to fully evaluate its application.” Id. DOE is proposing to codify this amendment into 

its regulations.

Since its codification, one company, HH Technologies, submitted data on May 24, 2013, 

demonstrating that its RollSeal doors satisfied this new AEMTCA provision. DOE reviewed 

these data and all other submitted information and concluded that the RollSeal doors at issue 

satisfied 42 U.S.C. 6313(f)(6). Accordingly, DOE issued a determination letter on June 14, 

2013, indicating that these doors met Section 6313(f)(6) and that the applicable insulation 

requirements did not apply to the RollSeal doors HH Technologies identified. Nothing in this 

proposed rule affects the previous determination regarding HH Technologies.

Federal energy conservation requirements generally supersedepre-empt state laws or 

regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a); 

42 U.S.C. 6316(b)) However, EPCA also provides that for walk-ins in particular, any state

standard issued before publication of the final rule shall not be pre-empted until the standards 

established in the final rule take effect. (42 U.S.C 6316(h)(2)(B))

Where applicable, DOE generally considers standby and off mode energy use for certain 

covered products or equipment when developing energy conservation standards. See 42 U.S.C. 

6295(gg)(3). Because mostthe vast majority of walk-in coolers and walk-in freezers operate 

continuously to keep their contents cold at all times, DOE is not proposing standards for standby 

and off mode energy use.

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DOE has also reviewed this regulation pursuant to Executive Order 13563 (76 FR 3281, 

Jan. 21, 2011). EO 13563 is supplemental to, and explicitly reaffirms the principles, structures, 

and definitions governing regulatory review established in, Executive Order 12866. To the extent 

permitted by law, agencies are required by Executive Order 13563 to: (1) propose or adopt a 

regulation only upon a reasoned determination that its benefits justify its costs (recognizing that 

some benefits and costs are difficult to quantify); (2) tailor regulations to impose the least burden 

on society, consistent with obtaining regulatory objectives, taking into account, among other 

things, and to the extent practicable, the costs of cumulative regulations; (3) select, in choosing 

among alternative regulatory approaches, those approaches that maximize net benefits (including 

potential economic, environmental, public health and safety, and other advantages; distributive 

impacts; and equity); (4) to the extent feasible, specify performance objectives, rather than 

specifying the behavior or manner of compliance that regulated entities must adopt; and (5) 

identify and assess available alternatives to direct regulation, including providing economic 

incentives to encourage the desired behavior, such as user fees or marketable permits, or 

providing information upon which choices can be made by the public. 

DOE emphasizes as well that Executive Order 13563 requires agencies to use the best 

available techniques to quantify anticipated present and future benefits and costs as accurately as 

possible. In its guidance, the Office of Information and Regulatory Affairs has emphasized that 

such techniques may include identifying changing future compliance costs that might result from 

technological innovation or anticipated behavioral changes. For the reasons stated in the 

preamble, DOE believes that today’s NOPR is consistent with these principles, including that, to 

the extent permitted by law, agencies adopt a regulation only upon a reasoned determination that 
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its benefits justify its costs and select, in choosing among alternative regulatory approaches, 

those approaches that maximize net benefits. 

Consistent with EO 13563, and the range of impacts analyzed in this rulemaking, the 

energy efficiency standard proposed herein by DOE achieves maximum net benefits.

B. Background

1. Current Standards 

EPCA defines a walk-in cooler and a walk-in freezer as an enclosed storage space 

refrigerated to temperatures above, and at or below, respectively, 32 °F that can be walked into. 

The statute also defines walk-in coolers and freezers as having a total chilled storage area of less 

than 3,000 square feet, excluding products designed and marketed exclusively for medical, 

scientific, or research purposes. (42 U.S.C 6311(20)) EPCA also provides prescriptive standards 

for walk-in coolers and freezers manufactured on or after January 1, 2009, which are described 

below. 

First, EPCA sets forth general prescriptive standards for walk-ins. Walk-ins must have 

automatic door closers that firmly close all walk-in doors that have been closed to within 1 inch

of full closure, for all doors narrower than 3 feet 9 inches and shorter than 7 feet; walk-ins must 

also have strip doors, spring hinged doors, or other methods of minimizing infiltration when 

doors are open. Walk-ins must also contain wall, ceiling, and door insulation of at least R-25 for 

coolers and R-32 for freezers, excluding glazed portions of doors and structural members, and 

floor insulation of at least R-28 for freezers. Walk-in evaporator fan motors of under 1 

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horsepower and less than 460 volts must be electronically commutated motors (brushless direct 

current motors) or three-phase motors, and walk-in condenser fan motors of under 1 horsepower 

must use permanent split capacitor motors, electronically commutated motors, or three-phase 

motors. Interior light sources must have an efficacy of 40 lumens per watt or more, including any 

ballast losses; less-efficacious lights may only be used in conjunction with a timer or device that 

turns off the lights within 15 minutes of when the walk-in is unoccupied. See 42 U.S.C. 

6313(f)(1). 

 Second, EPCA sets forth new requirements related to electronically commutated motors 

for use in walk-ins. See 42 U.S.C. 6313(f)(2)). Specifically, in those walk-ins that use an 

evaporator fan motor with a rating of under 1 horsepower and less than 460 volts, that motor 

must be either a three-phase motor or an electronically commutated motor unless DOE 

determined prior to January 1, 2009 that electronically commutated motors are available from 

only one manufacturer. (42 U.S.C. 6313(f)(2)(A)) DOE determined by January 1, 2009 that these 

motors were available from more than one manufacturer; thus, the stated requirements 

apply.according to EPCA, walk-in evaporator fan motors with a rating of under 1 horsepower 

and less than 460 volts must be either three-phase motors or electronically commutated motors. 

DOE documented this determination in the rulemaking docket as docket ID EERE-2008-BTSTD-0015-0072. This document can be found at 

http://www.regulations.gov/#!documentDetail;D=EERE-2008-BT-STD-0015-0072.

Additionally, EISA provided DOE with the authority to permit the use of other types of motors 

as evaporative fan motors—if DOE determines that, on average, those other motor types use no 

more energy in evaporative fan applications than electronically commutated motors. (42 U.S.C. 
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6313(f)(2)(B)) DOE is unaware of any other motors that would offer performance levels 

comparable to the electronically commutated motors required by Congress. Accordingly, all 

evaporator motors rated at under 1 horsepower and under 460 volts must be electronically 

commutated motors or three-phase motors. 

Third, EPCA sets forth additional requirements for walk-ins with transparent reach-in 

doors. Freezer doors must have triple-pane glass with either heat-reflective treated glass or gas 

fill for doors and windows for freezers. Cooler doors must have either double-pane glass with 

treated glass and gas fill or triple-pane glass with treated glass or gas fill. (42 U.S.C. 

6313(f)(3)(A)-(B)) For walk-ins with transparent reach-in doors, EISA also prescribed specific 

anti-sweat heater-related requirements: walk-ins without anti-sweat heater controls must have a 

heater power draw of no more than 7.1 or 3.0 watts per square foot of door opening for freezers 

and coolers, respectively. Walk-ins with anti-sweat heater controls must either have a heater 

power draw of no more than 7.1 or 3.0 watts per square foot of door opening for freezers and 

coolers, respectively, or the anti-sweat heater controls must reduce the energy use of the heater in 

a quantity corresponding to the relative humidity of the air outside the door or to the 

condensation on the inner glass pane. See 42 U.S.C. 6313(f)(3)(C)-(D). 

2. History of Standards Rulemaking for Walk-in Coolers and Freezers

EPCA directs the Secretary to issue performance-based standards for walk-ins that would 

apply to equipment manufactured 3 years after the final rule is published, or 5 years if the 

Secretary determines by rule that a 3-year period is inadequate. (42 U.S.C. 6313(f)(4)) 

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DOE initiated the current rulemaking by publishing a notice announcing the availability 

of its “Walk-In Coolers and Walk-In Freezers Energy Conservation Standard Framework 

Document” and a meeting to discuss the document. The notice also solicited comment on the 

matters raised in the document. 74 FR 411 (JanuaryJan 6, 2009). A PDF ofMore information on

the framework document is available at: 

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

ment.html.http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/3

0. The framework document described the procedural and analytical approaches that DOE 

anticipated using to evaluate energy conservation standards for walk-ins and identified various 

issues to be resolved in conducting this rulemaking.

DOE held the framework public meeting on February 4, 2009, in which it: (1) presented 

the contents of the framework document; (2) described the analyses it planned to conduct during 

the rulemaking; (3) sought comments from interested parties on these subjects; and (4) in 

general, sought to inform interested parties about, and facilitate their involvement in, the 

rulemaking. Major issues discussed at the public meeting included: (1) the scope of coverage for 

the rulemaking; (2) development of a test procedure and appropriate test metrics; (3) 

manufacturer and market information, including distribution channels; (4) equipment classes, 

baseline units, and design options to improve efficiency; and (5) life-cycle costs to consumers, 

including installation, maintenance, and repair costs, and any consumer subgroups DOE should 

consider. At the meeting and during the comment period on the framework document, DOE 

received many comments that helped it identify and resolve issues pertaining to walk-ins 

relevant to this rulemaking. 
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DOE then gathered additional information and performed preliminary analyses to help 

develop potential energy conservation standards for this equipment. This process culminated in 

DOE’s announcement of another public meeting to discuss and receive comments on the 

following matters: (1) the equipment classes DOE planned to analyze; (2) the analytical 

framework, models, and tools that DOE used to evaluate standards; (3) the results of the 

preliminary analyses performed by DOE; and (4) potential standard levels that DOE could 

consider. 75 FR 17080 (April 5, 2010) (the April 2010 Notice). DOE also invited written 

comments on these subjects and announced the availability on its website of a preliminary 

technical support document (preliminary TSD) it had prepared to inform interested parties and 

enable them to provide comments. Id. (The preliminary TSD is available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/wicf_preliminary_tsd.ht

ml (More information about the preliminary TSD is available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/30.)Finally, 

DOE sought views on other relevant issues that participants believed either would impact walkin standards or that the proposal should address. Id. at 17083. 

The preliminary TSD provided an overview of the activities DOE undertook to develop 

standards for walk-ins and discussed the comments DOE received in response to the framework 

document. The preliminary TSD also addressed separate standards for the walk-in envelope and 

the refrigeration system, as well as compliance and enforcement responsibilities and food safety 

regulatory concerns. The document also described the analytical framework that DOE used (and 

continues to use) in considering standards for walk-in coolers and freezers, including a 
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description of the methodology, the analytical tools, and the relationships between the various 

analyses that are part of this rulemaking. Additionally, the preliminary TSD presented in detail 

each analysis that DOE had performed for these products up to that point, including descriptions 

of inputs, sources, methodologies, and results. These analyses were as follows: 

• A market and technology assessment addressed the scope of this rulemaking, identified the 

potential classes for walk-in coolers and freezers, characterized the markets for these products, 

and reviewed techniques and approaches for improving their efficiency;

• A screening analysis reviewed technology options to improve the efficiency of walk-in coolers 

and freezers, and weighed these options against DOE’s four prescribed screening criteria;

• An engineering analysis estimated the manufacturer selling prices (MSPs) associated with more

energy-efficient walk-in coolers and freezers; 

• An energy use analysis estimated the annual energy use of walk-in coolers and freezers; 

• A markups analysis converted estimated MSPs derived from the engineering analysis to 

consumer prices;

• A life-cycle cost analysis calculated, for individual consumers, the discounted savings in 

operating costs throughout the estimated average life of walk-in coolers and freezers, compared 

to any increase in installed costs likely to result directly from the imposition of a given standard;

• A payback period analysis estimated the amount of time it takes individual consumers to recover 

the higher purchase price expense of more energy-efficient products through lower operating 

costs;

• A shipments analysis estimated shipments of walk-in coolers and freezers over the time period 

examined in the analysis, and was used in performing the national impact analysis;

• A national impact analysis assessed the national energy savings and the national net present 

value of total consumer costs and savings that are expected to result from specific potential 

energy conservation standards for walk-in coolers and freezers; and

• A preliminary manufacturer impact analysis (MIA) took the initial steps in evaluating the effects 

on manufacturers of new efficiency standards. 

 

 The public meeting announced in the April 2010 Notice took place on May 19, 2010. At 

this meeting, DOE presented the methodologies and results of the analyses set forth in the 

preliminary TSD. Interested parties that participated in the public meeting discussed a variety of 

topics, but the comments centered on the following issues: (1) separate standards for the 

refrigeration system and the walk-in envelope; (2) responsibility for compliance; (3) equipment 

classes; (4) technology options; (5) energy modeling; (6) installation, maintenance, and repair 

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costs; (7) markups and distributions chains; (8) walk-in cooler and freezer shipments; and (9) test 

procedures. The comments received since publication of the April 2010 Notice, including those 

received at the May 2010 public meeting, have contributed to DOE’s proposed resolution of the 

issues in this rulemaking, as they pertain to walk-ins. This NOPR responds to the issues raised by 

the commenters. (A parenthetical reference at the end of a quotation or paraphrase provides the 

location of the item in the public record.)

 

VII.III. General Discussion

In preparing today’s notice, DOE considered input from the various interested parties 

who commented on the framework document and preliminary analysis, information obtained 

from manufacturer interviews, and additional research that DOE conducted. The interested 

parties who provided comments to DOE during the framework document and preliminary 

analysis phases included the following: 

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Table III-1 Framework and Preliminary Analysis Commenters

VIII. Commenter(s)

IX. Abbrev

iated 

Designation

X. Affiliation

XI. Comm

ent Number(s)

in Docket

Kason Industries, Inc. Kason Component Supplier 0009.1, 0019.1

Craig Industries, Inc. and US Cooler Company Craig Industries Manufacturer

0011.1, 0025.1, 

0038.1, 0064.1, 

0071.1

AFM Corporation AFM Manufacturer 0012.1

Eliason Corporation Eliason Manufacturer 0013.1, 0022.1

The Northwest Energy Efficiency Alliance and 

the Northeast Power Coordinating Council

NEEA and 

NPCC

Utility 

Representative 0021.1, 0059.1

Bally Refrigerated Boxes, Inc. Bally Manufacturer 0023.1

Appliance Standards Awareness Project ASAP Energy Efficiency 

Advocate 0024.1

CrownTonka Walk-ins CrownTonka Manufacturer 0026.1, 0057.1

Earthjustice Earthjustice Energy Efficiency 

Advocate 0027.1, 0047.1

Edison Electric Institute EEI Energy Efficiency 

Advocate 0028.1

Foam Supplies, Inc. FSI Material Supplier 0029.1

Hired Hand Technologies Hired Hand Manufacturer 0030.1, 0050.1

Heating, Air-conditioning & Refrigeration 

Distributors International HARDI Trade Association 0031.1

Kysor Panel Systems Kysor Manufacturer 0032.1, 0054.1

Nor-Lake, Incorporated Nor-Lake Manufacturer 0049.1

Owens Corning Foam Insulation, LLC Owens Corning Material Supplier 0034.1

Southern California Edison and Technology 

Test Centers SCE Utility 0035.1

Air-Conditioning, Heating, and Refrigeration 

Institute AHRI Trade Association 0036.1, 0055.1

American Panel CorporationChemistry 

Council

American 

PanelACC

ManufacturerMateri

al Supplier

00390062.1, 

0048.1

Master-Bilt Products, Inc. Master-Bilt Manufacturer 0033.1, 0046.1

Zero-Zone, Inc. Zero-Zone Manufacturer 0051.1

American Chemistry Council Center for the 

Polyurethanes Industry CPI Material Supplier 0052.1

Hussmann and Ingersoll Rand Ingersoll Rand Manufacturer 0053.1

Manitowoc Ice Manitowoc Manufacturer 0056.1

Heatcraft Refrigeration Products LLC Heatcraft Manufacturer 0058.1, 0069.1

Southern California Edison, San Diego Gas & 

Electric, Pacific Gas & Electric Company, 

Sacramento Municipal Utility District

Joint Utilities Utility Group 0061.1

American Chemistry Council ACC Material Supplier 0062.1

Craig Industries, Inc. and U.S. Cooler 

Company Craig Industries Manufacturer 0064.1

AmeriKooler, Inc. AmeriKooler Manufacturer 0065.1

Hill Phoenix Walk-Ins Hill Phoenix Manufacturer 0066.1

NanoPore Insulation, LLC NanoPore Material Supplier 0067.1

Carpenter Co. Chemical Systems Division Carpenter Material Supplier 0068.1

American Council for an Energy Efficient 

Economy, Appliance Standards Awareness 

Project, Alliance to Save Energy, Natural 

Resources Defense Council, Northwest Energy 

Joint Advocates Energy Efficiency 

Advocates 0070.1

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Efficiency Alliance

American Panel Corporation American Panel Manufacturer 0039.1, 0048.1

AmeriKooler, Inc. AmeriKooler Manufacturer 0065.1

Appliance Standards Awareness Project ASAP Energy Efficiency 

Advocate 0024.1

Bally Refrigerated Boxes, Inc. Bally Manufacturer 0023.1

Carpenter Co. Chemical Systems Division Carpenter Material Supplier 0068.1

Craig Industries, Inc. and U.S. Cooler 

Company Craig Industries Manufacturer 0064.1

Craig Industries, Inc. and US Cooler Company Craig Industries Manufacturer

0011.1, 0025.1, 

0038.1, 0064.1, 

0071.1

CrownTonka Walk-ins CrownTonka Manufacturer 0026.1, 0057.1

Earthjustice Earthjustice Energy Efficiency 

Advocate 0027.1, 0047.1

Edison Electric Institute EEI Energy Efficiency 

Advocate 0028.1

Eliason Corporation Eliason Manufacturer 0013.1, 0022.1

Foam Supplies, Inc. FSI Material Supplier 0029.1

Heatcraft Refrigeration Products LLC Heatcraft Manufacturer 0058.1, 0069.1

Heating, Air-conditioning & Refrigeration 

Distributors International HARDI Trade Association 0031.1

Hill Phoenix Walk-Ins Hill Phoenix Manufacturer 0066.1

Hired Hand Technologies Hired Hand Manufacturer 0030.1, 0050.1

Hussmann and Ingersoll Rand Ingersoll Rand Manufacturer 0053.1

Kason Industries, Inc. Kason Component Supplier 0009.1, 0019.1

Kysor Panel Systems Kysor Manufacturer 0032.1, 0054.1

Manitowoc Ice Manitowoc Manufacturer 0056.1

Master-Bilt Products, Inc. Master-Bilt Manufacturer 0033.1, 0046.1

NanoPore Insulation, LLC NanoPore Material Supplier 0067.1

Nor-Lake, Incorporated Nor-Lake Manufacturer 0049.1

Owens Corning Foam Insulation, LLC Owens Corning Material Supplier 0034.1

Southern California Edison and Technology 

Test Centers SCE Utility 0035.1

Southern California Edison, San Diego Gas & 

Electric, Pacific Gas & Electric Company,

Sacramento Municipal Utility District

Joint Utilities Utility Group 0061.1

The Northwest Energy Efficiency Alliance and 

the Northeast Power Coordinating Council

NEEA and 

NPCC

Utility 

Representative 0021.1, 0059.1

Zero-Zone, Inc. Zero-Zone Manufacturer 0051.1

A. Component Level Standards

In the framework document, DOE considered setting standards that would apply to the 

entire walk-in. See the framework document at 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/wicf_framework_

doc.pdf. Several interested parties expressed concern about this approach because of the variety

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among assembled walk-ins, which would make compliance with such a walk-in standard 

difficult and burdensome. Stakeholders also stated that different components of each walk-in 

would likely be manufactured by different entities, which would make it difficult to enforce any 

standard that applied to an entire walk-in. 

After considering the comments submitted on the framework document, DOE modified 

its approach in the preliminary analysis. During that phase, it had tentatively identified two 

primary components of a walk-in: the envelope (the insulated box that separates the exterior 

from the interior) and the refrigeration system (the mechanical equipment that cools the 

envelope’s interior.). DOE also indicated that it was tentatively considering developing separate

standards for refrigeration systems and envelopes. 

Several interested parties agreed with this general approach. Manitowoc supported 

separate standards for the envelope and refrigeration system, stating that the envelope is typically 

supplied by one manufacturer and the refrigeration system is typically supplied by one or more 

manufacturers. (Manitowoc, Public Meeting Transcript, No. 0045 at p. 38 and No. 0056.1 at p. 

1) Manitowoc further stated that it would not be practical to regulate the energy used by the 

entire walk-in assembly because walk-ins are highly customized. Manitowoc, estimated that 

fewer than 20 percent of its walk-ins use a standard envelope and refrigeration system 

combination. (Manitowoc, No. 0056.1 at p. 1) Pacific Gas and Electric Company, Southern 

California Edison, Sempra Energy Utility, and the Sacramento Municipal Utility District 

(hereafter referred to as the “Joint Utilities”) also agreed with DOE’s proposal to separate the 

refrigeration system standards from the envelope standards because the components are 
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separately produced and often separately sold. (Joint Utilities, No. 0061.1 at pp. 2-3) American 

Panel stated that the envelope and refrigeration systems must be considered separately because 

the majority of WICFs are custom-made. (American Panel, No. 0048.1 at p. 4) Kysor, MasterBilt, AHRI, and CrownTonka all supported separate standards for the envelope and refrigeration 

systems. (Kysor, Public Meeting Transcript, No. 0045 at p. 39; Master-Bilt, No. 0046.1 at p. 1; 

AHRI, No. 0055.1 at p. 2; CrownTonka, No. 0057.1 at p. 1) One interested party did not agree 

with this approach:. Craig Industries, also doing business as U.S. Cooler, commented that DOE 

should establish a combination standard for the envelope and refrigeration system to permit 

manufacturers greater flexibility when designing walk-ins. Under this combination approach, a 

more efficient envelope could be paired with a less efficient refrigeration system, or vice versa, 

to achieve the same overall efficiency at a lower cost. (Craig Industries, No. 0064.1 at p. 1) 

Additionally, interested parties suggested that DOE extend the idea of separate standards 

to subcomponents of envelopes and refrigeration systems. The Joint Utilities stated that a 

component performance approach would accurately capture efficiency measurements associated 

with the components, and that energy savings associated with targeted components would apply 

to different configurations of whole walk-ins and possibly even to repairs and retrofits. (Joint 

Utilities, No. 0061.1 at p. 4) The Joint Utilities further added that DOE should consider 

component performance standards for major walk-in components that could be enforced at the 

level of the manufacturer’s catalog and could be labeled for easy inspection. (Joint Utilities, No. 

0061.1 at p. 12) Hill Phoenix also recommended that large construction-based envelopes (i.e.,

those constructed in a manner similar to a building) be regulated at the component level, 

asserting that these envelopes may need many different options and design flexibility, without 
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which a whole-envelope calculation would likely limit the accuracy of any estimate of a walkin’s total energy use. (Hill Phoenix, No. 0066.1 at p. 1) As stated previously, Manitowoc agreed 

that it would not be practical to regulate the energy used by the entire walk-in assembly because 

walk-ins are highly customized. (Manitowoc, No. 0056.1 at p. 1) Manitowoc also remarked that 

performance metrics could be developed for sub-classes of the components of an envelope, and 

the component manufacturers should be responsible for their own components. (Manitowoc, 

Public Meeting Transcript, No. 0045 at p. 46) 

Other stakeholders discussed specific sub-components of the envelope or the refrigeration 

system that could be regulated. Kysor mentioned panels and doors as envelope components that 

should be considered separately and stated that because these components are often 

manufactured by separate parties, the manufacturer of each component should be responsible for 

the performance of that component. (Kysor, Public Meeting Transcript, No. 0045 at p. 41) The

Northwest Energy Efficiency Alliance (NEEA) and Northwest Power Conservation Council 

(NPCC) recommended that DOE develop efficiency performance standards for display and solid 

doors separately so that an envelope manufacturer could certify that the envelope meets specified 

standards. (NEEA and NPCC, No. 0059.1 at p. 2)

Likewise, with regard to the refrigeration system, NEAA and NPCC recommended that 

DOE regulate the efficiency of the cooling system components separately, an example of which 

would be setting a performance requirement for the specific efficiency of unit coolers based on 

control algorithms. (NEAA and NPCC, No. 0059.1 at pp. 2 and 7) The Joint Utilities also stated 

that a refrigeration system requirement should not be based on a single metric and added that the 
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indoor unit (i.e., unit cooler) could have a minimum efficiency requirement regardless of other 

components of the refrigeration system. (Joint Utilities, No. 0061.1 at p. 4 and Public Meeting 

Transcript, No. 0045 at p. 64) Manitowoc, on the other hand, recommended that manufacturers 

have the option of rating the entire refrigeration system and that considering the condensing unit 

separately would not allow manufacturers to implement options that would improve the 

efficiency of a matched system. (Manitowoc, Public Meeting Transcript, No. 0045 at p. 38) 

Manitowoc further remarked that testing the refrigeration system as an integrated, single 

component and calculating the overall annual efficiency has the greatest potential for optimizing 

energy efficiency, but added that DOE should permit the individual components to be tested and 

the performance stated for the individual parts. (Manitowoc, Public Meeting Transcript, No. 

0045 at p. 59) 

After carefully considering the comments described above, DOE proposes an approach 

for the envelope that would set separate standards for panels, display doors, and non-display 

doors for the reasons set forth below. 

Different manufacturers typically produce panels and doors (both display and non-display

types) for use in walk-in applications. In particular, display doors are commonly manufactured 

separately because their unique construction and materials require specialized manufacturing 

methods. Additionally, the modular nature of a walk-in envelope means that it is constructed of 

relatively standardized components that can be assembled in a virtually infinite number of 

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

performance of those standardized components, manufacturers will be able to choose compliant 
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components that should help ensure that whatever walk-in configuration is built satisfies the 

minimal level of energy consumption and efficiency that DOE may prescribe. Because of the 

large number of possible combinations of panels and doors that could make up an envelope, the

burdens presented by a system-based approach for the entire walk-in unit would also likely be 

significantly greater than the burdens of the proposed approach because each walk-in envelope 

configuration would need to be separately certified as compliant. Alternatively, if DOE were to 

establish a set envelope of specified dimensions for a manufacturer to build and then to certify as 

compliant, the efficiency or energy usage measurement from that envelope would not only be 

more costly to obtain, but it would also not necessarily reflect the actual energy usage or 

efficiency of a given walk-in that is installed in the field.

DOE also notes that requiring an overall envelope performance standard would be likely 

to present significant enforcement burdens, as it would likely require DOE to test several fully 

constructed envelopes in order to ascertain the energy efficiency performance of a given 

envelope. DOE tentatively believes that such an approach, at this time, would be unduly 

burdensome. 

DOE is not, however, proposing to set standards for the constituent components of 

refrigeration systems separately. To ensure that manufacturers have sufficient flexibility to

improve the energy efficiency performance of their systems, DOE proposes to set a performance 

standard for the overall refrigeration system and to regulate that system as a single component. 

This approach would help ensure that the final refrigeration system assembled by the 

manufacturer would meet a given level of efficiency and would account for the interactive 
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effects of the numerous components comprising the overall system. For example, some 

refrigeration systems implement complex control strategies, the benefits of which could not be 

adequately demonstrated if the condensing unit and unit cooler were considered separately for 

purposes of setting standards. 

In summary, DOE proposes to set specific component standards for the panels, display 

doors, and non-display doors of a walk-in, and a single standard to assess the overall 

performance of the refrigeration system. DOE acknowledges that, by not establishing a standard 

for the energy use of the entire walk-in, manufacturers cannot meet the standard by pairing a 

more-efficient envelope with a less-efficient refrigeration system, and vice versa. Also, DOE 

would not account for the energy use of some components, such as the electricity use of 

overhead lighting or heat load due to the infiltration of warm air into the walk-in, and would not 

consider design options whose efficacy depends on the interaction between the different covered 

components. Including these factors as part of the current rulemaking would likely introduce 

significant complications with respect to compliance and enforcement and while yielding a 

comparatively small benefit in energy savings. DOE believes, however, that the proposed 

approach would help ensure that the walk-in components used by manufacturers satisfy some 

minimal level of energy efficiency and reduce the overall certification and enforcement burden 

on manufacturers. DOE may reconsider this issue in the future, particularly if accurate computer 

modeling, such as through an alternative efficiency determination method, becomes possible 

with respect to predicting the energy usage and efficiency of fully constructed walk-in units. 

DOE continues to invite comments on the approach presented in this NOPR.
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B. Test Procedures and Metrics

While Congress had initially prescribed certain performance standards and test 

procedures concerning walk-ins as part of the EISA 2007 amendments, Congress also instructed 

DOE to develop specific test procedures to cover walk-in equipment. DOE subsequently 

established a test procedure for walk-ins. See 76 FR 21580 (April 15, 2011). See also 76 FR 

33631 (June 9, 2011) (final technical corrections). The test procedure lays out an approach that 

bases compliance on the ability of component manufacturers to produce components that meet 

the required standards. This approach is also consistent with the framework established by 

Congress, which set specific energy efficiency performance requirements on a component-level 

basis. (42 U.S.C. 6313(f)) The approach is discussed more fully below. 

1. Panels

In the final test procedure rule for walk-ins, DOE defines “panel” as a construction 

component, excluding doors, used to construct the envelope of the walk-in (i.e., elements that 

separate the interior refrigerated environment of the walk-in from the exterior). 76 FR 33631 

(June 9, 2011). The rule explains that panel manufacturers would test their panels to obtain a 

thermal transmittance metric -- —known as U-factor, measured in Btu/h-ft2

-

°

F -- —and identifies 

three types of panels: display panels, floor panels, and non-floor panels. A display panel is 

defined as a panel that is entirely or partially comprised of glass, a transparent material, or both,

and is used for display purposes. Id. It is considered equivalent to a window and the U-factor is 

determined by NFRC 100-2010-E0A1, “Procedure for Determining Fenestration Product Ufactors.” 76 FR at 33639. Floor panels are used for walk-in floors, whereas non-floor panels are 

used for walls and ceilings. 

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The U-factor for floor and non-floor panels accounts for any structural members internal 

to the panel and the long-term thermal aging of foam. This value is determined by a three-step 

process. First, both floor and non-floor panels must be tested using ASTM C1363-10, “Standard 

Test Method for Thermal Performance of Building Materials and Envelope Assemblies by 

Means of a Hot Box Apparatus.” The panel’s core and edge regions must be used during testing. 

Second, the panel’s core U-factor must be adjusted with a degradation factor to account for foam 

aging. The degradation factor is determined by EN 13165:2009-02, “Thermal Insulation 

Products for Buildings - Factory Made Rigid Polyurethane Foam (PUR) Products - 

Specification,” or EN 13164:2009-02, “Thermal Insulation Products for Buildings - Factory 

Made Products of Extruded Polystyrene Foam (XPS) – Specification,” as applicable. Third, the

edge and modified core U-factors are then combined to produce the panel’s overall U-factor. All 

industry protocols were incorporated by reference most recently in the test procedure final rule

correction. 76 FR 33631. 

2. Doors

 The walk-in test procedure final rule addressed two door types: display and non-display 

doors. Within the general context of walk-ins, a door consists of the door panel, glass, framing 

materials, door plug, mullion, and any other elements that form the door or part of its connection 

to the wall. DOE defines display doors as doors designed for product movement, display, or 

both, rather than the passage of persons; a non-display door is interpreted to mean any type of 

door that is not captured by the definition of a display door. 76 FR at 33631. 

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The test metric for doors is in terms of energy use, measured in kilowatt-hours per day 

(kWh/day). The energy use accounts for thermal transmittance through the door and the 

electricity use of any electrical components associated with the door. The thermal transmittance 

is measured by NFRC 100-2010-E0A1, and is converted to energy consumption via conduction 

losses using an assumed efficiency of the refrigeration system in accordance with the test 

procedure final rule.. See 76 FR at 33636-33637. The electrical energy consumption of the door 

is calculated by summing each electrical device’s individual consumption and accounts for all 

device controls by applying a “percent time off” value to the appropriate device’s energy 

consumption. For any device that is located on the internal face of the door or inside the door, 75 

percent of its power is assumed to contribute to an additional heat load on the compressor. 

Finally, the total energy consumption of the door is found by combining the conduction load, 

electrical load, and additional compressor load. 

3. Refrigeration

The test procedure incorporates an industry test procedure applied to walk-in 

refrigeration systems: AHRI 1250 (I-P)-2009, “2009 Standard for Performance Rating of WalkIn Coolers and Freezers” (“AHRI 1250-2009”). 76 FR at 33631. This procedure applies to unit 

coolers and condensing units sold together as a matched system, unit coolers and condensing 

units sold separately, and unit coolers connected to compressor racks or multiplex condensing 

systems. It also describes methods for measuring the refrigeration capacity, on-cycle electrical 

energy consumption, off-cycle fan energy, and defrost energy. Standard test conditions, which 

are different for indoor and outdoor locations and for coolers and freezers, are also specified.

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The test procedure includes a calculation methodology to compute an annual walk-in 

energy factor (AWEF), which is the ratio of heat removed from the envelope to the total energy 

input of the refrigeration system over a year. AWEF is measured in Btu/W-h and measures the 

efficiency of a refrigeration system. DOE established a metric based on efficiency, rather than 

energy use, for describing refrigeration system performance, because a refrigeration system’s 

energy use would be expected to increase based on the size of the walk-in and on the heat load 

that the walk-in produces. An efficiency-based metric would account for this relationship and 

would simplify the comparison of refrigeration systems to each other. Therefore, DOE proposes

to use an energy conservation standard for refrigeration systems that would be presented in terms 

of AWEF. 

C. Prescriptive Versus Performance Standards 

EPCA established standards for certain WICF components of WICF, while also directing 

the Secretary to establish “performance-based standards,” which are the subject of this 

rulemaking. (42 U.S.C. 6313(f)(4)(A)) Some interested parties suggested that DOE establish 

prescriptive standards for certain components in addition to the performance-based standards that 

DOE is proposing. NEEA and NPCC stated that DOE should establish a prescriptive (i.e., 

design) standard for electronically commutated motors. (NEEA and NPCC, No. 0059.1 at p. 7) 

The Joint Utilities recommended that DOE consider the precedent set by EPCA, as the EPCA 

provisions include both prescriptive and performance standards, and further recommended that 

DOE include additional prescriptive requirements for various components of a walk-in as 

necessary to maximize energy savings, and performance standards for the unit cooler. (Joint 

Utilities, No. 0061.1 at p. 11) The Joint Utilities also recommended that DOE base new 

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standards using those design requirements already prescribed by Title 20 of California’s Code as

the baseline when developing a performance standard. (Joint Utilities, No. 0061.1 at p. 13) SCE 

also referred to the prescriptive standards in Title 20, and suggested that because EPCA already 

established prescriptive measures, there will be limited additional benefit from performance 

measures. SCE further recommended that a standard for infiltration should be implemented 

through ASHRAE 90.1 (SCE, Public Meeting Transcript, No. 0045 at p. 63) The Joint Utilities 

recommended other specific prescriptive requirements that DOE should implement, including a 

minimum solar reflective index for the roof of a walk-in located outdoors, adjustable variable 

speed fan control for unit coolers, and floating head pressure control (a control that allows the 

pressure of the refrigerant at the compressor exit point to reach an optimal level). (Joint Utilities, 

No. 0061.1 at pp. 5 and 12; Public Meeting Transcript, No. 0045 at p. 29) The Joint Utilities also 

asked DOE to examine how controls could be specified in a performance standard. (Joint 

Utilities, No. 0061.1 at p. 13) 

DOE notes that EPCA requires the promulgation of “performance-based standards” for 

walk-ins. That phrase indicates that DOE must set standards based on energy-related 

performance. See 42 U.S.C. 6313(f)(4). Accordingly, the design requirements suggested by 

commenters would be inconsistent with this requirement. 

D. Certification, Compliance, and Enforcement 

Walk-ins consist primarily of panels, display and non-display doors, and a refrigeration 

system, as described in section III.A. A number of arrangements exist for manufacturing walkins. One company may manufacture the panels, purchase the display and/or non-display doors 

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and refrigeration system, assemble the walk-in at the factory, and ship the walk-in to a consumer. 

Alternatively, the same company may ship the walk-in without a refrigeration system, which is 

then purchased separately by the consumer and installed on the walk-in. A contractor may 

purchase all the components from the component manufacturers and assemble the walk-in onsite. Other scenarios may also exist. Given the wide variety of scenarios under which a walk-in is 

manufactured, it is important to identify an entity or entities responsible for complying with 

standards and certifying compliance to DOE, and against whom a possible enforcement action 

could be taken.

During the preliminary analysis public meeting, many interested parties expressed 

concern about compliance responsibilities and whether those burdens would fall on the envelope 

and refrigeration manufacturers individually, the installer, or another party. Additionally, the 

Joint Advocates submitted a comment urging DOE to ensure that the separate system 

components would be compliant with the energy conservation standards, and stating that each 

manufacturer should be held accountable for their products (e.g., door manufacturers are 

responsible for compliance with door standards). (Joint Advocates, No. 0070.1 at pp. 2–3) Craig 

Industries recommended that the definition of a manufacturer be expanded to include the 

installer of the unit, because the installer has the ability to ensure that the installed unit meets the 

energy conservation standards. (Craig Industries, No. 0071.1 at p. 1). Comments on this issue 

were summarized in the recently published2011 Certification, Compliance, and Enforcement for 

Consumer Products and Commercial and Industrial Equipment (referred to hereafter as the CCE 

final rule), and are not repeated here. 76 FR 12422, 12442–12446 (March 7, 2011). 
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DOE notes that within the context of today’s proposal, the agency is contemplating an 

approach that would place the primary certification and compliance burden on those entities that 

manufacture particular key components of a walk-in—that is, the panels, doors, and refrigeration 

system. This approach dovetails with that outlined in the recent test procedure final rule. The 

various requirements that manufacturers would need to follow are detailed in a recentthe 2011

final rule noted above regarding manufacturer certification, compliance, and enforcement-related 

responsibilities. 76 FR 12422. For further details, see 76 FR at 12491. 

E. Technological Feasibility

1. General 

In each standards rulemaking, DOE conducts a screening analysis, which it bases on 

information gathered on all current technology options and prototype designs that could improve 

the efficiency of the products or equipment that are the subject of the rulemaking. As the first 

step in such analysis, DOE develops a list of design options for consideration in consultation 

with manufacturers, design engineers, and other interested parties. DOE then determines which 

of these means for improving efficiency are technologically feasible. DOE considers 

technologies incorporated in commercial products or in working prototypes to be technologically 

feasible. 10 CFR 430, subpart C, appendix A, section 4(a)(4)(i) Although DOE considers 

technologies that are proprietary, it will not consider efficiency levels that can only be reached 

through the use of proprietary technologies (i.e., a unique pathway), as it could allow a single 

manufacturer to monopolize the market.

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Once DOE has determined that particular design options are technologically feasible, it 

generally evaluates each of these design options in light of the following additional screening 

criteria: (1) practicability to manufacture, install, or service; (2) adverse impacts on product 

utility or availability; and (3) adverse impacts on health or safety. 10 CFR part 430, subpart C, 

appendix A, section 4(a)(4)(ii)-(iv) Section IV.B of this notice discusses the results of the 

screening analyses for walk-in coolers and freezers. Specifically, it presents the designs DOE 

considered, those it screened out, and those that are the basis for the TSLs in this rulemaking. For 

further details on the screening analysis for this rulemaking, see chapter 4 of the TSD.

2. Maximum Technologically Feasible Levels

When DOE proposes to adopt a new or amended or new energy conservation standard for 

a type or class of covered equipment such as walk-ins, it determines the maximum improvement 

in energy efficiency that is technologically feasible for such equipment. Accordingly, DOE 

determined the maximum technologically feasible (max-tech) improvements in energy efficiency

for walk-ins by applying those design parameters that passed the screening analysis to the 

engineering analysis that DOE prepared as part of the preliminary analysis. 

In a comment on the max-tech levels in the preliminary analysis, AHRI commented that 

max-tech efficiency levels would be achieved only by a few units, and it requested that DOE 

demonstrate that max-tech levels can be achieved by commonly used products. (AHRI, No. 

0055.1 at p. 3) 

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As indicated previously, whether efficiency levels exist or can be achieved in commonly 

used products does not determine whether they are max-tech levels. DOE considers technologies 

to be technologically feasible if they are incorporated in any commercially available equipment 

or working prototypes. A maximum technologically feasible level results from the combination 

of design options that result in the highest efficiency level for an equipment class, with such 

design options consisting of technologies already incorporated in commercial products or 

working prototypes. DOE notes that it re-evaluated the efficiency levels, including the max-tech 

levels, when it updated its results for this NOPR. See chapter 5 of the NOPR TSD for the results 

of the analysis. 

For panels, non-display doors, display doors, and refrigeration systems, the max-tech 

efficiency levels DOE has identified represent products with the most efficient productsdesign 

options available on the market, or previously offered for sale, in the given equipment class. No 

products at higher efficiencies are available or have been in the past, and DOE is not aware of 

any working prototype designs that would allow manufacturers to achieve higher efficiencies. 

Table III-2, Table III-3, Table III-4, and Table III-5Table III-5 list the max-tech levels for panels, 

display doors, non-display doors, display doors, and refrigeration systems, respectively. (See 

section IV.A.3 for a description of the equipment classes.)

For structural cooler and freezer panels, the max-tech level is represented by a single 

value for U-factor. For all other TSLs (and for all floor panel levels including the max-tech 

level), the level is represented by a polynomial equation expressing the U-factor in terms of 

certain panel dimensions, but the max tech level does not result in a polynomial equation because 
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the U-factor does not vary with the size of the panel. (See section V.A.2 for a list of equations for 

all TSLs.) At max-tech, panels are designed without structural members, making the panel 

uniformly comprised of hybrid insulation. See section IV.C.5 and chapter 5 of the TSD for the 

list of technologies included in max-tech equipment. 

Table III-2 Max-Tech Levels for Panels

XII. Eq

uipment 

CategoryCl

ass

Temperat

ure

Class Equations for Maximum U-Factor

(Btu/h-ft2-°F))*

Structural

Panel, 

Medium 

Temperature

Medium SP.M 0.0113011

LowStructura

l Panel, Low 

Temperature

SP

.L

0.0113011

Floor Panel, Low Temperature

Low

021.0 041.0

2

fp core

fp edge ×+ 















×− A

A

FP

.L 0209.0 0414.0

2

 nf core

edge nf ×+ 















×− A

A

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

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

Table III-3 Max-Tech Levels for Display Doors

XIII. Equipment 

CategoryClass

Temperatur

e

Class Equations for Maximum Energy 

Consumption (kWh/day))*

Display Door, Medium Temperature

Medium

0080.0 +× 0 Add

DD.

M

0095.0 +× .0 4 Add

LowDisplay Door, Low 

Temperature

DD.L

+× 32.011.0 Add

136.0 Add +× 402.0

Add represents the surface area of the display door.

*Add represents the surface area of the display door.

Table III-4 Max-Tech Levels for Non-Display Doors

XIV. Equipment 

CategoryClass

Temperatu

re

Class Equations for Maximum Energy Consumption 

(kWh/day))*

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Comment [A4]: Edits made per OIRA.

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Passage Door, Medium Temperature

Medium

00093.0 And +× 0

PD.

M

00124.0 And +× .0

LowPassage Door, Low 

Temperature

+× 9.313.0 And

PD.L

124.0 And +× 12.4

Freight Door, Medium Temperature

Medium

0.00092 +× .0 And

FD.

M

00134.0 And +× .0

LowFreight Door, Low 

Temperature

094.0 +× 2.5 And

FD.L 0955.0 And +× 25.5

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

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

Table III-5 Max-Tech Levels for Refrigeration Systems

XV. Equipment Class

Code Capacity Range 

(Btu/h)

Max Tech level

Equations for Minimum AWEF [((Btu/Wh]))*

Dedicated Condensing, Medium Temperature, Indoor 

System, < 9,000 Btu/h Capacity 53.41063.2 4 +×× − Q

Dedicated Condensing, 

Medium Temperature, Indoor 

SystemsSystem, ≥ 9,000 

Btu/h Capacity

DCMI < 15,000

6.9290

≥ 15,000Dedicated 

Condensing, Medium 

Temperature, Outdoor 

System, < 9,000 Btu/h 

Capacity

7.70 90.31023.9 4 +×× − Q

Dedicated Condensing, Medium Temperature, Outdoor 

SystemsSystem, ≥ 9,000 Btu/h Capacity DCMO12.21 < 15,000 11.67

≥ 15,000Dedicated 

Condensing, Low 

Temperature, Indoor 

System, < 9,000 Btu/h 

Capacity

14.79 93.11093.1 4 +×× − Q

Dedicated Condensing, Low 

Temperature, Indoor 

SystemsSystem, ≥ 9,000 

Btu/h Capacity

DCLI < 7500

3.2767

Dedicated Condensing, Low Temperature, Outdoor System, 

< 9,000 Btu/h Capacity 17.21053.4 4 +×× − Q ≥ 7500 4.12

Dedicated Condensing, Low Temperature, Outdoor 

SystemsSystem, ≥ 9,000 Btu/h Capacity DCLO6.25 < 7500 5.10

≥ 7500 7.90

Multiplex Condensing, Medium Temperature MCM10.82 N/A 12.96

Multiplex Condensing, Low Temperature MCL5.91 N/A 6.65

*Q represents the system gross capacity as calculated in AHRI 1250.

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A.F. Energy Savings

1. Determination of Savings 

DOE uses the National Impact Analysis (NIA) model to estimate the national For each 

TSL, DOE projected energy savings over the 2015–2045from the products that are the subject of 

this rulemaking purchased in the 30-year period. The model forecasts energy use over that 

begins in the analysis period for each representative equipment class at efficiency levels set by 

each of the six TSLs developed by DOE (see section V.A). DOE then compares the energy use at 

each TSL to the base case energy use, which assumes no new or amended energy efficiency 

standard. For calculating the base case energy consumption, DOE assumed that, in the absence 

of a new mandatory standard, all new shipments of refrigeration systems, panels, and doors 

would complyyear of compliance with the prescriptive new standards in EPCA. (42 U.S.C. 

6313(f)(1)(3))(2017–2046). The savings are measured over the entire lifetime of products 

purchased in the 30-year period.15 DOE quantified the energy savings attributable to each TSL as 

the difference in energy consumption between each standards case and the base case. The base 

case represents a projection of energy consumption in the absence of amended mandatory 

efficiency standards and considers market forces and policies that affect demand for more 

efficient products. 

DOE used its national impact analysis (NIA) spreadsheet model to estimate energy 

savings from amended standards for the products that are the subject of this rulemaking. The 

 

15 In the past DOE presented energy savings results for only the 30-year period that begins in the year of 

compliance. In the calculation of economic impacts, however, DOE considered operating cost savings measured 

over the entire lifetime of products purchased in the 30-year period. DOE has chosen to modify its presentation of 

national energy savings to be consistent with the approach used for its national economic analysis.

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NIA spreadsheet model is (described in section IV.GIV.G of this notice and in chapter 10 of the 

TSD.

The NIA spreadsheet model) calculates equipment energy savings in kilowatt hours 

(kWh) of site energy. Site energy is the electrical energy consumed at building sites by WICF 

refrigeration systems and the electricity, which is the energy directly consumed by certain 

envelope components. When presenting energy savings at a products at the locations where they 

are used. For electricity, DOE reports national level, however, DOE converts the site energy to 

quadrillion BTUs (quads) of source energy by applying the ‘site-to source’ energy conversion 

factors derived using a variantenergy savings in terms of the Energy Information Agency (EIA) 

National Energy Modeling System (NEMS) referred to here as NEMS-BT (based on EIA’s 

Annual Energy Outlook (AEO) 2010). Source energy is savings in the energy savingsthat is used 

to generate and transmit the site electricity consumed at the site. . To calculate this quantity, 

DOE derives annual conversion factors from the model used to prepare the Energy Information 

Administration’s (EIA) Annual Energy Outlook (AEO).

DOE has begun to also estimate full-fuel-cycle (FFC) energy savings. 76 FR 51282 (Aug. 

18, 2011), as amended at 77 FR 49701 (August 17, 2012). The FFC metric includes the energy 

consumed in extracting, processing, and transporting primary fuels (i.e., coal, natural gas, 

petroleum fuels), and thus presents a more complete picture of the impacts of energy efficiency 

standards. DOE’s approach is based on calculation of an FFC multiplier for each of the energy 

types used by covered products. For more information on FFC energy savings, see sections 

IV.G.3 and IV.L and appendix 10G of the TSD.

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2. Significance of Savings

DOE may not adopt a standard that would not result in significant additional energy 

savings. While the term “significant” is not defined in the Act, the U.S. Circuit Court of Appeals

for the District of Columbia in Natural Resources Defense Council v. Herrington, 768 F.2d 1355, 

1373 (D.C. Cir. 1985), indicated that Congress intended significant energy savings to be savings 

that were not “genuinely trivial.” The estimated energy savings in the 30-year analysis period for 

the trial standard levels considered in this rulemaking range from 4.18428 to 6.40437 quadrillion 

Btu (quads), an amount DOE considers significant.

B.G. Economic Justification

1. Specific Criteria 

As discussed in section II.A, EPCA provides seven factors to be evaluated in determining 

whether a potential energy conservation standard is economically justified. The following 

sections generally discuss how DOE addresses each of those seven factors in this rulemaking. 

For further details and the results of DOE’s analyses pertaining to economic justification, see 

sections IV and V of today’s notice.

a. Economic Impact on Manufacturers and Consumers

In determining the impacts of a new oran amended standard on manufacturers, DOE first 

determines the quantitative impacts usinguses an annual cash-flow approach. to determine the 

quantitative impacts. This approachstep includes both a short-term assessment (—based on the 

cost and capital requirements associated with new or amended standards during the period 

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between the announcement of when a regulation is issued and when entities must comply with 

the regulation comes into effect) —and a long-term assessment (based on the costs and margin 

impacts over thea 30-year analysis period).. The industry-wide impacts analyzed include industry 

net present value (INPV (), which values the industry on the basis of expected future cash 

flows),; cash flows by year,; changes in revenue and income,; and other measures of impact, as 

appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, 

including impacts on small manufacturers. Third, DOE considers the impact of standards on 

domestic manufacturer employment and manufacturing capacity, as well as the potential for 

standards to result in plant closures and loss of capital investment. Finally, DOE takes into 

account the cumulative impacts of differentvarious DOE regulations and other regulatory 

requirements on manufacturers.

For individual consumers, measures of economic impact include the changes in LCC and 

the PBP associated with new or amended standards. The LCC, which is also separately specified 

as one of the seven factors to be considered in determining the economic justification for a new 

or amended standard, is discussed in the following section. For consumers in the aggregate, DOE 

also calculates the net present value from a national perspective of the economic impacts on 

consumers over the forecast period used in a particular rulemaking. For the results of DOE’s 

analyses related to the economic impact on consumers, see section V.B.1 of this notice and 

chapters 8 and 11 of the TSD. For the results of DOE’s analyses related to the economic impact 

on manufacturers, see section V.B.2 of this notice and chapter 12 of the TSD. 
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b. Life-Cycle Costs

The LCC is the sum of the purchase price of equipment (including the cost of its 

installation) and the operating expense (including energy and maintenance and repair 

expenditures) discounted over the lifetime of the equipment. The LCC savings for the considered 

efficiency levels are calculated relative to a base case that reflects likely trends in the absence of 

new standards. The LCC analysis requires a variety of inputs, such as equipment prices, 

equipment energy consumption, energy prices, maintenance and repair costs, equipment lifetime, 

and consumer discount rates. DOE assumes in its analysis that consumers purchase the 

equipment in the year in which compliance with the new standard is required.

To account for uncertainty and variability in specific inputs, such as equipment lifetime 

and discount rate, DOE uses a distribution of values with probabilities attached to each value. A 

distinct advantage of this approach is that DOE can identify the percentage of consumers 

estimated to receive LCC savings or experience an LCC increase. In addition to identifying 

ranges of impacts, DOE evaluates the LCC impacts of potential standards on identifiable 

subgroups of consumers that may be disproportionately affected by a new national standard. For 

the results of DOE’s analyses related to the life-cycle costs of equipment, see section V.B.1.a of 

this notice and chapter 8 of the TSD.

c. Energy Savings

While significant conservation of energy is a separate statutory requirement for imposing 

an energy conservation standard, EPCA requires DOE, in determining the economic justification 

of a standard, to consider the total projected energy savings that are expected to result directly 

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from the standard. DOE uses the NIA spreadsheet results in its consideration of total projected 

savings. For the results of DOE’s analyses related to the potential energy savings, see section 

V.B.3.a of this notice and chapter 10 of the TSD.

d. Lessening of Utility or Performance of Products

In establishing classes of equipment, and in evaluating design options and the impact of 

potential standard levels, DOE seeks to develop standards that would not lessen the utility or 

performance of the equipment under consideration. None of the TSLs presented in today’s 

NOPR would reduce the utility or performance of the equipment considered in the rulemaking. 

During the screening analysis, DOE eliminated from consideration any technology that would 

adversely impact consumer utility. For the results of DOE’s analyses related to the potential 

impact of new standards on equipment utility and performance, see section IV.B of this notice 

and chapter 4 of the TSD.

e. Impact of Any Lessening of Competition

EPCA directs DOE to consider the impact of any lessening of competition, as determined 

in writing by the Attorney General, that is likely to result from standards.the imposition of a 

standard. It also directs the Attorney General of the United States (Attorney General) to 

determine the impact, if any, of any lessening of competition likely to result from a proposed 

standard and to transmit such determination to the Secretary within 60 days of the publication of 

a proposed rule, together with an analysis of the nature and extent of the impact. DOE will 

transmit a copy of today’s proposed rule to the Attorney General andwith a request that the 

Department of Justice (DOJ) provide its determination on this issue. DOE will address the 

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Attorney General’s determination, if any, in the final rule. For the results of DOE’s analysis 

related to lessening of competition, see section V.B.5 of this notice. in the final rule.

f. Need of the Nation to Conserve Energy

Another factor which DOE considers in determining whether a new or amended standard 

is economically justified is the need for national energy and water conservation. The energy 

savings from new or amended The energy savings from the proposed standards are likely 

to provide improvements to the security and reliability of the nation’s energy system. Reductions 

in the demand for electricity may also may result in reduced costs for maintaining the reliability 

of the nation’s electricity system. DOE conducts a utility impact analysis to estimate how new or 

amended standards may affect the Nation’snation’s needed power generation capacity. The 

utility impact analysis is contained in chapter 14 of the TSD.

Energy savings from the adoption of today’s The proposed standards are also are likely to 

result in environmental benefits in the form of reduced emissions of air pollutants and 

greenhouse gases associated with energy production (i.e.,. DOE reports the emissions impacts

from power plants). For a discussion of the results of the analyses relating to the potential 

environmental benefits of thetoday’s standards, seeand from each TSL it considered, in section 

V.B.6 of this notice. DOE reports the environmental effects from the proposed standards, as well 

as from each TSL it considered for walk-in coolers and freezers, in the environmental assessment 

contained in and chapter 15 of the TSD. DOE also reports estimates of the economic value of 

emissions reductions resulting from the considered TSLs.

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OIRA indicate that we had agreed to cut this 

sentence.

Comment [A6]: Edits made per OIRA.

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g. Other Factors

EPCA allows the Secretary, in determining whether a standard is economically justified, 

to consider any other factors that the Secretary deems to be relevant. For the results of DOE’s 

analyses related to other factors, see section V.B.7 of this notice.

2. Rebuttable Presumption 

 As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA provides for a rebuttable presumption 

that an energy conservation standard is economically justified if the additional cost to the 

consumer of equipment that meets the standard level is less than three times the value of the 

first-year energy (and, as applicable, water) savings resulting from the standard, as calculated 

under the applicable DOE test procedure. DOE’s LCC and PBP analyses generate values 

thatwhich can be used to calculate the payback period for consumers of products or equipment 

that meet the proposed standards. These analyses include, but are not limited to, the three-year 

payback period contemplated under the rebuttable presumption test. However, DOE routinely 

conducts a full economic analysis that considers the full range of impacts to the consumer, 

manufacturer, nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results 

of this analysis serve as the basis for DOE to evaluate the economic justification for a potential 

standard level (thereby supporting or rebutting the results of any preliminary determination of 

economic justification). The rebuttable presumption payback calculation is discussed in section 

IV.F.12 of this NOPR and chapter 8 of the TSD. 

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XVI.IV. Methodology and Discussion

A. Market and Technology Assessment

When beginning an energy conservation standards rulemaking, DOE develops 

information that provides an overall picture of the market for the products concerned, including 

the purpose of the products, the industry structure, and market characteristics. This activity 

includes both quantitative and qualitative assessments based primarily on publicly-available 

information (e.g., manufacturer specification sheets and industry publications) and data 

submitted by manufacturers, trade associations, and other stakeholders. The subjects addressed in 

the market and technology assessment for this rulemaking include: (1) quantities and types of 

products sold and offered for sale; (2) retail market trends; (3) products covered by the 

rulemaking; (4) equipment classes; (5) manufacturers; (6) regulatory requirements and nonregulatory programs (such as rebate programs and tax credits); and (7) technologies that could 

improve the energy efficiency of the products under examination. DOE researched 

manufacturers of panels, display doors, non-display doors, and refrigeration equipment. DOE 

also identified and characterized small business manufacturers of these components. See chapter 

3 of the TSD for further discussion of the market and technology assessment.

In the preliminary TSD, DOE presented market performance data. Typically, DOE’s 

analysis of market data uses catalog and performance data to determine the number of products 

on the market at varying efficiency levels. However, WICF systems and equipment have not 

previously been rated for efficiency by manufacturers, nor has an efficiency metric been 

established for this equipment. Based on the available data, DOE presented a sample of 

equipment at various sizes in the preliminary TSD and estimated the energy consumption of the 

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equipment using the preliminary engineering spreadsheet. For refrigeration equipment in 

particular, DOE found that, as expected, the relationship between capacity and energy 

consumption was roughly linear.

In a comment on the market performance data DOE presented, Manitowoc expressed 

concern that DOE’s use of linear trends to establish the relationship between energy 

consumption and net capacity will lead to an overestimation of the potential benefits of 

refrigeration system standards. (Manitowoc, No. 0056.1 at p. 2) 

DOE presented the market performance data to illustrate its understanding of the market. 

In response to Manitowoc’s concern, DOE notes that the benefits of the rule are not derived from 

the estimates of market performance data but are determined from the LCC analysis and NIA. 

DOE seeks market performance data to help inform DOE’s analysis. 

1. Definitions Related to Walk-In Coolers and Freezers

DOE proposes to amend the definition of display door and to adopt definitions for 

passage and freight door in order to clarify the boundaries separating these productequipment

classes. The display door definition was modified to permit transparent doors used for the 

passage of people to be categorized as display doors rather than as non-display passage doors. 

DOE is proposing to define transparent passage doors as a type of display door because 

transparent passage doors are generally constructed in the same manner and with the same

materials as transparent reach-in doors. DOE proposes to include definitions for non-display 

passage and freight doors in order to clarify the distinction between the two types of doors. NonFormatted: Indent: Left: 0", Don't adjust

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display passage doors are typically smaller than freight doors and are designed for passage of 

people and small machines, whereas non-display freight doors are larger than passage doors and 

designed for the passage of large machines like forklifts. 

a. Display Doors

As described in section III.B of this notice, DOE established a definition for display door

in the test procedure. 76 FR 33631 (June 9, 2011). DOE is now proposing to amend this 

definition to include all doors that are comprised of 5075 percent or more glass or other 

transparent material. This amendment is intended to classify passage doors that are mostly 

comprised of glass as display doors because the utility and construction of glass passage doors 

more closely resembles that of a display door. DOE proposes to define a display door as one that 

“(1) is designed for product movement, display, or both, rather than the passage of persons; or 

(2) has 5075 percent or more of its surface area comprised of glass or another transparent 

material.” DOE requests comment on this proposed definition. 

 

b. Passage Doors

DOE proposes a definition of passage doors to differentiate passage doors from freight 

doors. Passage doors are mostly intended for the passage of people and small machines like hand 

carts. DOE proposes to define this term to mean “a door that is used as a means of access for 

people and is less than 3 feet 9 inches wide and 7 feet tall.” DOE based these proposed 

dimensions on requirements for automatic door closers prescribed in EPCA. (42 U.S.C 

6313(f)(1)(A)) DOE requests comment on this proposed definition. 

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c. Freight Doors 

 DOE is proposing to separate non-display doors into two equipment classes, passage 

doors and freight doors. DOE proposes to define freight doors in order to clarify the distinction 

between these two equipment classes and remove any ambiguity about which energy standards 

apply to a given door. The two types of doors are constructed differently—for example, freight 

doors tend to have more structural support because they are bulkier— — and thereforewarrant

different standards are warranted for each type. DOE is proposing a definition of freight doors 

that would account for the fact that these doors are typically larger than passage doors and are 

used to allow large machines, like forklifts, into walk-ins. Specifically, DOE proposes to define a 

freight door as oneto mean “a door that is not a display door and is equal to or larger than 34 feet 

9 inches wide and 78 feet tall, which corresponds to the typical .” DOE based these proposed 

dimensions on the standard size of commercially-availablea walk-in panel, which is 4 feet wide 

by 8 feet tall. In DOE’s estimation doors that can easily permitused for the entry and exitpassage

of vehicles such as forklifts. DOE people small machines would be less than the standard size of 

a walk-in panel and therefore all other doors would be freight doors. DOE requests comment on 

its proposed definition. 

 

d. Passage Doors

DOE proposes a definition of passage doors to differentiate passage doors from freight 

doors and display doors. Passage doors are mostly intended for the passage of people and small 

machines like hand carts and not for product display. DOE proposes to define this term to mean

“a door that is not a freight or display door.” DOE requests comment on this proposed definition. 

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2. Equipment Included in this Rulemaking

a. Panels and Doors

As mentioned in section III.B.1, DOE identified three types of panels used in the walk-in 

industry: display panels, floor panels, and non-floor panels. Based on its research, DOE 

determined that display panels, typically found in beer caves (walk-ins used for the display and 

storage of beer or other alcoholic beverages often found in a supermarket) make up a small 

percentage of all panels currently present in the market. Therefore, because of the extremely 

limited energy savings potential currently projected to result from amending the requirements 

that these panels must meet, DOE is not proposing standards for walk-in display panels in this 

NOPR. Display panels, however, must still follow all applicable design standards already 

prescribed by EPCA, as discussed in section II.B.1 of this notice. 

DOE is also not proposing to require the installation of walk-in cooler floor panels. DOE 

did not consider including walk-in cooler floor panels in its analysis because of their complex 

nature. Through manufacturer interviews and market research, DOE determined that, unlike 

walk-in freezers, the majority of walk-in coolers are made with concrete floors and do not use

insulated floor panels. The entity that installs the cooler floor is considered the floor’s 

manufacturer and is responsible for testing and complying with a walk-in cooler floor standard. 

If DOE were to require that all walk-in coolers to be equipped with floor panels, the onus of 

complying with this requirement would likely fall on entities that do not specialize in 

constructing walk-in coolers, and the accompanying burden in using these components and 

certifying compliance with the appropriate standards would likely be costly and difficult for that 

entity to fulfill. Therefore, at this time, it is DOE’s view that requiring the use of floor panels --

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along with the accompanying compliance costs -- would present an undue burden to those 

entities that would be responsible for meeting these requirements. DOE proposes instead that 

manufacturers of all other types of panels (i.e., non-floor and freezer floor), who are already 

subject to specific performance requirements and are better situated to meeting any amended 

standards than entities that manufacture walk-in flooring, would be subject to a final

performance standard under today’s proposal.For these reasons, DOE is not proposing to require 

walk-in coolers to have floor panels, nor is DOE proposing energy efficiency standards for 

cooler floor panels. (DOE is, however, proposing energy efficiency standards for walk-in freezer

floor panels and notes that EPCA requires floor insulation of at least R-28 for walk-in freezers. 

(42 U.S.C. 6313(f)(1)(D)).) 

DOE also identified two types of doors in the walk-in market, display doors and nondisplay doors, which are discussed in section III.B.2 of this NOPR. All types of doors will be 

subject to the performance standards proposed in this rulemaking. 

b. Refrigeration System

[DOE defines the refrigeration system of a walk-in as the mechanism (including all 

controls and other components integral to the system’s operations) used to create the refrigerated 

environment in the interior of the walk-in cooler and freezer, consisting of either (1) a packaged 

system where the unit cooler and condensing unit are integrated into a single piece of equipment, 

(2) a split system with separate unit cooler and condensing unit sections, or (3) a unit cooler that 

is connected to a multiplex condensing system. 76 FR at 33631. 

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DOE based its preliminary results used in today’s proposal on an analysis of storage 

coolers and freezers. DOE did not analyze blast freezer walk-ins, which are designed to quickly 

freeze food and then store it at a specified holding temperature. American Panel commented that 

blast freezer performance differs from storage freezer performance due to the large product loads 

experienced with this specialized equipment. (American Panel, No. 0048.1 at p. 4) Heatcraft 

added that blast freezer refrigeration systems’ energy consumption would be higher than that of 

storage freezers and that they require wider fin spacing because of a higher rate of frost 

accumulation. (Heatcraft, No. 0058.1 at p. 1)

DOE agrees with American Panel and Heatcraft that blast freezer refrigeration systems 

have different energy characteristics from storage freezers, but questions whether they would 

necessarily have a lower rated efficiency. DOE is not proposing to include blast freezers in this 

rulemaking analysis because they make up a small percentage of walk-ins currently present in 

the market. DOE requests comment on whether blast freezer refrigeration systems would have 

difficulty complying with DOE’s refrigeration efficiency standards and, if so, to direct DOE to

(and supply it with) any test procedure data supporting this conclusion. DOE proposes to apply 

the same standards to blast freezer refrigeration systems as to storage freezer refrigeration 

systems, unless DOE finds that blast freezer refrigeration systems would have difficulty 

complying with DOE’s standards. Otherwise, DOE will consider excluding blast freezers from 

coverage under this rulemaking, although they would still have to comply with the already

statutorily-prescribed standards in EPCA.

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Regarding the particular refrigerant to be used in the analysis, DOE analyzed 

refrigeration equipment using R404A, a hydrofluorocarbon (HFC) refrigerant blend, in the 

preliminary analysis. Heatcraft supported DOE’s approach to use only HFC refrigerants in the 

analysis, but also suggested that DOE consider lower global warming potential (GWP) 

refrigerants—such as R134a, R407A, or R407C—in the analyses as well because of shifts in the 

marketplace towards these products, even though these refrigerants may have lower efficiencies. 

(Heatcraft, No. 0069.1 at p. 3) 

In response to Heatcraft’s comment, DOE used R404A in its analysis for this NOPR 

because it is widely used currently in the walk-in industry. DOEDOE appreciates Heatcraft’s 

suggestion to analyze alternative refrigerants, especially those with a lower GWPs given the 

interest by many manufacturers to use these alternatives, and requests comment on the extent of 

the use or likely phase-in of lower GWP refrigerants and asks manufacturers to submit data 

related to the ability of the equipment (either existing or redesigned) using these refrigerants to 

meet the proposed standard, as well as the cost of such equipment. 

3. Equipment Classes

a. Panels and Doors

In the preliminary analysis, DOE proposed to divide the envelope into two separate 

equipment classes: display and non-display walk-ins (that is, walk-ins with and without glass). 

Display walk-ins are walk-ins that have doors for display purposes, are typically made with 

glass, and are inherently less efficient than walk-ins without glass because glass is not as 

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insulative as the insulation material used in non-display walk-ins (typically polyurethane or 

polystyrene). 

 Interested parties commented on the need to separate display and non-display walk-ins

into two different equipment classes. Nor-Lake and AHRI agreed with the equipment classes 

proposed by DOE, and AHRI commented that the equipment classes represent the most common 

walk-in configurations. (Nor-Lake, No. 0049.1 at p. 1; AHRI, No. 0055.1 at p. 2) Manitowoc 

stated that classification of envelopes into storage and display types is appropriate as it may 

allow for different performance levels for certain components. (Manitowoc, No. 0056.1 at p. 2) 

However, CrownTonka contended that it was unnecessary to have two equipment classes for 

display and non-display walk-ins and that separate classes for coolers and freezers are adequate. 

(CrownTonka, No. 0057.1 at p. 1) ASAP and SCE opined that one equipment class is sufficient 

and that the difference between non-display and display doors could be accounted for through a 

weighted average of the opaque and glass surface areas. (ASAP, Public Meeting Transcript, No. 

0045 at p. 70; SCE, Public Meeting Transcript, No. 0045 at p. 79) However, NEAA, NPCC and 

Manitowoc countered that there should not be a single metric for both display and non-display 

doors because it would not account for the unique utility offered by display walk-ins (i.e., 

permitting the display of stored items). (NEAA and NPCC, Public Meeting Transcript, No. 0045 

at p. 76; Manitowoc, Public Meeting Transcript, No. 0045 at p. 78) NEAA and NPCC stated that, 

if DOE were to separate display and non-display walk-ins into two different classes, DOE should 

carefully define the boundary between the two classes. (NEAA and NPCC, Public Meeting 

Transcript, No. 0045 at p. 77) NEAA and NPCC also suggested that, as an alternative to having 

one equipment class for display and non-display walk-ins with a single performance metric, 
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DOE should move to component level-based classes with separate performance metrics. (NEAA 

and NPCC, Public Meeting Transcript, No. 0045 at p. 76) 

Interested parties also submitted comments about the names of the equipment classes. 

NEAA and NPCC stated that if DOE has two separate equipment classes for display and nondisplay walk-ins, DOE should carefully define the boundary between the two classes. (NEAA 

and NPCC, Public Meeting Transcript, No. 0045 at p. 77) Kysor stated that the class names DOE 

suggested were confusing and offered an alternative -- “coolers with glass doors” instead of 

“display coolers” -- to help clarify the difference between the two separate equipment classes. 

(Kysor, Public Meeting Transcript, No. 0045 at p. 78) 

In light of the component level standards described in section III.A, DOE proposes to 

create separate equipment classes for panels, display doors, and non-display doors. These 

different items comprise the main components of a walk-in envelope. DOE proposes separate 

classes for panels, display doors, and non-display doors because each component type has a 

different utility to the consumer and possesses different energy use characteristics. 

In the preliminary analysis, DOE also considered the possibility of creating separate 

classes for walk-in coolers and walk-in freezers because EPCA specifically divides walk-in 

equipment into coolers (above 32°F) and freezers (at or below 32°F), (42 U.S.C. 6311(20)), and 

prescribes unique design requirements for each. (42 U.S.C. 6313(f)(1)(C)-(D)(3)) DOE has 

continued to apply this approach in its analysis. 
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Panels

DOE has placed panels into two equipment classes: freezer floor panels and non-floor 

panels (also called structural panels). DOE understands that freezer floor panels and structural 

panels serve two different utilities. Freezer floor panels, which are panels used to construct the 

floor of a walk-in, must often support the load of small machines like hand carts and pallet jacks 

on their horizontal faces. Non-floor panels or structural panels, which include panels used to 

construct the ceiling or wall of a walk-in, provide structure for the walk-in. Because of their 

different utilities, the two classes of panels are constructed differently from each other and use

different amounts of framing material, which affects the panels’ energy consumption.

Structural panels are further divided into two more classes based on temperature --— i.e., 

cooler versus freezer panels. Cooler structural panels are rated with their internal faces exposed 

to a temperature of 35°F, as called for in the test procedure final rule. Freezer structural panels 

are used in walk-in freezers and rated with its internal face exposed to a temperature of -10°F, as 

required by the test procedure final rule. 76 FR at 21606; 10 CFR 431.303. EPCA also requires 

walk-in freezer panels to have a higher R-value than walk-in cooler panels. These differences 

result in different amounts of insulating foam between these panel types and affect the panel’s Uvalue. 

Doors

DOE has distinguished between two different door types used in walk-in coolers and 

freezers: display doors and non-display doors. DOE proposed separate classes for display doors 

and non-display doors to retain consistency with the dual approach laid out by EPCA for these 
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walk-in components. (42 U.S.C. 6313(f)(1)(C) and (3)) Non-display doors and display doors also 

serve separate purposes in a walk-in. Display doors contain mainly glass in order to display 

products or objects located inside the walk-in. Non-display doors function as passage and freight 

doors and are mainly used to allow people and products to be moved into and out of the walk-in. 

Because of their different utilities, display and non-display doors are made up of different 

material. Display doors are made of glass or other transparent material, while non-display doors 

are made of highly insulative materials like polyurethane. The different materials found in 

display and non-display doors significantly affect their energy consumption. 

DOE divided display doors into two equipment classes based on temperature differences: 

cooler and freezer display doors. Cooler display doors and freezer display doors are exposed to 

different internal temperature conditions, which affect the total energy consumption of the doors. 

In the test procedure final rule, DOE established an internal rating temperature of 35°F for walkin cooler display doors and -10°F for walk-in freezer display doors. 76 FR at 21606; 10 CFR

31.303Part 431, Subpart R, Appendix A, Section 5.3.

DOE also separated non-display doors into two equipment classes, passage and freight 

doors. Passage doors are typically smaller doors and mostly used as a means of access for people 

and small machines, like hand carts. Freight doors typically are larger doors used to allow access 

for larger machines, like forklifts, into walk-ins. The different shape and size of passage and 

freight doors affects the energy consumption of the doors. Both passage and freight doors are 

also separated into cooler and freezer classes because, as explained for display doors, cooler and 
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freezer doors are rated at different temperature conditions. A different rating temperature impacts 

the door’s energy consumption.

In the preliminary analysis, DOE did not consider outdoor envelopes as a separate 

equipment class. Walk-ins located outdoors have very similar features to walk-ins located 

indoors, and DOE could not identify any additional design options that improved the energy 

consumption only of outdoor walk-ins. The Joint Utilities, NEEA and NPCC, CrownTonka, NorLake, and Hill Phoenix stated that DOE should differentiate equipment classes by their external 

environment. (Joint Utilities, No. 0061.1 at p. 5; NEEA and NPCC, No. 0059.1 at p. 6; 

CrownTonka, Public Meeting Transcript, No. 0045 at p. 81; Nor-Lake, No. 0049.1 at p.2; Hill 

Phoenix, No. 0066.1 at p.2) The Joint Utilities requested that DOE evaluate cost-effective 

insulation levels for outdoor walk-ins, and stated that there would be a loss in energy savings if 

DOE did not consider region-specific insulation levels. (Joint Utilities, Public Meeting 

Transcript, No. 0045 at pp. 80 and 82) Nor-Lake contested DOE’s claim that walk-ins designed 

as outdoor units include no additional features that impact energy consumption, stating that the 

ambient temperature and product load will change the energy consumption for both the indoor 

and outdoor units. (Nor-Lake, No. 0049.1 at p.2) Hill Phoenix recommended a separate 

equipment class for outdoor walk-ins because outdoor walk-ins must have thicker panels to 

withstand environmental conditions. (Hill Phoenix, No. 0066.1 at p. 2) American Panel observed 

that a walk-in located outdoors has an added benefit in that no building space was constructed to 

house the walk-in, which is a significant energy savings not considered in the preliminary 

analysis. (American Panel, No. 0048.1 at p.3)
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Some commenters described how DOE could include equipment classes that capture the 

external conditions. SCE suggested that DOE set a series of different conditions by the location 

of the wall such as an outdoor, indoor, or demising wall (i.e., a dividing wall to separate spaces) 

between a cooler and a freezer space. (SCE, Public Meeting Transcript, No. 0045 at pp. 80 and 

82-–83) NEEA and NPCC recommended changing the equipment classes to indoor cooler, 

indoor freezer, outdoor cooler, and outdoor freezer. (NEEA and NPCC, No. 0059.1 at p. 6) 

Other interested parties agreed with DOE’s assertion that it was unnecessary to consider 

outdoor walk-ins as a separate productequipment class. Kysor explained that the envelope would 

be designed for whatever ambient conditions it may be subjected to, and that adding additional 

performance requirements would be unnecessary. (Kysor, Public Meeting Transcript, No. 0045 

at p. 80) Manitowoc stated that there should not be any classification based on external 

environments as there are times when the envelope is exposed to both internal and external 

conditions. (Manitowoc, Public Meeting Transcript, No. 0045 at p. 82) 

DOE is not proposing to include any panel or door equipment class that accounts for the 

different external environmental conditions that a walk-in could experience in real world 

applications. DOE does not find outdoor and indoor walk-in envelope components to have 

distinct utilities. Components for outdoor walk-ins and indoor walk-ins are generally 

constructed with the same design and materials and serve the same purpose. In response to NorLake’s comment about DOE’s assumption about additional features, DOE clarifies that while the 

difference in outdoor temperatures affects the real world energy consumption of the walk-in

envelope, DOE was referring to design features, likesuch as different types of insulation, which
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differ from the design options found on indoor walk-ins and improve the energy efficiency of the 

outdoor walk-in. As to Hill Phoenix’s comment that a panel facing external conditions requires 

more insulation, DOE notes that panels with thicker insulation already surpass the baseline panel 

specifications, which would make it easier for these types of panels to meet the standards in 

today’s proposal.

 

Hill Phoenix also recommended that DOE divide envelopes into factory assembled stepin style walk-ins and larger construction-based walk-ins. (Hill Phoenix, No. 0066.1 at p. 1) 

Because it is not proposing standards for walk-in envelopes, but rather for the panels and doors 

that are components of the envelopes, DOE has not adopted Hill Phoenix’s recommendation in 

today’s proposed standards.proposal. DOE has, however, separated into different equipment 

classes the components typically found in factory-assembled walk-ins, such as passage doors and 

floor panels, and those components found in large construction-based walk-ins, such as freight 

doors. DOE believes this approach will achieve the objective of the Hill Phoenix 

recommendation, namely that the proposed standards reflect the different energy use 

characteristics of factory-assembled and construction-based walk-ins. 

Table IV-1 lists the equipment classes DOE proposes to create in this NOPR. In the table 

below table, medium temperature refers to cooler equipment and low temperature refers to 

freezer equipment. The column entitled “Class” lists the codes that will be used to abbreviate 

each equipment class, and will be used throughout the NOPR. 
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Table IV-1 Equipment Classes for Panels and Doors

XVII. Product XVIII. Temperature XIX. Class

XX. Structural 

Panel XXI. Medium XXII. SP.M

Low SP.L

Floor Panel Low FP.L

Display Door Medium DD.M

Low DD.L

Passage Door Medium PD.M

Low PD.L

Freight Door Medium FD.M

Low FD.L

a.b. Refrigeration Systems

In the preliminary analysis, DOE considered dividing walk-in refrigeration systems into 

six equipment classes based on key physical characteristics that affect equipment efficiency: (1) 

the type of condensing unit (i.e., whether the system has a dedicated condensing unit or is 

connected to a multiplex system), (2) the operating temperature, and (3) the location of the walkin (i.e., indoors or outdoors). In this NOPR, DOE also proposes to differentiate refrigeration 

system classes based on capacity. DOE discusses the four proposed class differentiations below.

Type of Condensing Unit

Due to the significant impact of the condensing unit on the overall energy consumption of 

the walk-in (as much as 90 percent), the preliminary analysis differentiated between two 

different condensing unit types: dedicated condensing systems and multiplex condensing 

systems. In a dedicated condensing system, only one condensing unit (consisting of one or more 

compressors and condensers) serves a single walk-in. A multiplex condensing system consists of 

a rack of compressors usually located in a mechanical room, a large condenser or condensers 

usually located on the roof, and several unit coolers or evaporators belonging to various types of 

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refrigeration equipment, including walk-ins. The only part of a multiplex condensing system that 

would be covered under the proposed standard would be a unit cooler in a walk-in -- a “unit 

cooler connected to a multiplex condensing system.” The compressor and condenser of a 

multiplex system would not be covered under the walk-in standard because they serve equipment 

other than walk-ins. Furthermore, DOE would be unable to attribute the portion of energy use 

related to only the walk-in, at the point of manufacture of the compressor and condenser of the 

multiplex system. 

DOE received several comments about the classification of condensing types. AHRI, 

Nor-Lake and Manitowoc agreed with DOE’s equipment classes proposed in the preliminary 

analysis, while the Joint Utilities suggested redesignating the multiplex and dedicated equipment 

classes as remote and self-contained, respectively. (AHRI, Public Meeting Transcript, No. 0045 

at p. 74, Nor-Lake, No. 0049.1 at p. 1, Manitowoc, No. 0056 at p. 2, Manitowoc, Public Meeting 

Transcript, No. 0045 at p. 73, Joint Utilities, Public Meeting Transcript, No. 0045 at p. 71) The 

Joint Utilities suggested regulating condensing units in a manner similar to that used by DOE for

commercial refrigeration equipment, which, in their view, would result in coverage of most of 

the condensing units serving the walk-in industry. (Joint Utilities, No. 0061.1 at p. 11, 12) The 

Joint Advocates suggested that DOE conduct a separate rulemaking for condensing units. (Joint 

Advocates, No. 0070.1 at p. 3) They added that DOE should reduce the number of refrigeration 

types to self-contained and unit coolers only, while the Joint Utilities recommended against 

including remote condensing units as part of this rulemaking. (Joint Advocates, No. 0070.1 at p. 

3, Joint Utilities, No. 0045 at p. 22) 
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DOE believes the refrigeration systems covered by the two classes of equipment, 

dedicated condensing and multiplex condensing, accurately represent the range of refrigeration 

equipment used in walk-in coolers and freezers. Although the proposed classes differ from the

classes designated in the commercial refrigeration equipment rulemaking, there are key 

differences between commercial refrigeration equipment refrigeration systems and walk-in 

refrigeration systems. The Joint Advocates and Joint Utilities refer to two common types of

refrigeration systems commonly used with commercial refrigeration equipment refrigeration 

units: “self-contained” (meaning the entire refrigeration system is built into the case) and

“remote condensing” (meaning the unit cooler is built into the case, but the whole case is 

connected to a central system of compressors and condensers, called a “rack” or “multiplex 

condensing system”, connected to most or all of the refrigeration units in a building). “Remote 

condensing”, however, can also refer to a configuration in which the unit cooler is connected to a 

dedicated (i.e., only serving that one unit) compressor and condenser that are located somewhere 

away from the unit cooler. This configuration is rare for commercial refrigeration equipment, but 

comprises a large proportion of walk-in refrigeration system applications. 

To avoid confusion over the different configurations for walk-ins and commercial 

refrigeration equipment that can be classified as “remote condensing”, DOE is not proposing to

classify walk-in refrigeration systems as “remote condensing” and “self-contained”. Also, DOE 

does not agree that the compressor and condenser parts should not be covered under the walk-in 

coolers and freezers rulemaking. Instead, DOE is proposing to include dedicated condensing 

units in the rule, even if remotely located, because these units could be viewed as part of the 

walk-in as long as they are connected only to that particular walk-in and not to other refrigeration 

Comment [A9]: Edits made per OIRA.
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equipment. For systems where the walk-in is connected to a multiplex condensing system that 

runs multiple pieces of equipment, the compressor and condenser would not be covered because 

they are not exclusively part of the walk-in.

In consideration of the above, DOE proposes to create two classes of refrigeration 

systems: dedicated condensing and multiplex condensing. DOE believes that dedicated remote 

condensing units represent a substantial opportunity for energy savings in a regulation for walkin components because the configuration of a dedicated remote condensing unit is widespread in 

several market segments, such as restaurants. Manufacturers can optimize the dedicated remote 

condensing unit with the unit cooler to take advantage of certain conditions, such as low ambient 

outdoor temperatures. 

 DOE does not propose to create separate classes for dedicated packaged systems (where 

the unit cooler and condensing unit are integrated into a single piece of equipment) and dedicated 

split systems (with separate unit cooler and condensing unit sections). Packaged systems are 

potentially more efficient than split systems because they do not experience as much energy loss 

in the refrigerant lines. However, because packaged systems comprise a small share of the 

refrigeration market, DOE currently believes that little additional energy savings could be 

achieved by considering them as a separate class. Accordingly, DOE is not proposing to consider

the creation of a separate packaged systems class. 

DOE also notes that its proposed standards for dedicated condensing systems are based 

on an analysis of split systems. DOE requests comment on its proposal not to consider dedicated 
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packaged systems and dedicated split systems as separate classes and whether this proposal 

would unfairly disadvantage any manufacturers.

Operating Temperature

The second physical characteristic that DOE proposes as a basis for dividing refrigeration 

systems into equipment classes is the operating temperature. EPCA divides walk-in equipment 

into coolers (above 32 °F) and freezers (at or below 32 °F) (42 U.S.C. 6311(20)) Using this 

distinction, DOE is proposing to categorize refrigeration systems as low or medium temperature 

systems based on the temperature profiles of their unit coolers. The medium (M) and low (L) 

temperature units are differentiated by their operating temperatures, which are greater than 32 °F 

(for coolers) and less than or equal to 32 °F (for freezers). In response to DOE’s discussion of

these classes in the preliminary analysis, Ingersoll Rand suggested that any walk-in with defrost 

be rated as a freezer regardless of the operating temperature. (Ingersoll Rand, No. 0053.1 at p. 1) 

DOE has not adopted these suggestions because doing so would conflict with the statutory 

distinction created by Congress that relies on operating temperature to distinguish between walkin coolers and freezers. See 42 U.S.C. 6311(2) (treating walk-ins as separate equipment based on 

whether they are coolers or freezers). 

Furthermore, applying the rating conditions for low temperature refrigeration systems is 

unlikely to enable a tester to accurately measure the efficiency of a medium temperature 

refrigeration system. Requiring a refrigeration system with defrost to be rated at the low 

temperature rating conditions even if it is designed to operate closer to the medium temperature 

rating conditions could lead to inaccurate equipment ratings for such equipment. In certain cases, 

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applying temperature ratings in this manner may not permit this type of equipment to be rated at 

low temperature rating conditions if it is not designed to operate at those conditions.

16 

Location of the Walk-in

 The third physical characteristic DOE considered is the location of the condensing unit 

(i.e., indoor or outdoor), which also affects the energy consumption of dedicated condensing 

systems. Indoor refrigeration systems generally operate at fixed ambient temperatures, while 

outdoor refrigeration systems experience varying temperatures through the year. This change in 

temperature affects the performance of the refrigeration system by requiring it to operate more 

during warmer conditions and less during colder ones. Accordingly, the test procedure has one 

ambient rating condition for indoor systems and three ambient rating temperatures for outdoor 

systems. 

In the preliminary analysis, DOE considered creating separate classes for refrigeration 

systems with indoor (I) and outdoor (O) condensing units because of their different energy 

consumption characteristics. Outdoor condensing units can also implement a wide variety of 

design options to run more efficiently at low ambient temperatures. (In contrast, DOE did not 

consider indoor and outdoor envelope components as belonging to separate classes partly 

because of the absence of available options for improving efficiency based on the ambient 

temperature. See section IV.A.3.a for details.) Following the preliminary analysis, DOE did not 

 

16 For example, most medium temperature unit coolers are designed to operate between 15 °F and 45 °F, and would 

not be able to operate at the low temperature rating condition of -10 °F.

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receive any comments regarding the indoor and outdoor condensing unit classes, and therefore 

proposes the same differentiation in this NOPR.

Refrigeration Equipment Size

In the preliminary analysis, DOE did not consider different equipment classes based on 

refrigeration equipment size. Heatcraft suggested adding sub-categories to the proposed 

equipment classes, stating that the size of refrigeration systems varies with envelope size. 

(Heatcraft, No. 0069.1 at p. 1) Manitowoc commented that small sized equipment would struggle 

to meet minimum standards if DOE based the metric on a larger size, largely due to the 

efficiency difference of each system size. (Manitowoc, Public Meeting Transcript, No. 0044 at p. 

118) 

DOE is not proposing to base refrigeration system classes on envelope size because it is 

taking a component-level approach that sets standards for the refrigeration system independent of 

the envelope. In reaching this tentative decision, DOE examined the ability of various sized 

equipment to meet a proposed standard. For the NOPR analysis, DOE analyzed a wider range of 

equipment sizes than it did for the preliminary analysis, as described later in section IV.C.1.b. As 

a result of this expanded analysis, DOE observed that small sized equipment may have difficulty 

meeting an efficiency standard that is based on an analysis of large equipment, as Manitowoc 

noted. DOE found that this result was primarily due to a lack of availability of the more efficient 

compressor types (e.g., scroll compressors) at lower capacities. Additionally, certain design 

options, mainly controls, generally have a fixed cost, but their benefit decreases with lower 

capacities, so they are less cost-effective for lower-capacity equipment. Therefore, DOE 
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proposes one standard levelequipment class for high-capacity equipment and another for lowcapacity equipment within the dedicated condensing category (because the compressor is 

covered only for DC systems). HighDOE has tentatively chosen 9,000 Btu/h as the capacity 

threshold for small- and low-capacity equipment would occupylarge-capacity equipment based 

on the efficiency characteristics of available compressors, among other factors. See chapter 3 for 

details. DOE requests comment on the capacity threshold between the two different 

equipmentcapacity classes; the boundary between high and low capacity is different for mediumand low-temperature units because of varying compressor availability for dedicated condensing 

systems. 

Proposed Classes

Using the proposed combinations of condensing unit types, operating temperatures, 

location, and size, ten equipment classes are possible for walk-in cooler or freezer refrigeration 

systems. DOE believes that these ten classes accurately represent the refrigeration units used in 

the walk-in market today.

Table IV-2 lists the equipment classes for refrigeration equipment that DOE is proposing 

in this NOPR. The column entitled “Class” lists the codes that will be used to abbreviate each 

equipment class, and will be used throughout the NOPR. 
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Table IV-2 Equipment Classes for Refrigeration Equipment

XXIII. Condensi

ng Type

XXIV. Operati

ng Temperature

XXV. Condens

er Location

XXVI. Refrigerati

on Capacity (Btu/h) XXVII. Class

Dedicated

Medium Indoor < 159,000 DC.M.I, < 159,000

≥ 159,000 DC.M.I, ≥ 159,000

Low Outdoor < 159,000 DC.L.I, < 15M.O, < 9,000

≥ 159,000 DC.L.I, < 15M.O, ≥ 9,000

Medium

Low OutdoorIndoor

< 75009,000 DC.M.O, < 7500L.I, < 

9,000

≥ 75009,000 DC.M.O, ≥ 7500L.I, ≥

9,000

Low Outdoor < 75009,000 DC.L.O, < 75009,000

≥ 75009,000 DC.L.O, ≥ 75009,000

Multiplex

Medium - - MC.M

Low - - MC.L

1.4. Technology Assessment

In a technology assessment, DOE identifies technologies and designs that could be used 

to improve the energy efficiency or performance of covered equipment. For the preliminary 

analysis, DOE conducted a technology assessment to identify all technologies and designs that 

could be used to improve the energy efficiency of walk-ins or walk-in components. DOE 

described these technologies in chapter 3 of the preliminary TSD. 

DOE received several comments in response to its preliminary list of technology options. 

NEEA and NPCC recommended that DOE include modulating condenser fan controls in its 

analysis because there are significant potential energy savings from this technology. (NEEA and 

NPCC, No. 0059.1 at p. 8) Emerson agreed and noted that higher-efficiency compressors often 

require modulating fan controls to realize the full benefit of the higher-efficiency compressors. 

(Emerson, Public Meeting Transcript, No. 0045 at p. 90) The Joint Utilities pointed out that DOE 

did not include variable speed controls for condenser fans. (Joint Utilities, No. 0061.1 at p.10) In 

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addition, NEEA and NPCC recommended that DOE include liquid suction heat exchangers in its 

analysis because there are significant potential energy savings from this technology. (NEEA and 

NPCC, No. 0059.1 at p. 8)

In response to the recommendation that DOE consider condenser fan controls, DOE has 

added condenser fan controls as a design option because it determined through further analysis 

that they could be an effective means of saving energy. As to NEEA and NPCC’s 

recommendation that DOE include liquid suction heat exchangers, DOE also considered liquid 

suction heat exchangers in the technology assessment because this technology could potentially 

be used to save energy. However, DOE screened this option from further consideration because 

further examination indicated that it would be unlikely to yield significant energy savings under 

the rating conditions used in setting standards for walk-in equipment. See chapters 3, 4, and 5 of 

the TSD for more details on the technologies considered in the analysis.

B. Screening Analysis

DOE uses four screening criteria to determine which design options are suitable for 

further consideration in a standards rulemaking. Namely, design options will be removed from 

consideration if they (1) are not technologically feasible; (2) are not practicable to manufacture, 

install, or service; (3) have adverse impacts on product utility or product availability; or (4) have 

adverse impacts on health or safety. 10 CFR 430, subpart C, appendix A, sections (4)(a)(4) and 

(5)(b).) 

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1. Technologies That Do Not Affect Rated Performance

In the preliminary analysis TSD, DOE proposed to screen out the following technologies 

because they do not improve energy efficiency: non-penetrative internal racks and shelving, air 

and water infiltration sensors, humidity sensors, and heat flux sensors. 

For the reasons stated in the TPtest procedure final rule, DOE’s test procedure establishes 

metrics to test the energy consumption or energy use of walk-in components and does not 

include heat load caused by infiltration. See 76 FR at 21594-21595. As a result, DOE included 

additional infiltration-related technologies in the following list of technologies that do not 

improve rated performance: 

• Internalinternal racks and shelving that are non-penetrative; 

• Airair and water infiltration sensors; 

• Extrudedextruded polystyrene insulation; 

• Humidityhumidity sensors; 

• Heatheat flux sensors; 

• Doordoor gasketing improvements and panel interface systems; 

• Automaticautomatic door opening and closing systems; 

• Airair curtains; 

• Stripstrip curtains; 

• Vestibulevestibule entryways; and

• Insulationinsulation with improved moisture resistance. 

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In the preliminary analysis, DOE listed hot gas defrost as a technology that does not 

improve rated performance of refrigeration equipment. In response, the Joint Utilities stated that 

DOE should include hot gas defrost. (Joint Utilities, Public Meeting Transcript, No. 0045 at p. 

25; Joint Utilities, No. 0061.1 at pp. 3, 7, and 10). DOE has included hot gas defrost as a design 

option for multiplex condensing systems, but not for dedicated condensing systems due to its 

lack of effectiveness in improving efficiency. Specifically, for multiplex condensing systems, the 

hot gas defrost system utilizes hot gas generated by the compressor rack. Because at least one of 

the compressors in the rack is likely to be running (because the rack also has to operate with 

other refrigeration units) no new energy is consumed to generate the hot gas. In contrast, for 

dedicated systems, the condensing unit typically turns off during an electric defrost cycle. 

Running the compressor to generate hot gas at a time when it would normally be off results in 

energy use that outweighs the energy saved by using hot gas defrost instead of electric defrost.

See chapters 3 and 5 of the TSD for details.

Also as part of the preliminary analysis, DOE analyzed the envelope and the refrigeration 

system separately and did not consider design options that depend on the interaction between the 

envelope and the refrigeration system. SCE suggested that DOE consider control options that 

depend on the interaction between envelope components and the refrigeration system, such as a 

control that turns off the evaporator fan when the door is opened. SCE suggested that DOE 

evaluate such technologies by establishing a typical, nominal savings value for use in energy 

consumption equations. (SCE, Public Meeting Transcript, No. 0045 at p. 25) Similarly, NEEA 

and NPCC stated that such technological controls have not been included in the design options. 

(NEEA and NPCC, No. 0059.1 at p. 7)
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A nominal savings value, as suggested by SCE, would be highly dependent on many 

assumptions about the application of the walk-in and the pairing of the refrigeration system with 

the walk-in. As a result, DOE does not believe that it would be reasonable to apply this shared 

value to all refrigeration system or door manufacturers because of the wide variety of equipment 

produced by these entities for walk-in applications. Moreover, DOE’s proposed component level 

approach eliminates the need to consider design options whose efficacy depends on the 

interaction between different components.

DOE also did not consider design options whose benefits would not be captured by the 

test procedure, such as economizer cooling. Economizer cooling consists of directly venting 

outside air into the interior of the walk-in when the outside air is as cold as or colder than the 

interior of the walk-in. This technique relieves the load on the refrigeration system when a pulldown load (i.e., a load due to items brought into the walk-in at a higher temperature than the 

operating temperature and must then be cooled to the operating temperature) is necessary. 

However, the test procedure does not include a method for accounting for economizer cooling, as 

it does not specify conditions for air that would be vented into the walk-in, nor does it provide a 

method for measuring the energy use of the economizer. Therefore, any benefits from including 

an economizer on a WICF would not be captured by the test procedure. Comment [A12]: Revision made per OIRA.

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2. Screened-Out Technologies

a. Panels and Doors

In the preliminary analysis, DOE screened out the following technologies for envelopes: 

revolving doors, energy storage systems, fiber optic natural light, non-electric anti-sweat 

systems, and automatic insulation deployment systems. DOE did not receive comments 

regarding any of the screened-out technologies, and will continue to exclude them from this 

rulemaking. DOE has also screened out additional technologies as part of its proposal to regulate 

the components of the envelope separately (i.e., display doors, non-display doors, and panels.) 

See chapter 4 of the TSD for more details on the screened-out technologies.

b. Refrigeration

In the preliminary analysis, DOE screened out the following technologies for 

refrigeration systems: higher-efficiency evaporator fan motors, improved evaporator coil, threephase motors, and economizer cooling. In response to DOE’s request for comment on the 

screening analysis, American Panel, AHRI and CrownTonka agreed with this approach to screen 

out these technologies. (American Panel, Public Meeting Transcript, No. 0045 at p. 98; AHRI. 

Public Meeting Transcript, No. 0045 at p. 99; CrownTonka, No. 0057.1 at p. 1) Emerson, 

however, disagreed with DOE’s decision to screen out economizer cooling because there are 

potential energy savings under certain circumstances. (Emerson, Public Meeting Transcript, No. 

0045 at p. 100) Also, Heatcraft disagreed with the exclusion of phase motor technology because 

three-phase motors are the dominant motor type in the larger walk-in envelopes that are a part of 

this rulemaking. (Heatcraft No. 0069.1 at p. 2) Manitowoc remarked that there are other ways to 

achieve an effective economizer cooling cycle and encouraged DOE to investigate other options 

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to improve cycle efficiency, but did not provide any specific recommendations. (Manitowoc, 

Public Meeting Transcript, No. 0045 at p. 92) 

DOE continues to screen out economizer cooling and three-phase motor technologythreephase motor technology. . Economizer cooling consists of directly venting outside air into the 

interior of the walk-in when the outside air is as cold as or colder than the interior of the walk-in. 

This technique relieves the load on the refrigeration system when a pull-down load (i.e., a load 

due to items brought into the walk-in at a higher temperature than the operating temperature and 

must then be cooled to the operating temperature) is necessary. Economizer cooling is limited in 

its effectiveness, however, because it has limited application and is not effective in areas of the 

country where the temperature does not drop below the walk-in envelope’s storage temperature.

These are primarily warm-climate regions such as areas of the southeastern United States that do 

not typically experience temperatures below 35 degrees. DOE continues to screen out this option 

based on utility to the consumer, one of the four screening criteria.

The use of three-phase motor technology generally provides higher energy savings as 

compared to single-phase motors. Three-phase power is commonly used to power large motors 

and heavy electrical loads; however, it is not available for all businesses, particularly small 

business consumers of walk-ins. DOE did not consider three-phase motor technology as a design 

option based on utility to the consumer, one of the four screening criteria. In addition, use of 

three-phase motor technology may also be impracticable to install and service given the lack of 

three-phase power for some businesses. DOE did find that, as Heatcraft noted, very large 

refrigeration systems requiretypically use three-phase power; therefore, DOE assumed, and notes

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that manufacturers may use three-phase motors would be used into improve the efficiency 

ratings of their equipment of this size. as the benefit would likely be captured by the test 

procedure. However, DOE continued to screen three-phase motor technology from its analysis 

for the reasons discussed above. 

DOE also did not consider economizer cooling in its analysis. Although there are 

potential energy savings under certain circumstances, as Emerson mentioned, these energy 

savings are not captured by the test procedure, as discussed in section IV.B.1.

Regarding Manitowoc’s remark about considering other options to improve cycle 

efficiency, DOE did not identify any options to improve cycle efficiency beyond what was 

already considered. DOE requests specific recommendations on how to improve cycle 

efficiency. DOE also notes that even though certain options were screened out of the analysis, 

manufacturers may still choose to adopt these options to meet the proposed standard.

3. Screened-In Technologies

Based on DOE’s decision to regulate walk-ins on a component level, DOE will consider 

separate technologies for each covered walk-in component (i.e. panels, display doors, nondisplay doors, and refrigeration systems). The remaining technologies that were not “screenedout” are called the “screened-in” technologies and will be used to create design options for 

improving the efficiency of the walk-in components. The “screened-in” technologies for each 

covered component include: 

• Panels

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o Insulation thickness

o Insulation material

o Framing material

• Display doors

o Electronic lighting ballasts and highHigh-efficiency lighting

o Occupancy sensors

o Improved glass system insulation performance

o Anti-sweat heater controls

• Non-display doors

o Insulation thickness

o Insulation material

o Framing material

o Improved window glass systems

o Anti-sweat heat controls

• Refrigeration Systems

o Higher efficiency compressors

o Improved condenser coil

o Higher efficiency condenser fan motors

o Improved condenser fan blades

o Condenser fan control

o Ambient sub-cooling

o Improved evaporator fan blades

o Evaporator fan control 
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o Defrost controls

o Hot gas defrost

o Head pressure control

C. Engineering Analysis

The engineering analysis determines the manufacturing costs of achieving increased 

efficiency or decreased energy consumption. DOE has identified the following three 

methodologies to generate the manufacturing costs needed for the engineering analysis: (1) the

design-option approach, which provides the incremental costs of adding design options to a 

baseline model to improve its efficiency; (2) the efficiency-level approach, which provides the 

relative costs of achieving increases in energy efficiency levels without regard to the particular 

design options used to achieve such increases; and (3) the cost-assessment (or reverse 

engineering) approach, which provides “bottom-up” manufacturing cost assessments for 

achieving various levels of increased efficiency based on detailed data as to costs for parts and 

material, labor, shipping/packaging, and investment for models that operate at particular 

efficiency levels.

DOE conducted the engineering analyses for this rulemaking using a combination of the 

design-option and cost-assessment approaches in analyzing the U-factor standards for panels, 

maximum energy use for non-display doors and display doors, and minimum AWEF for 

refrigeration systems. More specifically, DOE identified design options for analysis and then 

used the cost-assessment approach to determine the manufacturing costs and analytical modeling 

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to determine the energy consumption at those levels. Additional details of the engineering 

analysis are in chapter 5 of the NOPR TSD.

1. Representative Equipment 

a. Panels and Doors 

In presenting the preliminary analysis, DOE proposed three representative sizes for each 

envelope equipment class: small, medium, and large. American Panel agreed with the sizes that 

DOE proposed. (American Panel, No. 0048.1 at p. 4) CrownTonka recommended that the 

equipment classes for envelopes be divided into only two sections, small and medium, because 

EPCA covers only walk-ins of less than 3,000 square feet, which excludes sizes that are typically 

considered “large.” (CrownTonka, Public Meeting Transcript, No. 0045 at p.111) Heatcraft 

agreed that the sizes chosen are small, as all the sizes considered must be less than 3,000 square 

feet, and they recommended that the distribution of envelope sizes include larger sizes 

approaching the 3,000 square foot limit, the maximum size limit defined in the statute. Heatcraft 

also stated that the selected envelope sizes will have an effect on the engineering analysis 

because certain technologies are utilized at different sizes. (Heatcraft, Public Meeting Transcript, 

No. 0045 at p. 111, No. 0058.1 at p. 4) American Panel suggested that DOE use three sizes and 

investigate using an extra large size. (American Panel, Public Meeting Transcript, No. 0045 at p. 

114) Manitowoc asserted that DOE did not include a large enough range of sizes and should 

consider smaller sized walk-ins to correctly represent the energy consumption of a given unit. 

Additionally, Manitowoc noted that as the walk-in’s size increases, there are different base levels 

of performance and that if DOE sets the minimum efficiency based on a larger size, 

manufacturers will not be able to make small-sized equipment meeting the standards. 

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(Manitowoc, Public Meeting Transcript, No. 0045 at pp. 116 and 118) Hill Phoenix 

recommended that the envelope sizes be determined by surface area or volume. (Hill Phoenix, 

No. 0066.1 at p. 2) NEEA and NPCC suggested that DOE establish a standard based on the 

square feet of panels shipped each year and use the square footage to determine the energy 

consumption of a complete functioning envelope,. (NEEA and NPCC, No. 0059.1 at p. 8)

DOE notes that its proposal rests on a component-based approach and does not include

infiltration losses. As a result, the size of the walk-in envelope does not affect the energy 

consumption of the components. In regard to American Panel’s and Heatcraft’s comments about 

large sized walk-ins, DOE analyzed a large panel size that it considered to represent the large 

panels found in the industry. DOE anticipated the possibility raised by Manitowoc that small 

panels might not be able to meet a standard based on the large panel size previously under 

consideration and is now considering the adoption of an approach that considers small, medium, 

and large sizes. As Hill Phoenix suggested, DOE determined the size of the panel based on the 

panel’s surface area. Also, similar to NEEA and NPCC’s suggestion, DOE is proposing a 

standard for walk-in panels based on the panel’s surface area. 

Panels

 As explained previously, the engineering analysis for walk-in panels uses three different 

panel sizes to represent the variations within each class. DOE determined the sizes based on 

market research and the impact on the test metric U-factor. Table IV-3 shows each equipment 

class and the representative sizes associated with that class. DOE requests comment on the 

representative sizes used in the proposed analysis. 
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Table IV-3 Sizes Analyzed: Panels

XXVIII.Eq

uipment 

Family 

NameClass

Equip

ment 

Famil

y 

Code

Tempe

rature 

Code Size Code

Representa

tive Height 

(feet)

Representa

tive Width 

(feet)

SP.MStructural Members

SSML C S 8 1.5

MED M 8 4 

LRG L 9 5.5

SP.L SML F S 8 1.5

MED M 8 4 

LRG L 9 5.5

FP.LFloor Panels

FSML F S 8 2 

MED M 8 4 

LRG L 9 6 

Doors

Similar to the panel analysis, the engineering analyses for walk-in display and nondisplay doors both use three different sizes to represent the differences in doors within each size 

class DOE examined. The door sizes were determined using market research. Details are 

provided in Table IV-4 for non-display doors and Table IV-5 for display doors.

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Table IV-4 Sizes Analyzed: Non-Display Doors

XXIX. Eq

uipment 

Family 

NameClass

Equip

ment 

Famil

y 

Code

Tempe

rature 

Code Size Code

Representat

ive Height 

(feet)

Representat

ive Width 

(feet)

PD.MPassage Doors

DSML C S 6.5 2.5

MED M 7 3 

LRG L 7.5 4 

PD.L SML F S 6.5 2.5

MED M 7 3 

LRG L 7.5 4 

FD.MFreight Doors

FSML C S 8 5 

MED M 9 7 

LRG L 12 7 

FD.L SML F S 8 5 

MED M 9 7 

LRG L 12 7 

Table IV-5 Sizes Analyzed: Display Doors

XXX. Eq

uipment 

Family 

NameClass

Equip

ment 

Famil

y 

Code

Tempe

rature 

Code Size Code

Representat

ive Height 

(feet)

Representat

ive Width 

(feet)

Display DoorsDD.M

DSML C S 5.25 2.25

MED M 6.25 2.5

LRG L 7 3 

DD.L SML F S 5.25 2.25

MED M 6.25 2.5

LRG L 7 3 

a.b. Refrigeration

In the engineering analysis for walk-in refrigeration systems, DOE analyzed the six 

primary walk-in refrigeration equipment classes: (1) Dedicated Condensing MediumTemperature Indoor System (DC.M.I), (2) Dedicated Condensing Low-Temperature Indoor 

System (DC.L.I), (3) Dedicated Condensing Medium-Temperature Outdoor System (DC.M.O), 

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(4) Dedicated Condensing Low-Temperature Outdoor System (DC.L.O), (5) MediumTemperature unit coolers connected to a Multiplex System (MC.M.N), and (6) Low-Temperature 

unit coolers connected to a Multiplex System (MC.L.N). 

DOE used a range of capacities as analysis points for each equipment class. The name of 

each equipment class along with the naming convention was discussed in section IV.A.3.b. In 

addition to the multiple analysis points, scroll, hermetic, and semi-hermetic compressors were 

also investigated because different compressor types have different efficiencies and costs.17 Due 

to the wide range of capacities considered for each condenser type, and the availability of 

compressors at certain capacities, compressors closely matching the condenser capacities were 

examined in terms of their performance at varying operating temperatures. 

Table IV-6 identifies, for each class of refrigeration system, the sizes of the equipment 

DOE analyzed. in the engineering analysis. Chapter 5 of the NOPR TSD includes additional 

details on the representative equipment classes used in the analysis. 

 

17 Scroll compressors are compressors that operate using two interlocking, rotating scrolls that compress the 

refrigerant. Hermetic and semi-hermetic compressors are piston-based compressors and the key difference between 

the two is that hermetic compressors are sealed and hence more difficult to repair, resulting in higher replacement 

costs, while semi-hermetic compressors can be repaired relatively easily.

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Table IV-6 Sizes Analyzed: Refrigeration System

XXI. Equipment Class XXXII. Sizes Analyzed (Btu/h) Compressors Analyzed

DC.M.I, < 159,000 6,000 Hermetic, Semi-hermetic

DC.M.I, ≥ 159,000 18,000; 54,000; 96,000 Hermetic, Semi-hermetic, Scroll

54,000 Semi-Hermetic, Scroll

96,000 Semi-Hermetic, Scroll

DC.L.I, < 15M.O, < 9,000 6,000 Hermetic, Semi-hermetic

DC.L.I, < 15M.O, ≥ 9,000 18,000; 54,000; 96,000 Hermetic, Semi-hermetic, Scroll

54,000 Semi-Hermetic, Scroll

96,000 Semi-Hermetic, Scroll

DC.M.O, < 7500L.I, < 9,000 6,000 Hermetic, Semi-hermetic, Scroll

DC.M.O, ≥ 7500L.I, ≥ 9,000 9,000; 54,000 Hermetic, Semi-hermetic, Scroll

54,000 Semi-Hermetic, Scroll

DC.L.O, < 75009,000 6,000 Hermetic, Semi-hermetic, Scroll

DC.L.O, ≥ 75009,000 9,000; 54,000; 72,000 Hermetic, Semi-hermetic, Scroll

54,000 Semi-Hermetic, Scroll

72,000 Semi-Hermetic

MC.M.N 4,000; 9,000; 24,000 -

9,000 -

24,000 -

MC.L.N 4,000; 9,000; 18,000; 40,000 -

9,000 -

18,000 -

40,000 -

1.2. Energy Modeling Methodology

In the preliminary analysis, DOE proposed using an energy consumption model to 

estimate separately the energy consumption rating of entire envelopes and entire refrigeration 

systems at various performance levels using a design-option approach. DOE developed the 

model as a Microsoft Excel spreadsheet. The spreadsheet calculated the cumulative effect on the 

energy consumption of adding options above the baseline. 

DOE continues to use a spreadsheet-based model, but is now modeling panels, display

doors, non-display doors, and refrigeration systems separately. The models estimate the 

performance of the because these components are tested separately. As mentioned above, the 

purpose of the engineering analysis is to determine the manufacturing costs of achieving 

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increased efficiency or decreased energy consumption. DOE assumes that manufacturers will 

only incur costs to achieve efficiency gains or energy reductions that are accounted for in their 

certified equipment rating. Therefore, the energy models estimate the performance rating that the 

manufacturer would obtain by testing their equipment using the DOE test procedure because 

manufacturers are required to rate the components using the test procedure. The models estimate 

the energy ratings of baseline equipment and levels of performance above the baseline associated 

with specific design options that are added cumulatively to the baseline equipment. The model 

does not account for interactions between refrigeration systems and envelope components, nor 

does it address how a design option for one component may affect the energy consumption of 

other components., because such effects are not accounted for in the test procedure. Component 

performance results are found in appendix 5A of the TSD. DOE requests comment on the 

performance data found in appendix 5A of the TSD and requests data about the performance of 

panels, display doors, or non-display doors and their design options.

a. Refrigeration

The refrigeration energy model calculates the annual energy consumption and the AWEF 

of walk-in refrigeration systems at various performance levels using a design option approach. 

AWEF is the ratio of the total heat removed, in Btus, from a walk-in envelope during a one-year 

period of use (not including the heat generated by operation of the refrigeration system) to the 

total energy input of refrigeration systems, in watt-hours, during the same period. DOE’s DOE

proposes to base its standards for the refrigeration system using the AWEF metric. DOE and

seeks comment on this approach. 

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This model was used to analyze specific examples of equipment in each refrigeration 

system equipment class. For a given class, the analysis consists of calculating the annual energy 

consumption and the AWEF for the baseline and several levels of performance above the 

baseline. See chapter 5 of the TSD for further details about the analytical models used in the 

engineering analysis.

For the preliminary analysis, DOE partially relied on refrigeration catalog information to

obtain equipment specifications for its energy model. Manitowoc and the Joint Utilities believed 

that catalog information was not the best source from an analytical standpoint. Manitowoc 

observed that catalog information is provided mainly for sizing equipment and not for 

representing equipment performance, while the Joint Utilities pointed out that the rating 

methodology that produced the data in the catalogs could be different from the rating 

methodology for walk-ins, which could make the data inappropriate for analyzing walk-ins. 

(Manitowoc, Public Meeting Transcript, No. 0045 at p. 31; Joint Utilities, No. 0061.1 at p. 3) 

In recognition of these comments, DOE conducted further research into refrigeration 

system performance and has improved the analysis for the NOPR in several ways. First, the 

energy model now calculates system performance based on a whole-system approach using 

thermodynamic principles. The model determines the refrigerant properties (pressure, 

temperature, etc.) at each point in the system and these properties, rather than catalog 

specifications, are used to calculate refrigeration capacity. Second, for any catalog information 

based on specific rating conditions, DOE ensured the rating conditions were consistent with 

those for walk-in refrigeration systems, or adjusted the specifications accordingly. Third, while it 
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continued to rely on catalog data directly for some equipment specifications (e.g., typical number 

of fans and fan horsepower for units of the sizes analyzed), DOE also surveyed catalogs from 

various manufacturers to determine the most representative specifications for a particular type 

and size of equipment. See chapter 5 for more details on the refrigeration system energy model

and other enhancements made to its analysis. 

The energy consumption calculations in the engineering analysis are based on

calculations in AHRI 1250-2009, the industry test procedure incorporated by reference in the 

walk-in test procedure. 76 FR at 33631. These calculations involve the refrigeration system 

running at a high load for one-third of the time and a low load for two-thirds of the time. 

American Panel noted that the load profile for restaurants would generally be reversed (i.e., the 

refrigeration system is sized for running at a high load two-thirds of the time and a low load onethird of the time) and requested DOE to adjust the load assumptions based on the walk-in

application. (American Panel, No. 0048.1 at p. 8) 

DOE’s assumption in the engineering analysis about the refrigeration load profile was 

made for purposes of comparing the performance of different types of refrigeration equipment 

that have varying features. Furthermore, the analysis attempts to assess the impacts of 

technologies manufacturers might use to improve the efficiencies of their equipment, including 

impacts on the efficiency ratings of the equipment. DOE will base any standards it adopts on the 

use of some or all of these technologies, and the DOE test procedure would serve as the basis for 

rating equipment and determining compliance. Therefore, the test procedure calculations are 
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used in the analysis to determine the efficiency ratings of equipment utilizing the various

technologies on which DOE might base the standards. 

However, DOE does not treat the load profile assumptions used in the engineering 

analysis as equivalent to the actual duty cycle of every class or application of refrigeration 

systems. Rather, where warranted, DOE evaluates other duty cycle assumptions in its energy use 

analysis, which examines the actual energy consumption of the refrigeration system under a 

variety of operating conditions and applications. In the energy use analysis, DOE has adjusted its 

assumptions for actual duty cycles based in part on American Panel’s recommendation. See

section IV.E.1 and chapter 7 of the TSD for details.

In the preliminary analysis, DOE analyzed the result of adding design options 

cumulatively to the baseline. DOE observed that some design options (e.g., larger condenser 

coil) increased the efficiency of the refrigeration system while also increasing its capacity. To 

distinguish between these effects, DOE created a “normalized energy consumption” metric in the 

preliminary analysis which represented the energy consumption per unit capacity. DOE expected 

that the normalized energy consumption metric would generally be analogous to an efficiency 

metric. For example, for two units of the same capacity, the unit with lower normalized energy 

consumption would be more efficient because it would use less energy for the same heat removal 

capability. 

In a comment on the preliminary analysis, American Panel stated that it was not 

beneficial for the capacity of a unit to increase because the refrigeration system must balance the 
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heat load to control temperature and humidity. (American Panel, Public Meeting Transcript, No. 

0045 at p. 175) After interviewing manufacturers and examining refrigeration catalogs, DOE

observed that manufacturers typically offer refrigeration systems in specific, discrete capacities 

while providing consumers with options for improving system efficiency. DOE reasoned that 

manufacturers would likely design their systems for a certain set of capacities regardless of the 

efficiency options available and, consequently, implementing efficiency options on a system 

would be unlikely to change the capacity of the system (because the manufacturer would prefer 

to market the system at the established capacity. Therefore, DOE agrees with American Panel’s 

assessment and has implemented its suggestion into the NOPR analysis. 

DOE notes that it analyzed six classes of refrigeration systems at various capacity points,

as explained in section IV.C.1.b. When a design option is added to the baseline, it does not 

change the capacity of the unit; instead, other aspects of the system are adjusted to maintain the 

capacity at the specified point. See chapter 5 of the TSD for details.

In the preliminary analysis, DOE considered the effects of adding design options to the 

baseline. Some interested parties commented on the interactive effects of design options. 

Thermocore stated that there are substantial differences in performances based on the integrated 

system as opposed to considering options separately. (Thermocore, Public Meeting Transcript, 

No. 0045 at p. 86) Emerson stated that DOE must account for how the technologies are 

combined because the effects will vary depending on what is already included in the system. 

(Emerson, Public Meeting Transcript, No. 0045 at p. 93) AHRI agreed that efficiency gains due 

to combinations of certain design options are not necessarily additive and noted that assessing 
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the aggregate benefit from combined design options requires rigorous analysis and simulation of 

the total system. (AHRI, No. 0055.1 at p. 2)

DOE recognizes that the interactive effects of design options must be considered because 

the efficacy of certain design options differs depending on whether they are analyzed separately 

or in conjunction with other design options. DOE has taken a system-based approach to the 

refrigeration system energy model that calculates the effect on the entire system of adding design 

options. Each efficiency level above the baseline consists of a design option added cumulatively 

and the interactive effects of each new design option on all previously added design options are 

considered. In formulating the cost-efficiency curves, DOE attempted to capture the most costeffective design option at each efficiency level, given all previously added design options at that 

level. Manufacturers may use any combination of design options to meet the future energy 

conservation standard. See chapter 5 of the TSD for further discussion on the interactive effects 

of design options. 

Some commenters disagreed with DOE’s refrigeration energy modeling approach. SCE 

recommended using DOE 2.2R (an expanded version of the building simulation program DOE 

2.2) to directly model certain design options, such as modulating the fan speed for the on-cycle 

fan power for a unit cooler connected to a multiplex system. (SCE, Public Meeting Transcript, 

No. 0045 at p. 138) NEEA and NPCC also stated that the spreadsheet-based model does not 

adequately evaluate all of the design options and their combinations, and that DOE should 

consider using DOE 2.2R for modeling instead. (NEEA and NPCC, No. 0059.1 at p. 9)

Comment [A14]: Edit made per OIRA.
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DOE 2.2R is designed to simulate the operation of building refrigeration systems, such as 

those found in supermarkets, refrigerated warehouses, and industrial facilities. Although DOE 

2.2R is a powerful simulation tool that can aid in refrigeration system design, DOE believes it is 

inappropriate for the energy modeling that DOE is conducting as part of this rulemaking. This 

rulemaking is taking a component-level approach and determining the performance of each 

component (the panels, the doors, and the refrigeration system) separately, whereas DOE 2.2R 

models the interactions of components that comprise an entire building. Also, the component 

performance as modeled in the engineering analysis must be based on the operating conditions 

and calculations contained in the test procedure, which DOE believes is not consistent with the 

simulation methodology in DOE 2.2R. To address the concerns of SCE, NEEA and NPCC that a 

spreadsheet model would be inadequate for certain options or combinations of options, DOE has 

modified the spreadsheet model to more accurately account for combinations of design options 

and interactive effects of design options within a component. To address the Joint Utilities’ 

concerns with fan speed modulation, DOE included calculations for fan speed modulation that 

are consistent with the test procedure.

 Although DOE is not conducting the analysis using DOE 2.2R, DOE encourages 

interested parties to submit their own simulation results from DOE 2.2R modeling and compare 

them to DOE’s engineering results.
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2.3. Cost Assessment Methodology 

a. Teardown Analysis

To calculate the manufacturing costs of the different components of walk-in coolers and 

freezers, DOE disassembled baseline equipment. This process of disassembling systems to 

obtain information on their baseline components is referred to as a “physical teardown.” During 

the physical teardown, DOE characterized each component that makes up the disassembled 

equipment according to its weight, dimensions, material, quantity, and the manufacturing 

processes used to fabricate and assemble it. The information was used to compile a bill of 

materials (BOM) that incorporates all materials, components, and fasteners classified as either 

raw materials or purchased parts and assemblies. 

DOE also used a supplementary method, called a “virtual teardown,” which examines 

published manufacturer catalogs and supplementary component data to estimate the major 

physical differences between equipment that was physically disassembled and similar equipment 

that was not. For virtual teardowns, DOE gathered product data such as dimensions, weight, and 

design features from publicly-available information, such as manufacturer catalogs. 

The teardown analyses allowed DOE to identify the technologies that manufacturers 

typically incorporate into their equipment. The end result of each teardown is a structured BOM, 

which DOE developed for each of the physical and virtual teardowns. DOE then used the BOM

from the teardown analyses as inputone of the inputs to the cost model to calculate the 

manufacturer production cost (MPC) for the product that was torn down. The MPCs derived

from the physical and virtual teardowns were then used to develop an industry average MPC for 

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each productequipment class analyzed. See chapter 5 of the NOPR TSD for more details on the 

teardown analysis.

For display doors and non-display freight doors, limited information was publicly 

available, particularly as to the assembly process and shipping. To compensate for this situation,

DOE conducted physical teardowns for two representative units, one within each of these 

equipment classes. DOE supplemented the cost data it derived from these teardowns with

information from manufacturer interviews. The cost models for panels and for non-display

structural doors were created by using public catalog and brochure information posted on 

manufacturer websites and information gathered during manufacturer interviews. 

For the refrigeration system, DOE conducted physical teardowns of unit cooler and 

condensing unit samples to construct a BOM. The selected systems were considered 

representative of baseline, medium-capacity systems, and used to determine the base components 

and accurately estimate the materials, processes, and labor required to manufacture each 

individual component. From these teardowns, DOE gleaned important information and data not 

typically found in catalogs and brochures, such as heat exchanger and fan motor details, 

assembly parts and processes, and shipment packaging. 

Along with the physical teardowns, DOE performed several virtual teardowns of 

refrigeration units for the NOPR analysis. The complete set of teardowns helped DOE obtain the 

baseline average MPC for all equipment classes proposed. 
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b. Cost Model 

The cost model is one of the analytical tools DOE used in constructing cost-efficiency 

curves. DOE derived the cost model curves from the teardown BOMs and the raw material and 

purchased parts databases. Cost model results are based on material prices, conversion processes 

used by manufacturers, labor rates, and overhead factors such as depreciation and utilities. For 

purchased parts, the cost model considers the purchasing volumes and adjusts prices accordingly. 

Original equipment manufacturers (OEMs), i.e., the manufacturers of WICF components, 

convert raw materials into parts for assembly, and also purchase parts that arrive as finished 

goods, ready-to-assemble. DOE bases most raw material prices on past manufacturer quotes that 

have been inflated to present day prices using Bureau of Labor Statistics (BLS) and American 

Metal Market (AMM) inflators. DOE inflates the costs of purchased parts similarly and also 

considers the purchasing volume – the higher the volume, the lower the price. Prices of all

purchased parts and non-metal raw materials are based on the most current prices available, 

while raw metals are priced on the basis of a 5-year average to smooth out spikes. Chapter 5 of 

the NOPR TSD describes DOE’s cost model and definitions, assumptions, data sources, and 

estimates.

For panels, non-display doors, and display doors DOE used a “parameterized” 

computational cost model, which allows a user to manipulate the components parameters such as 

height and length by inputting different numerical values for these features to produce new cost 

estimates. This parameterized model, coupled with the design specifications chosen for each 

representative unit modeled in the engineering analysis, was used to develop fundamental MPC 

costs. The fundamental MPC costs were then incorporated into the engineering analysis model 

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where they were combined with additional costs associated with each design option. Costs for 

each design option were calculated based on discussions with panel, non-display, and display 

door manufacturers and pricing from commercially available sources. 

As previously mentioned in section IV.B.3, DOE is considering high efficiency lighting, 

specifically light-emitting diode (LED) lighting, as a design option to improve the efficiency of 

display doors. Forecasts of the LED lighting industry, including those performed by DOE, 

suggest that LED lighting is an emerging technology that will continue to experience significant 

price decreases in coming years. For this reason, in an effort to capture the anticipated cost 

reduction in LED fixtures in the analyses for this rulemaking, DOE incorporated price 

projections from its Solid State Lighting program into its MPC values. The price projections for 

LED lighting were developed using projections created for the DOE’s Solid State Lighting 

Program’s 2012 report, Energy Savings Potential of Solid-State Lighting in General Illumination 

Applications 2010 to 2030 (“the energy savings report”). In the appendix of this report, price 

projections from 2010 to 2030 were provided in ($/klm) for LED lamps and LED luminaires. 

DOE analyzed the models used in the Solid State Lighting program work and determined that the 

LED luminaire projection would serve as a proxy for a cost projection to apply to LEDs on walkin display doors.

The price projections presented in the Solid State Lighting program’s energy savings 

report are based on the DOE’s 2011 Solid State Lighting R&D Multi-Year Program Plan 
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(MYPP)18

 

. The MYPP is developed based on input from manufacturers, researchers, and other 

industry experts. This input is collected by the DOE at annual roundtable meetings and 

conferences. The projections are based on expectations dependent on the continued investment 

into solid state lighting by the DOE. 

DOE incorporated the price projection trends from the energy savings report into its 

engineering analysis by using the data to develop a curve of decreasing LED prices normalized 

to a base year. That base year corresponded to the year when LED price data were collected for 

the NOPR analyses of this rulemaking from catalogs, manufacturer interviews, and other 

sources. DOE started with LED cost data specific to walk-in manufacturers and then applied the 

anticipated trend from the energy savings report to forecast the projected cost of LED fixtures at 

the time of required compliance with the proposed rule (2017). These 2017 cost figures were 

incorporated into the engineering analysis to calculate the MPC of display doors with LEDs as a 

design option. The LCC analysis (section IV.F) was carried out with the engineering numbers 

that account for the 2017 cost of LED luminaires. The reduction in costs of LED luminaires from 

2018 to 2030 were taken into account in the NIA (section IV.G). The cost reductions were 

calculated for each year from 2018 and 2030 and subtracted from the equipment costs in the 

NIA.

 

18 The DOE Solid-State Lighting Research and Development Multi-Year Program Plan is a document that outlines 

DOE’s research goals and planned methodologies with respect to the advancement of solid-state lighting 

technologies in the United States. The complete document is available at: 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_mypp2011_web.pdf.
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During the preliminary analysis, DOE developed a cost model for the proposed 

representative sizes of walk-in envelopes. Panel manufacturers generally make panels with a 

combination of raw materials and purchased parts, and DOE estimated manufacturing process 

parameters, the required initial material quantity, scrap, and other factors to determine the value 

of each component. DOE then aggregated all parameters related to manufacture and assembly to 

determine facility requirements at various manufacturing scales and the final unit cost. 

To more accurately model walk-in costs, DOE used common factory parameters, which 

affect the cost of each unit produced (e.g., labor and fabrication rates). American Panel 

commented on some of the factors assumed in the cost model and the resulting values. In 

particular, in its view, approximately 1 million square feet of panels are manufactured per year 

per manufacturer, and most door manufacturers produce 1,800 doors per year. Accordingly, 

these numbers suggest a total walk-in production volume of well under DOE’s initial estimate of 

30,000 per year per manufacturer. American Panel believed that overestimating the amount of 

panels manufactured per year would cause the small manufacturers to be at a disadvantage. 

(American Panel, Public Meeting Transcript, No. 0045 at p. 14–15; American Panel, No. 0048.1 

at pp.5–6) 

Assuming an average walk-in surface area of 500 ft2 (roughly corresponding to an 8-foot 

by 10-foot walk-in), American Panel’s estimate equates to approximately 2,000 walk-ins per 

year, per manufacturer – much lower than DOE’s estimate. DOE understands that its estimate

may be more reasonable for a large manufacturer than a small one and agrees with American 

Panel that impacts on small manufacturers may be underestimated in an analysis that assumes a 

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high production capacity. Thus, DOE has considered particular impacts on small manufacturers 

in the MIA by adjusting for their reduced production capacity as compared to larger 

manufacturers. See sections IV.I.3.c and 0V.B.2.d (Manufacturer Impact Analysis) and VI.B

(Regulatory Flexibility Analysis, which specifically address the impact of the rule on small 

business manufacturers). 

Additionally, American Panel, citing its own experience, stated that other DOE cost 

estimates needed adjusting, citing its own experience. Some examples include the following:

• The cost of the tongue and groove design found on panels should be increased by a factor of 

10.8.

• The cost of the advanced door sweep should increase by a factor of 7.8. 

• The DOE cost per square foot of panel was too high and actual costs were closer to $0.25 per 

square foot.

• The actual MSP for walk-in cooler envelopes was 70–112 percent lower than the DOE estimate.

• The actual MSP for walk-in freezer envelopes was 24–42 percent lower than the DOE estimate. 

(American Panel, Public Meeting Transcript, No. 0045 at pp. 14–15; American Panel, No. 

0048.1 at pp. 5–6) 

 

DOE appreciates the efforts made by American Panel in preparing detailed comments

and providing useful information about factory parameters, material costs, and the resulting 

manufacturing selling price for walk-in envelopes. Some of the differences can be explained 

based on the parameters used in the cost model, such as the material costs. DOE particularly 

appreciates American Panel’s comments related to the costs of certain designs and has taken 

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these costs into consideration in its analysis by aggregating them with other data DOE has 

received through research and confidential manufacturer interviews. For instance, American 

Panel’s cost per square foot of panel was particularly useful in helping DOE estimate the costs of 

certain materials that make up the panel. 

DOE was not, however, able to use some of the cost data -- —for example, costs related to 

infiltration-reducing measures were not used because DOE is no longer considering infiltration 

in the analysis. Also, DOE has not calculated costs related to the assembly of the entire envelope

-- —for instance, the MSP of the envelope -- —as part of the engineering analysis because of the 

component-based approach DOE is proposing to use. Consequently, DOE is now using the cost 

model to determine the manufacturer production costs and manufacturer selling prices of the 

individual components covered by the standards. 

DOE estimated installation costs for the refrigeration systems and the envelope 

components separately as part of the life-cycle cost analysis. DOE has proposed new 

manufacturer cost estimates in chapter 5 of the TSD and seeks comment on the new parameters 

proposed for each component. 

c. Manufacturing Production Cost

Once it finalized the cost estimates for all the components in each teardown unit, DOE 

totaled the cost of the materials, labor, and direct overhead used to manufacture the unit to 

calculate the manufacturer production cost of such equipment. The total cost of the equipment 

was broken down into two main costs: (1) the full manufacturer production cost, referred to as 

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MPC; and (2) the non-production cost, which includes selling, general, and administration 

(SG&A) costs; the cost of research and development; and interest from borrowing for operations 

or capital expenditures. DOE estimated the MPC at each design level considered for each 

productequipment class, from the baseline through max-tech. After incorporating all of the data

into the cost model, DOE calculated the percentages attributable to each element of total 

production cost (i.e., materials, labor, depreciation, and overhead). These percentages were used 

to validate the data by comparing them to manufacturers’ actual financial data published in 

annual reports, along with feedback obtained from manufacturers during interviews. DOE uses 

these production cost percentages in the MIA (see section IV.I).

In the preliminary analysis, DOE developed both an envelope cost and a refrigeration 

system cost for each equipment class and size using a manufacturing cost model. See chapter 5 

of the preliminary TSD. American Panel suggested that manufacturer cost should be estimated 

using a sample from 40 manufacturers and representative volumes. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 312) In response to American Panel’s comment, DOE 

believes it is infeasible to sample so many manufacturers because data on manufacturing cost 

and representative volumes are not publicly available for most manufacturers of walk-ins and 

walk-in components, particularly small, private companies. Additionally, not all manufacturers 

were willing to share cost information with DOE. DOE did hold confidential interviews with 

manufacturers, some of whom chose not to share this information. DOE notes that cost 

information it did obtain was helpful in enabling the agency to develop and refine its estimates of 

manufacturer cost. The interview process is explained in chapter 12 of the TSD.
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d. Manufacturing Markup

DOE uses MSPs to conduct its downstream economic analyses. DOE calculated the

MSPsbyMSPs by multiplying the manufacturer production cost by a markup and adding the 

equipment’s shipping cost. The production price of the equipment is marked up to ensure that 

manufacturers can make a profit on the sale of the equipment. DOE gathered information from 

manufacturer interviews to determine the markup used by different equipment manufacturers. 

Using this information, DOE calculated an average markup for each component of a walk-in. 

DOE requests comments on the proposed markups listed in Table IV-7. 

Table IV-7 Manufacturer Markups

XXXIII. Walk-In Component XXXIV. Markup

Panels 32%

Display Doors 50%

Non-Display Doors 62%

Refrigeration Equipment 35%

a.e. Shipping Costs

In the preliminary analysis TSD, DOE calculated manufacturer shipping costs assuming 

that manufacturers include outbound freight as part of their equipment selling price. In response 

to DOE’s request for comment on shipping assumptions, American Panel and NEEA and NPCC 

remarked that DOE’s costs were significantly higher than actual industry shipping rates. 

(American Panel, Public Meeting Transcript, No. 0045 at p. 15, 142; NEEA and NPCC, No. 

0059 at p. 9) Additionally, American Panel stated that freight costs are typically paid in full by 

the customer and not absorbed by the manufacturer who is selling the equipment. (American 

Panel, No. 0048.1 at p. 5) Both American Panel and CrownTonka said that sometimes the freight 

cost would be included as part of the selling price and sometimes it would be entirely separate; 

i.e., paid by the buyer directly to the freight company. (American Panel, Public Meeting 

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Transcript, No. 0045 at p. 143; CrownTonka, Public Meeting Transcript, No. 0045 at p. 144) 

NEEA and NPCC stated that freight costs are normally included in the packaged price to 

consumers. (NEEA and NPCC, No. 0059.1 at p. 9) 

DOE re-evaluated the shipping rates in preparing this NOPR. These rates were developed

by conducting additional research on shipping rates and by interviewing manufacturers of the 

covered equipment. For example, DOE found through its research that most panel, display door, 

and non-display door manufacturers use less than truck load freight to ship their respective 

components and revised its estimated shipping rates accordingly. DOE also found that most 

manufacturers, when ordering component equipment for installation in their particular 

manufactured product, do not pay separately for shipping costs; rather, it is included in the 

selling price of the equipment. However, when manufacturers include the shipping costs in the 

equipment selling price, they typically do not mark up the shipping costs for profit, but instead 

include the full cost of shipping as part of the price quote. DOE has revised its methodology 

accordingly. Please refer to chapter 5 of the TSD for details. 

2.4. Baseline Specifications

a. Panels and Doors

In the preliminary analysis, DOE set the baseline level of performance to correspond to 

the most common least efficient component that is compliant with the standards set forth in 

EPCA. (42 U.S.C. 6313(f)(1)(3)) DOE determined specifications for each equipment class by 

surveying currently available units and models. This approach was used for the NOPR analyses 

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to determine the baseline units for panels, display doors, and non-display doors. More detail 

about the specifications for each baseline model can be found in chapter 5 of the TSD. 

Because the walk-in market is comprised of panels insulated with polyurethane and 

extruded polystyrene, DOE proposed in the preliminary analysis that the R-value for the baseline 

insulation used in the walk-in envelope would be the average of the typical long term thermal 

resistance (LTTR) R-values of polyurethane and extruded polystyrene. CPI opposed the use of 

an average R-value for extruded polystyrene and polyurethane because it would affect the 

accuracy of the normalized energy consumption calculation for the envelope. (CPI, No. 0052.1, 

at p.1) DOE agrees with CPI’s concern and is using in the revised analysis foam-in-place 

polyurethane as the baseline insulation for panels and non-display doors. Polyurethane is more 

commonly used as panel or non-display door insulation, has a better long term thermal 

resistance, and is less expensive than extruded polystyrene. DOE notes that extruded polystyrene 

may outperform polyurethane in other respects, like moisture absorption, which are not captured 

in the energy consumption model because they are not included in the test procedure.

DOE’s analysis also uses wood framing members as the baseline framing material in 

panels. The analysis assumes the typical wood frame completely borders the insulation and is 1.5 

inches wide. DOE requests comment on its baseline specifications for walk-in panels, 

specifically the assumptions about framing material and framing dimensions. 

 

The baseline display doors modeled in DOE’s analysis are based on the minimum 

specifications set by EPCA. (42 U.S.C. 6313(f)(3)) DOE modeled baseline display cooler doors 
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comprised of two panes of glass with argon gas fill and hard coat low emittance or low-e coating. 

The baseline cooler display door requires 2.9 Watts per square foot of anti-sweat heater wire and 

does not have a heater wire controller. The baseline display freezer doors modeled in DOE’s 

analysis consist of three panes of glass, argon gas, and soft coat low-e coating. Baseline freezer 

doors use 15.23 watts per square foot of anti-sweat heater wire power and require an anti-sweat 

heater wire controller. DOE also estimates that each baseline door includes one fluorescent light

with electronic ballasts, with a door shorter than 6.5 feet having a 5-foot fluorescent bulb and a 

door equal to or taller than 6.5 feet having a 6-foot fluorescent bulb. DOE requests comment on 

the baseline assumptions for display cooler and freezer doors. In particular, DOE requests data 

illustrating the energy consumption of anti-sweat heaters found on cooler and freezer display 

doors. 

DOE’s analysis assumes that the baseline non-display doors are constructed in a similar 

manner to baseline panels. Therefore, DOEDOE’s analysis uses baseline non-display doors that

consist of wood framing materials 1.5 inches wide that completely border the foamed-in-place 

polyurethane insulation. DOE also includes a small window in a non-display door that conforms 

to the standards set by EPCA. DOE estimates that all passage doors have a 2.25 square foot 

window regardless of the passage door’s size. DOE analyzed two different size windows for 

non-display freight doors. The small freight doors have a 2.25 square foot window and both the 

medium and large freight doors have a 4-square foot window. DOE requests comment on the 

baseline specifications for non-display doors, and specifically on the size of the windows 

included in the baseline doors. 
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DOE also received comments about the amount of energy savings attributed to 

infiltration reduction devices (IRDs) on baseline walk-in doors. NEEA and NPCC commented 

that even though EISA requires an infiltration reduction device on the baseline door, DOE 

should also include additional IRDs as a design option. NEEA and NPCC continued to suggest 

that DOE should re-evaluate the amount of energy savings associated with IRDs. (NEEA and 

NPCC, Public Meeting Transcript, No. 0045 at p. 170) The Joint Utilities also believed that DOE 

overestimated the impacts of IRDs in the baseline doors and explained that overestimating the 

baseline savings from an IRD affects the amount of savings achieved by the design options DOE 

evaluated. (Joint Utilities, No. 0061.1 at p. 5) DOE agrees with NEEA and NPCC and the Joint 

Utilities that a baseline door must have an IRD because this is required by EPCA. (42 U.S.C. 

6313(f)(1)(A)(B)) However, the walk-in test procedure does not measure energy consumption 

from door-opening infiltration so there is no rated energy saving from IRDs and DOE is not 

estimating the amount of energy saved from IRDs on baseline doors. 

b. Refrigeration

As with panels and doors, DOE set the baseline level of refrigeration system performance 

to correspond to components that were the least efficient but compliant with the standards set 

forth in EPCA. See 42 U.S.C. 6313(f)(1)-(3). DOE determined specifications for each equipment 

class by surveying currently available models. See chapter 5 of the TSD for more details about 

the specifications for each baseline model. 

In the preliminary analysis, DOE analyzed several representative baseline units for 

refrigeration systems and requested comment on the characterization of the baseline units. In 

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response to DOE’s request for comment on the representative units analyzed, several 

stakeholders expressed concern that the range of refrigeration systems DOE evaluated was too 

limited. Heatcraft and the Joint Utilities encouraged DOE to include larger capacity equipment 

and different compressor types. (Heatcraft, No. 0058.1 at pp. 3–4; Heatcraft, No. 0069.1 at p. 2; 

Joint Utilities, No. 0061.1 at p. 3) American Panel echoed this concern and stated that DOE 

should explore the full range of condensing units and that WICF envelopes should be paired with 

different sized refrigeration systems based on use. (American Panel, No. 0048.1 at pp. 8–9) DOE 

has considered these comments and has expanded its analysis to include a larger range of 

refrigeration system capacities. DOE has also included different compressor types in the 

refrigeration system analysis; see section IV.C.5.b and chapter 5 of the TSD for details. DOE has 

not considered pairing WICF envelopes and refrigeration systems in the engineering analysis, 

however, because DOE is applying a component-based approach. 

The preliminary analysis also presented estimated baseline specifications and costs for 

the representative units it analyzed. American Panel remarked that the baseline costs in the 

engineering analysis were too low and were not comparable to their data. Additionally, it stated 

that the refrigeration load will increase if the product is not at the same temperature as the walkin cooler or freezer. (American Panel, No. 0048.1 at p. 7) Interested parties also commented on 

certain baseline unit subcomponents that were not included in the engineering analysis. 

American Panel noted that baseline units could include a downstream solenoid valve that would 

prevent refrigerant from migrating to the evaporator and Heatcraft encouraged DOE to make 

sure that the amount of refrigerant, piping, and insulation scale properly with size. (American 

Panel, No. 0048.1 at p. 7; Heatcraft, No. 0069.1 at p. 3) 
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In response to American Panel’s comments on refrigeration system costs, DOE adjusted 

its cost model as described in section IV.C.3 and believes its costs are now more representative 

of typical equipment. Regarding refrigeration load, DOE does not consider the effect of different 

product loads in the engineering analysis because the engineering analysis is based on the rating 

conditions; DOE considers product loads in the energy use analysis as explained in section 

IV.E.3. In response to American Panel’s and Heatcraft’s comments about subcomponents of

refrigeration equipment, the revised analysis now includes all necessary subcomponents from the 

manufacturer -- —i.e., those subcomponents needed for the unit to operate. The analysis includes 

a calculation of refrigerant charge that is scaled with the size of the unit, as Heatcraft suggested. 

DOE has tentatively decided not to include piping and insulation between the unit cooler and 

condensing unit, as it believes these components would not be supplied by the manufacturer or 

included in the equipment’s MSP, but by the contractor upon installation of the equipment. DOE 

requests comment on this assumption.

In the preliminary analysis, DOE made certain assumptions regarding saturated 

evaporator temperature (SET) and saturated condensing temperature (SCT) that it used in the 

analysis for freezers and coolers and indoor and outdoor units. In general, DOE based these 

temperatures on an assumed temperature difference (TD) between the coil temperature and the 

ambient temperature where the ambient temperature for indoor and outdoor units was specified 

by the rating conditions in AHRI 1250-2009, the test procedure for refrigeration systems. 76 FR 

at 33631. The Joint Utilities and Heatcraft both submitted comments about the temperature set 

points in the baseline equipment; the Joint Utilities suggested a condensing temperature control 

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point of 90 °F for both freezers and coolers, while Heatcraft recommended different temperatures 

for several productequipment classes. (Joint Utilities, No. 0061.1 at p. 10; Heatcraft, No. 0069.1 

at p.2) 

In determining appropriate temperature set points, DOE considered information from 

various sources when formulating its assumptions, including comments, research, and 

discussions with manufacturers and other parties. DOE notes that the ambient temperature for the 

test procedure is 90 and 95 °F for indoor and outdoor condensing units, respectively. Given that 

the system must maintain a reasonable TD between the SCT and the ambient temperature, the 

SCT during the test procedure would be higher than the 90–95 °F assumption recommended by 

the Joint Utilities. Even though the set point during actual use may be lower, equipment is 

rated—and evaluated for meeting the standard—at the test procedure rating points. For these 

reasons, DOE believes its SCT assumptions are reasonable for baseline equipment operating at

the rating conditions required for the test procedure. DOE requests comment on this assumption, 

particularly whether the TDs for baseline and higher efficiency equipment are appropriate. See 

chapter 5 of the TSD for details.

3.5. Design Options

a. Panels and Doors

For the preliminary analysis, DOE included the following design options for the walk-in 

envelope:

• Improved wall, ceiling, and floor insulation

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• Improved door gaskets and panel interface systems

• Electronic lighting ballasts and high-efficiency lighting

• Occupancy sensors and automatic door opening and closing systems

• Air curtains and strip curtains

• Vestibule entryways

• Display and window glass system insulation enhancements

• Anti-sweat heater controls and no anti sweat heat systems

In the preliminary analysis, DOE presented tables detailing each design option, including 

the cost of implementing each option and a description of the design option’s properties. The 

discussion below sets forth comments received on these design options for panels and doors, as 

well as DOE’s proposed approach in today’s NOPR. 

Panels

Stakeholders commented on steady state IRDs that DOE initially considered including as 

design options for the walk-in envelope. Craig Industries commented that DOE should consider 

different caulking materials as a design option because it is inexpensive and would reduce 

infiltration by sealing the joints of walk-ins, but noted that this design option would conflict with 

the current National Sanitation Foundation (NSF) standards. (Craig Industries, No. 0064.1 at p. 

3) American Panel stated that changing the gasketing or joint profile of an insulated panel would 

require a new test burden of $20,000, and that the improved gasketing is not necessarily going to 

be functional. It also noted that improved panel interfaces may not mate with existing walk-in 

panels, which would prevent manufacturers from supplying replacement panels. Lastly, in its 

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view, the complex gasketing and panel interface systems could cause walk-ins to become more 

difficult to build. (American Panel, No. 0048.1 at p. 6; American Panel, Public Meeting 

Transcript, No. 0045 at p. 121) Hill Phoenix commented that enhancing the gasketing between 

panels will not have a significant impact on the walk-in’s energy consumption. In its view, the

main heat load caused by infiltration is from door openings as opposed to steady state 

infiltration. (Hill Phoenix, No. 0066.1 at p. 3)

For the reasons stated in the test procedure final rule, the test procedure recently

promulgated by DOE no longer requires manufacturers to measure a walk-in’s steady-state 

infiltration. Therefore, design options for reducing steady state infiltration, including caulking

and improved gasketing, would not impact the rated energy consumption of any of the walk-in 

components addressed in this rulemaking. 76 FR 21580, 21595 (April 15, 2011). Furthermore, 

DOE would screen out any design options (including caulking) that would be likely to have

significant adverse impacts on the utility of the equipment or had an adverse impact on health or 

safety, according to the screening criteria described in section IV.B. . 

In the preliminary analysis, DOE considered design options that increased the baseline 

insulation thickness and improved insulation material. The preliminary analysis used a baseline 

insulation thickness of 4 inches and analyzed design options with increased insulation 

thicknesses of 5 inches, 6 inches, and 7 inches. The baseline panel insulation R-value was an 

average of extruded polystyrene and foamed-in-place polyurethane. The improved insulation 

materials in the preliminary analysis were vacuum insulated panel (VIP) insulation and hybrid 

insulation, a combination of the baseline material and vacuum insulated panels. 
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Many stakeholders commented on the proposed insulation improvements. American 

Panel did not agree with the initial costs DOE initially presented for the increased thicknesses of 

insulation. In its view, costs were higher due to the increased difficulty of manufacturing thicker 

panels. To accurately reflect this inefficiency, American Panel suggested DOE increase the cost 

of labor per panel because it takes more time to foam the fixture. (American Panel, No. 0048.1 at 

p. 5) American Panel also remarked that most manufacturers possess tooling that is adjustable

only from 4–6 inches. (American Panel, Public Meeting Transcript, No. 0045 at p. 121) Hill 

Phoenix stated that panel thicknesses above 5.5 inches will have a costly impact on the 

manufacturer and end user because manufacturers need to purchase more equipment to deal with 

the increased weight and the end-user will need more floor space to house or site the walk-in. 

(Hill Phoenix, No. 0066.1 at p. 3) American Panel criticized the preliminary analysis for omitting 

insulating floor panels or an insulation slab with vertical breaks as design options. American 

Panel explained that although the payback period would be longer if these options are included, 

DOE should still consider the long term energy savings that these options may yield. (American 

Panel, No. 0048.1 at p. 5) 

DOE agrees with American Panel that most manufacturers do not currently have the 

tooling to produce panels with more than 6 inches of insulation. In addition, DOE finds that 

constructing and handling panels thicker than 6 inches would be unduly burdensome to the 

manufacturer because panels thicker than 6 inches would be very difficult to handle, store, ship, 

and produce at typical industry production volumes. Because panels thicker than 6 inches would 

not be practicable to manufacture, DOE screened them out from its analysis. DOE’s NOPR 
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analysis limits the maximum insulation thickness to 6 inches of foam and DOE does not expect 

its proposed standard to require panels thicker than 5 inches (see chapter 5 and appendix 10D of 

the TSD).); however, the agency requests comment on this assumption in the analysis. DOE 

notes Hill Phoenix’s comment about the increased labor cost associated with increasing the panel 

thickness and proposes to account for the increased cost of handling large panels in its costefficiency analysis. DOE also agrees with American Panel’s comment that requiring insulated 

floor panels for walk-in coolers would produce long term energy savings. However, DOE is not 

proposing to set a standard for walk-in cooler floors as explained in section IV.A.2.a of this 

notice.

Two stakeholders made comments specifically about VIPs. NanoPore stated that silicacarbon based core materials have a better lifetime performance than fiberglass core materials 

when using vacuum insulated panels, and noted that VIPs have reached a point of large scale 

commercialization. (NanoPore, No. 0067.1 at pp. 1 and 6) However, Hill Phoenix commented 

that VIPs are impractical because of the high cost to the manufacturer, and that vacuum insulated 

panels would require additional labor and tooling. (Hill Phoenix, No. 0066.1 at p. 3) 

DOE included hybrid insulation (half foam-in-place polyurethane and half VIP) as a 

design option to improve the efficiency of walk-in panels and non-display doors. It did not, 

however, include VIP insulation as a design option because DOE cannot definitively conclude 

that VIPs have the structural capability of supporting typical walk-in loads, particularly since

VIPs can easily be punctured, which would cause a loss in thermal insulation (see chapter 5 of 

the TSD for details). DOE notes that while NanoPore stressed the benefits of silica-carbon based 
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VIP, DOE did not specify the type of VIP used in the engineering analysis in order to maximize 

manufacturer flexibility in meeting the proposed standard. DOE agrees with Hill Phoenix that 

VIPs are more expensive and may require additional tooling, but DOE does not find this 

increased cost couldwould prevent manufacturers from implementing VIPs. DOE also notes that 

the high costs of VIPs are captured in the engineering analysis for panels and non-display doors.

In its engineering analysis for walk-in panels, DOE included design options which 

increase the baseline insulation thickness, change the baseline insulation material from foam-inplace polyurethane to a hybrid of polyurethane and VIP, change the baseline framing material 

from wood to high density polyurethane, and eliminate a structural panel’s framing material. 

DOE assumed in its analysis that freezer floor panels retain some type of framing material to 

maintain structural integrity because the foam itself may be un ableunable to support heavy, 

perpendicular loads -- e.g. personnel, machinery, and products -- to the panel’s face. DOE also 

assumed that high density polyurethane framing materials used in a panel have the same 

dimensions as the wood framing materials used in a wood-framed panel. DOE seeks comment on 

these panel design options, particularly with respect to the specifications for high density 

polyurethane framing materials. 

Doors

Stakeholders also commented on design options that would reduce the infiltration from 

door openings: namely, automatic door opening and closing systems, which automatically open 

and close the door by sensing when a person is about to pass or has passed through; air curtains 

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and strip curtains, both of which provide a secondary barrier to air infiltration when the door is 

open; and vestibule entryways, which consist of a series of two doors separated by a space 

through which one would pass to enter the walk-in. Hired Hand noted that the engineering 

analysis omitted automatic roll-up doors or bi-folding envelope doors, and that these doors 

cannot be adequately subsumed under “automatic door opening and closing” (which DOE did 

include) because this option does not capture the full benefit of these doors. (Hired Hand, No. 

0050.1 at pp. 1-2) American Panel was skeptical that automatic door opening and closing sensors 

existed in the industry and did not agree with DOE’s proposed cost of the technology. (American 

Panel, No. 0048.1 at p.6) American Panel also stated that a vestibule is not a practical design 

option because the cost of the floor space and the layout of standard stores would be prohibitive 

to the end user. It noted that the cost of a vestibule is higher than DOE estimated, and predicted 

that the cost for materials and equipment would be well over $2,500. (American Panel, No. 

0048.1 at pp. 3 and 6) 

For the reasons stated in its recent final rule, the test procedure does not include a method 

for measuring the door opening infiltration associated with walk-ins. See 76 FR at 21595. 

Therefore, the energy consumption caused by door opening infiltration is not accounted for in 

the panel, display door, or non-display door engineering analyses, and design options related to 

door opening infiltration would not affect the energy consumption of the walk-in components. 

Some stakeholders specifically commented about the strip curtains design option. NEEA 

and NPCC stated that strip curtains are already required by EPCA, and should not be considered 

a design option, but that infiltration load could still be reduced by additional IRDs. (NEEA and 
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NPCC, Public Meeting Transcript, No. 0045 at p. 170; NEEA and NPCC, No. 0059.1 at p. 8) 

NEEA, NPCC and Master-Bilt disagreed with DOE’s assumption that strip curtains can reduce 

the total energy consumption of a walk-in by half. NEEA and NPCC suggested strip curtains 

would more likely reduce the energy consumption by one third, according to a Pacific Northwest 

study, and Master-Bilt commented that strip curtains reduce the compressor load by less than 5 

percent according to their own field tests. (NEEA and NPCC, Public Meeting Transcript, No. 

0045 at p. 152; NEEA and NPCC, No. 0059.1 at p. 8; Master-Bilt, Public Meeting Transcript, 

No. 0045 at p.159; Master-Bilt, No. 0046.1 at p. 1) American Panel noted that strip curtain 

manufacturers indicated that the device achieves a 25 percent reduction in air infiltration, much 

lower than DOE’s assumption of 90 percent effectiveness. (American Panel, Public Meeting 

Transcript, No. 0045 at p. 154; American Panel, No. 0048.1 at p. 6) Lastly, AHRI also 

commented that DOE overestimated the benefit of strip curtains, and that DOE should verify 

their assumptions with field data; AHRI did not provide any alternative data on the benefit of 

strip curtains. (AHRI, No. 0055.1 at p. 2) As explained in section IV.B.1 of this document, 

however, infiltration devices are no longer included in the engineering analysis.

Stakeholders also commented on the door lighting design options presented in the 

preliminary analysis; specifically, occupancy sensors that cause the lights to operate only when 

people are present; electronic lighting ballasts, which are more efficient than typical magnetic 

ballasts; and high-efficiency light-emitting diode (LED) lighting, a type of lighting that uses 

semiconducting materials to produce light and uses less energy per lumen than incandescent or 

fluorescent lighting. American Panel stated that LED lighting is not a viable design option 

because the LED fixture and bulb payback period is 2.5 years. (American Panel, No. 0048.1 at p. 
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6) The Joint Utilities suggested that DOE should add LED lighting with motion controls as a 

design option for display cases. (Joint Utilities, Public Meeting Transcript, No. 0045 at p. 26; 

Joint Utilities, Public Meeting Transcript, No. 0045 at p. 89; Joint Utilities, No. 0061.1 at p. 3)

 In response to American Panel’s concern about the cost of LED lighting, DOE accounts 

for the cost of the bulb and fixture when estimating the total cost of LED lighting. However, 

DOE has not automatically eliminated LED lighting from consideration based on payback period 

but includes it in the range of design options it is considering. For more details on the payback 

period analysis, see section IV.F. In response to the suggestion from Joint Utilities, a combined 

design option with LED lighting and motion control sensors is not warranted because DOE 

already includes a lighting sensor and LED lighting as separate design options in the walk-in 

display door engineering analysis. A separate design option for lighting sensors allows the sensor 

to be applied to fluorescent as well as LED lighting. 

Some stakeholders commented on the anti-sweat heater wire design option. CrownTonka 

commented that anti-sweat heater wire should be applied to non-display freezer doors and any 

windows in non-display doors. (CrownTonka, Public Meeting Transcript, No. 0045 at p. 89) 

Craig Industries supported the inclusion of self-regulating heater wire and noted that this wire is 

readily available and more efficient than other types of heater wires. (Craig Industries, No. 

0064.1 at p. 1) DOE agrees with CrownTonka and proposes to include anti-sweat heater wire 

around the outer edge of non-display freezer doors as well as on the windows located on nondisplay doors as design options. In response to Craig Industries’ suggestion, the energy savings 

from self -regulating anti-sweat heater wire alone cannot be captured in the proposed engineering 
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analysis for display and non-display doors because the energy savings are not captured by the 

test procedure. The test procedure credits the manufacturer with energy savings if a preinstalled 

timer, control system or other auto-shut-off system is required for the used in conjunction with 

anti-sweat heater wire to receive. The credit is called a percent time off (PTO) credit, which 

reduces the calculated power associated with the device. 76 FR 33631, 33635, 33637 (June 9, 

2011). 

The display door design options used in the analysis include improved glass packs—

where “glass pack” refers to the combination of glass panes, gas fill, and low-emission coatings 

making up the transparent part of the door; anti-sweat heater controls for cooler doors; LED 

lighting; and lighting sensors that control when the lights turn on and off. DOE did not analyze 

anti-sweat heater controls for freezer display doors because baseline freezer doors mustare 

already required to have a controller to regulate the power consumed by the anti-sweat heater 

wire. EISA requires all freezer doors to have an anti-sweat heater control if the anti-sweat heater 

wire consumes more than 7.1 watts per square foot of door opening, and DOE estimated that 

baseline display doors consume 15.2 watts per square foot of door opening. Therefore, baseline 

display doors already have an anti-sweat heater wire control system in order to comply with 

EISA. 

As explained previously, the walk-in cooler and freezer test procedure credits the 

manufacturer for having a control. The type or amount of controls does not change the credit nor 

increase the energy savings realized by the DOE test procedure. For these reasons, DOE did not 

include control systems as a design option. Additionally, DOE did not consider eliminating antiComment [A16]: Edits made per OIRA.

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sweat heater wire as a separate design option. The improvements made to the glass pack cause a 

reduction in the power draw of the anti-sweat heater wire. In the case of display cooler doors, the 

performance of the glass pack is improved enough so that anti-sweat heater wire is no longer 

required on the door. DOE also did not consider higher efficiency ballasts in its analysis because 

it found that electronic ballasts already incorporated into baseline units and DOE is not aware of 

more efficient ballasts. DOE requests comment on its analyzed design options and specifically

seeks any heat transfer data for the improved glass packs detailed in chapter 5 of the TSD. 

The design options that DOE analyzed in the engineering analysis for non-display doors 

include increasing the insulation thickness, changing the insulation material from baseline to a 

hybrid of polyurethane and VIP, changing the baseline framing material from wood to high 

density polyurethane, improving the window’s glass pack, and adding an anti-sweat heater wire 

controller to the door. These options are more fully described in chapter 5 of the TSD. DOE 

requests comment on the non-display door design options it analyzed, particularly with respect to

the cost of the window improvements detailed in chapter 5 of the TSD. 

American Panel suggested that DOE consider low cost methods for extending the 

envelope and door lifetimes. (American Panel, No. 0048.1 at p. 9) DOE has not considered 

options in this analysis that do not improve the rated performance of the equipment, as described 

in section IV.B.1. The purpose of the engineering analysis is to analyze the manufacturing cost 

and the performance of the covered equipment as rated by the test procedure. Examining 

methods to extend the life of walk-in equipment, including the impact of such methods on 

standards adopted by DOE, would complicate and create a significant impediment to completion 

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of this rulemaking, without any clear prospect that it would affect the standards DOE ultimately 

adopts. For this reason, DOE has decided not to pursue this issue.

After considering all the comments it received on the design options, DOE is including 

the following design options in the NOPR analysis for panels, display doors, and non-display 

doors: 

Panels

• Increased insulation thickness up to 6 inches

• Improved insulation material

• Improved framing material 

Display Doors

• Electronic lighting ballasts and highHigh-efficiency lighting

• Occupancy sensors

• Display and window glass system insulation performance

• Anti-sweat heater controls

• No anti-sweat systems

Non-Display Doors

• Increased insulation thickness up to 6 inches

• Improved insulation material

• Improved panel framing material 

• Display and window glass system insulation performance

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• Anti-sweat heater controls

• No anti-sweat systems

b. Refrigeration

In the preliminary analysis, DOE included the following design options for the walk-in 

refrigeration system:

• High-efficiency compressors

• Improved condenser coil

• High-efficiency condenser fan motors

• Improved condenser fan blades

• Improved evaporator coil

• Improved evaporator fan blades

• Evaporator fan controls

• Floating head pressure

• Defrost controls

The preliminary analysis contained tables detailing each design option, including the cost 

of implementing each option and a description of the design option’s properties. The discussion 

below sets forth comments received on these design options for refrigeration systems, as well as 

DOE’s proposed approach in today’s NOPR. 

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One option DOE considered was high-efficiency compressors. For example, DOE 

suggested using scroll compressors to represent the performance associated with higher 

efficiency compressors in walk-in applications. In response, Master-Bilt and Heatcraft 

commented that scroll compressors are not necessarily more efficient than other compressor 

types and are limited by their application and the prevalent conditions in which the compressor 

operates. (Master-Bilt, Public Meeting Transcript, No. 0045 at p. 1; Heatcraft, No. 0058.1 at p. 2) 

Heatcraft also stated that with increasing horsepower, fewer compressor types are available. 

(Heatcraft, No. 0069.1 at p. 1) The Joint Utilities added that for larger walk-in units, semihermetic compressors are more efficient than scroll types—except at low temperatures where, in 

their view, scroll compressors are more often utilized—but they did not provide information 

supporting the same. In addition, the Joint Utilities stated that hermetic compressors hold an 

added cost advantage over semi-hermetic compressors. (Joint Utilities, No. 0061.1 at pp. 6 and 

10) With regard to the types of compressors used in the food service market, American Panel 

suggested that hermetic compressors were dominant and stated that theirsemi-hermetic 

compressors’ high initial cost made them less prevalent generally. (American Panel, No. 0048.1 

at p. 9) 

DOE conducted additional research on available compressors and found that the 

prevalence of some compressor types varied at certain sizes. DOE also ensured that its analysis 

accounted for the effect that different applications and conditions may have on the relative 

efficiency of compressor types. In particular, the NOPR analysis includes an evaluation of a wide 

range of refrigeration capacities, and DOE has separately evaluated the different compressor 
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types available at each capacity point. DOE believes that this modified analysis adequately 

captures the performance of each compressor type at each size and set of operating conditions.

To obtain data on compressor performance, DOE’s preliminary analysis relied on 

manufacturer websites and related product specification sheets and did not consider the effect of 

the return gas conditions. The compressor data were based on return gas conditions under which 

the individual compressors were rated. The Joint Utilities stated that the return gas conditions 

were inconsistent with the typical operating conditions of walk-ins. (Joint Utilities, Public 

Meeting Transcript, No. 0045 at p. 27 and No. 0061.1 at p. 11) In consideration of the Joint 

Utilities’ comment, DOE investigated the effect of the return gas conditions on compressor 

performance and has updated the compressor characteristics using return gas conditions that are 

consistent with the rating conditions in AHRI 1250-2009, which are different from the rating 

conditions for individual compressors. The conditions are contained within AHRI 1250-2009 

itself, which DOE has incorporated into its test procedure. 76 FR at 33631. 

 

After considering the stakeholder comments and conducting further research, DOE 

expanded its initial compressor range beyond scroll compressors and hermetic compressors to 

now include semi-hermetic compressors in the list of compressor options in order to capture 

most of the market share. This was done specifically due to the varying compressor efficiencies 

at different operating temperatures, and the lack of availability of certain compressor types at all 

capacity ranges. For example, it is difficult to obtain hermetic compressors at capacities 

exceeding 30,000 Btu/h, so manufacturers may be more likely to use semi-hermetic compressors 

at these capacities as a lower-cost alternative to scroll compressors. 
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The preliminary TSD discusses the evaporator and condensing coil baseline and 

improved efficiency as coil size increases. In that analysis, DOE selected increased coil size as a 

design option because increasing the coil size corresponds to a drop in temperature difference, 

which would increase compressor capacity and result in lower normalized energy consumption. 

DOE received several comments about heat exchanger coil size and the associated 

savings. The Joint Utilities, Manitowoc and Heatcraft commented that the analysis did not 

consider an increase in fan power with an increase in coil size. (Joint Utilities, Public Meeting 

Transcript, No. 0045 at p. 27 and No. 0061.1 at p. 6; Manitowoc, No. 0056.1 at p. 2; Heatcraft, 

No. 0058.1 at pp. 2 and 3) American Panel stated that increasing condenser coil size would also 

require an increase in evaporator coil size, while Manitowoc suggested that the coil heat transfer 

equation should use log-mean temperature. (American Panel, No. 0048.1 at p. 6; Manitowoc, No. 

0056.1 at p. 2) 

After carefully considering these comments, DOE modified its analysis by increasing fan 

power proportionally to coil size. DOE found through its analysis, however, that as coil size 

increases, the decrease in compressor power far exceeds the increase in fan power, which 

ultimately decreases the net energy consumption. As a result, DOE retained increased coil size 

as a design option in its analysis. DOE agrees with Manitowoc’s comment that using log mean 

temperature difference is a more accurate way to calculate heat transfer because this method 

accounts for changes in air temperature and refrigerant temperature across the refrigerant coil 

rather than assuming that these temperatures are constant. DOE’s analysis had used a simplified 
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form of the heat transfer equations in the preliminary analysis, but now includes a log mean 

temperature difference in its analysis for the NOPR. In response to American Panel’s comment 

about requiring an increase in evaporator coil with condenser coil, DOE has taken a complete 

system modeling approach in analyzing the refrigeration system’s performance to capture any 

effects on the evaporator conditions from condenser coil changes. At this point, DOE believes 

that increasing the coil size of the condenser does not necessarily require an increase in coil size 

for the evaporator because the manufacturer would balance other aspects of the system to 

maintain the same capacity. DOE requests comment on this assumption, particularly from 

manufacturers who currently utilize larger condenser coils.

Condenser Fan Motors

In chapter 5 of the preliminary TSD, DOE discussed more efficient condenser fan motors 

as a viable design option. EPCA requires that walk-in condenser fan motors of less than 1 

horsepower must use permanent split capacitor motors, electronically commutated motors, or 

three-phase motors. (42 U.S.C. 6313(f)(1)(F)) Permanent split capacitor (PSC) motors are less 

expensive and less efficient than electronically-commutated (EC) motors and are currently used 

by the majority of manufacturers. DOE also assumed the same motor efficiencies for PSC and 

EC motors that were assumed in the ANSI/ARI Standard 1200-2006 -- that is, 29 percent and 66 

percent respectively. (The analysis did not considerscreened out three-phase motors as a design 

option forbased on utility to the reasonsconsumer, as explained in section IV.B.2.b, although 

manufacturers may still use this technology to improve the overall efficiency of the equipment 

they manufacture.)
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DOE received comments about the assumed efficiency of fan motors. Manitowoc 

commented that DOE’s assumed efficiency for PSC motors was too low and should be about 50 

percent, while Heatcraft stated that PSC motor efficiency would likely be between 45 and 55 

percent, three-phase motor efficiency would be approximately 80 percent, and EC motor 

efficiency would range from 60 to 90 percent. (Manitowoc, No. 0056.1 at p. 2; Heatcraft, No. 

0058.1 at p. 2 and No. 0069.1 at p. 2) The Joint Utilities suggested that the methodology of 

determining input power from efficiency ratings for small motors was inaccurate. (Joint Utilities, 

No. 0061.1 at p. 8) Heatcraft provided a list of parts to be added to the engineering analysis. 

(Heatcraft, No. 0069.1 at p. 1) 

DOE has considered the suggestions of Manitowoc and Heatcraft regarding motor 

efficiency and has changed its assumptions for PSC motors to 50 percent and EC motors to 75 

percent after researching currently available motors. Additionally, regarding comments received 

from Heatcraft about three-phase motors, DOE did not include three-phase motors as a design 

option or as part of the design of smaller baseline equipment due to adverse utility to the 

consumer and impracticability to manufacture, install and service, because many consumers do 

not have three-phase power sources; however, DOE assumed that larger baseline equipment 

would use three-phase motors. See section IV.B.2.b for more details. DOE also included in its 

analysis the fan motor parts Heatcraft identified after evaluating teardown data and conducting 

further analysis of those parts. In response to the Joint Utilities’ comment that DOE should not 

determine input power from efficiency ratings, DOE has used this method as its best estimate for 

motor power consumption. DOE has not identified a more accurate methodology for determining 

input power and requests feedback on this issue. 
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 Chapter 5 of the preliminary TSD presented several fan blade options for the evaporator 

and condenser fan blade design option. Responding to these options, Heatcraft suggested the 

inclusion of swept fan blades as they are more aerodynamic and reduce vibrations and noise that 

result in inefficiencies. In addition, it also suggested that motor efficiency is independent from 

fan blade efficiency because more efficient fan blades do not result in high efficiencies for 

motors and vice versa. Rather, the efficiency of each component is due to its own intrinsic 

characteristics. After considering Heatcraft’s comment, DOE is continuing to treat the motor and 

fan blade options separately.

The preliminary analysis examined evaporator fan controls as a design option. The 

impacts of fan controls were analyzed consistent with the test procedure requirement that 

“controls shall be adjusted so that the greater of a 25 percent duty cycle or the manufacturer 

default is used for measuring off-cycle fan energy. For variable-speed controls, the greater of 25 

percent fan speed or the manufacturer’s default fan speed shall be used for measuring off-cycle 

fan energy.” Because of this requirement, DOE set a 75 percent reduction in off-cycle fan energy 

as the energy savings achieved for the fan control technology option. DOE did not differentiate 

between modulated fan controls and variable speed fan controls in the preliminary analysis. DOE 

received comments both on its characterization of the fan control design option and on the 

energy results for that design option. NEEA and NPCC expressed concern that DOE’s analysis

caused the evaporator fan control option to appear less cost-effective compared to other design 

options, possibly indicating that DOE underestimated its potential energy savings. (NEEA and 

NPCC, No. 0059.1 at p. 7) The Joint Utilities cited studies indicating that fan speed control is 
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one of the most, if not the most, cost-effective design option for many refrigeration systems. 

(Joint Utilities, Public Meeting Transcript, No. 0045 at p. 28; No. 0061.1 at pp. 2 and 6) The 

Joint Utilities also criticized DOE’s initial approach of not distinguishing between fan cycling 

and fan speed control. They indicated that the approach taken by DOE overly simplified the 

analysis, which then yielded considerably smaller projected savings for multiplex systems. 

Because of the complexity of the size ranges and system variations of these units, a more 

detailed analysis than the single design option used in the preliminary analysis is, in their view, 

required to sufficiently evaluate the potential energy savings from using a fan control system. 

They recommended that an analysis of fan speed controls include the benefit of operating at 

reduced fan speeds for the majority of the time the system operates. (Joint Utilities, No. 0061.1 at 

pp. 6 and 9) NEEA and NPCC agreed with DOE’s approach insofar as fan controls that adjust 

envelope interior temperature conditions should be applied to every walk-in. (NEEA and NPCC, 

No. 0059.1 at p. 7)

Some interested parties also cautioned DOE about the unintended consequences of 

implementing different types of fan controls. The Joint Utilities stated that a fan duty-cycling 

control strategy would be unacceptable in many applications because of the increased likelihood 

of uneven temperatures and the related concern for perishable products. (Joint Utilities, No. 

0061.1 at p. 9) Zero Zone stated that variable speed evaporator fan motors could prevent the 

walk-in from maintaining the desired product temperature. (Zero Zone, No. 0051.1 at p. 1) 

American Panel stated that if fan controls cause the compressor to run for longer periods, energy 

consumption will increase because the compressor draws more power than the fans. American 

Panel also recommended that DOE ensure that whatever standards it may propose, that air 
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defrost evaporators still be able to defrost ice build-up on refrigeration coils during off-cycle 

periods using lower fan speeds. (American Panel, No. 0048.1 at p. 7) 

One interested party commented on DOE’s assumed cost of the fan control option. The 

Joint Utilities stated that the assumed cost of $300 for fan control would likely be lower, 

particularly for small walk-ins, because the EC motors have inherent variable speed capability 

and the microcontrollers used to control these motors can provide the required voltage signal to 

control the EC motors. (Joint Utilities, No. 0061.1 at p. 9)

 To address these concerns, DOE has made several changes to its fan control analysis. 

DOE is now considering both modulated (fan cycling) and variable speed controls as potential 

design options. Modulated fan controls cycle the fans at 50 percent runtime at 100 percent speed 

when the compressor is off, while variable speed controls set the fan speed to 50 percent of 

maximum speed at 100 percent runtime when the compressor is off. DOE’s analysis applies the 

commonly used fan power laws, which describe the relationship between power and speed 

during a fan’s operation. A reduction in fan speed causes a reduction in fan power to the third 

power. For example, reducing speed to 50 percent of full speed reduces the power to 12.5 

percent of full power. Thus, variable speed controls would be expected to save more energy than 

modulated fan controls for the particular control strategies analyzed. 

DOE applied both modulated fan controls and variable speed fan controls as a design 

option for all classes analyzed. DOE did not, however, consider controls that respond to specific 

box conditions because, as stated in the test procedure final rule, the impact of these controls 
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would not be captured using the component-level approach, which analyzes refrigeration systems 

separately from envelope components. DOE notes that, as a result of the enhancements made to 

its analytical approach, the NOPR analysis indicates that modulated and variable speed fan 

controls would likely be among the primary options to improve walk-in refrigeration system 

efficiency.

DOE appreciates the concerns about fan controls raised by American Panel, the Joint 

Utilities, and Zero Zone. To address American Panel’s comment about compressor runtime, 

DOE does not expect compressor runtime to increase from the inclusion of fan control 

implementation because fan speed or cycling controls are activated only when the compressor is 

off. Also, DOE’s research does not indicate that air defrost would be adversely affected by fan 

controls. Therefore, air defrost would likely still be adequate with reduced fan speed. DOE is 

aware of To address commenters’ concerns about the potential effects of fan controls on food 

safety, butDOE estimates that the outcome of using such controls would be equivalent to an 

overall 50 percent decrease in runtime (for a cycle control) or a 50 percent decrease in speed (for 

a variable-speed control) and has tentatively concluded that the impact of the controls it analyzed 

will be limited (to 50 percent fan cycling or 50 percent fan speed when the compressor is off) 

and not affect the maintenance of safe food temperatures. See chapter 5 for details. DOE requests 

comment from interested parties as to whether food temperatures would be adequately 

maintained in the specific control cases it has analyzed and, if not, what an appropriate control 

strategy would be. DOE seeks any data that interested parties can provide to show the 

relationship between fan controls and food temperatures. DOE also seeks information as to 

whether additional components are necessary to ensure food temperature, such as extra 

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thermostats located in certain areas of the walk-in. To address American Panel’s comment about 

compressor runtime, DOE does not expect compressor runtime to increase from the inclusion of 

fan control implementation because the fans run at full speed while the compressor is running 

and fan speed or cycling controls are activated only when the compressor is off. DOE also does 

not expect controls to increase the amount of time the compressor is off because the compressor 

cycles on based on the walk-in’s interior temperature, which DOE believes will not be 

significantly affected by the fan control strategy modeled in the analysis. 

Defrost Controls

In the preliminary analysis, DOE evaluated several defrost control options available in 

the market. DOE considered using time-initiated, time-terminated defrost as the baseline. The 

design option involved a generic defrost control that would result in half as many defrosts per 

day. Heatcraft and American Panel doubted whether existing defrost controls could achieve the 

50 percent reduction in defrosts assumed in the preliminary analysis. (American Panel, No. 

0048.1 at p. 7; Heatcraft, No. 0058.1 at p. 4) In addition, Heatcraft, American Panel and the Joint 

Utilities suggested DOE replace time termination with temperature termination in the base case. 

(Heatcraft, No. 0058.1 at p. 4; American Panel, No. 0048.1 at p. 7; Joint Utilities, Public Meeting 

Transcript, No. 0045 at p. 26) Heatcraft and the Joint Utilities also noted that defrost time should 

be dependent on system size to account for the greater surface area of larger units and suggested 

that the baseline defrost control strategy be a time-initiated, temperature-terminated scheme, 

which is the industry standard. (Heatcraft, No. 0058.1 at pp. 3-4; Joint Utilities, No. 0061.1 at p. 

3) 
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In response to comments received about defrost control, DOE’s analysis now applies a 

temperature-terminated defrost approach for all defrost control schemes (baseline or higher). The 

defrost cycle ends once the coil temperature reaches 45 °F. For the defrost design option, DOE is 

continuing to apply a generic defrost control that would reduce the number of defrosts per day. 

The magnitude of the reduction is set at 40 percent, which is less than the 50 percent level 

originally assumed in the preliminary analysis. DOE chose this reduced level because it would 

result in significant energy savings while still maintaining adequate defrost capability. Further 

details about the defrost control parameters are found in chapter 5 of the TSD. 

Floating Head Pressure

In the preliminary analysis, DOE also considered floating head pressure as a design 

option. With floating head pressure, the compressor pressure and the saturated condensing 

temperature (SCT) float down to the minimum level at which the compressor can operate. DOE 

assumed that floating head pressure would allow the SCT to float down to 70° F. DOE also 

assumed that the SCT would decrease at the same rate as the ambient temperature such that the 

system would maintain the same temperature difference (TD) between the SCT and the ambient 

air. This change resulted in a predicted reduction in energy consumption because compressors 

generally run more efficiently at a lower SCT. The capacity of the system was related to the SCT 

and the TD. 

Some interested parties commented on DOE’s assumptions relating to floating head 

pressure. Heatcraft disagreed with DOE’s assumption that the TD would be constant as SCT 

decreases and stated that the TD increases as SCT decreases. To illustrate its point, Heatcraft 
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calculated the TD of a system at an SCT of 115 °F and again at an SCT of 70 °F and found that 

the ratio of the condenser TD between these two SCT conditions would be approximately 1.19, 

not 1.0 (where a ratio of 1.0 would correspond to no change in TD as SCT decreases). This value 

was calculated using the total heat of rejection (THR) of the condenser. (Heatcraft, No. 0058.1 at 

p. 4) The Joint Utilities had several comments relating to the implementation of floating head 

pressure. They recommended that DOE account for the additional fan power required for floating 

head pressure, and stated that varying the speed of condenser fans as part of a floating head 

pressure control has effects on the system such as more stable operation of the expansion valve 

and less likelihood of compressor damage due to liquid refrigerant reaching the compressor. 

(Joint Utilities, No. 0061.1 at pp. 6 and 10) The Joint Utilities also identified two different head 

pressure control types that have an impact on projected energy savings: fan control or fan cycling 

and a condenser valve to maintain the minimum condensing temperature. (Joint Utilities, No. 

0061.1 at p. 10) Finally, the Joint Utilities pointed out that if a lower initial or baseline SCT 

value is assumed, the estimated savings for floating head pressure will be less. (Joint Utilities, 

No. 0061.1 at p. 10)

To account for the suggestions made by commenters, DOE has implemented changes to 

its NOPR analysis of floating head pressure. First, DOE investigated the control methods 

identified by the Joint Utilities. In the current model used for the NOPR analysis, fan modulation 

is implemented in the baseline to maintain a fixed head pressure. When floating head pressure is 

implemented, a valve and accompanying controls are added to maintain a minimum condensing 

temperature. Regarding the comments on fan power submitted by the Joint Utilities, DOE agrees 

that at lower ambient temperatures, the required fan airflow is higher when floating head 
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pressure is implemented because the TD is smaller. DOE’s current energy model calculates the 

fan power necessary to maintain adequate heat transfer when floating head pressure is 

implemented. DOE assumed that condenser fans would be modulated in the baseline; variable 

speed condenser fans are considered as a separate design option. DOE’s model calculates the 

energy savings of variable speed condenser fans with or without floating head pressure 

implemented. The energy model does not capture increased stability in the expansion valve or 

the reduced possibility of compressor damage because the energy model attempts to capture the 

performance as rated by the test procedure, and for the reasons stated in the test procedure final 

rule, the test procedure recently established by DOE is designed to rate only certain aspects of 

the equipment -- e.g., AWEF and capacity. 76 FR 21580, 21597-21598 (April 15, 2011).

DOE also assumes that a system tested by the manufacturer would likely be a new 

system, which is unlikely to experience decreased stability in the expansion valve; therefore, 

DOE did not capture expansion valve stability in the energy model. The energy model also does 

not capture long-term compressor damage because DOE assumes the test procedure would be 

performed at the point of manufacture of the equipment, and would therefore not capture such

damage to the compressor. Compressor replacement is, however, addressed in the life cycle cost 

analysis (see section IV.F.6). Any additional benefits that accrue due to reduced maintenance are 

also not captured in the engineering analysis. 

DOE also acknowledges the Joint Utilities’ observation that the savings for the floating 

head pressure option depends on the baseline SCT and DOE’s energy modeling confirms their 

assertion that the floating head pressure option would appear to save less energy if the baseline 
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SCT were lower. However, DOE chose certain baseline SCT values for each class that would be 

realistic considering the equipment rating conditions, as explained in section IV.C.4.b. To 

address Heatcraft’s comment that TD would increase with decreasing SCT, DOE analyzed the 

total heat of rejection of sample systems using the specified temperatures in the test procedure

and found an average TD ratio corresponding to each compressor type analyzed. DOE 

implemented the TD ratio in the engineering analysis. See chapter 5 of the TSD for more details 

on the floating head pressure design option. DOE requests comment on its assumptions and 

implementation of this option, particularly regarding the cost to implement various floating head 

pressure control schemes and the energy savings that would be achieved.

Refrigeration Summary

After considering all the comments it received on the design options, DOE is including 

the following design options in the NOPR analysis:

• Higher efficiency compressors

• Improved condenser coil

• Higher efficiency condenser fan motors

• Improved condenser and evaporator fan blades

• Ambient sub-cooling

• Evaporator and condenser fan control 

• Defrost control

• Hot gas defrost

• Head pressure control

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Each design option is explained in detail in chapter 5 of the TSD.

4.6. Cost-Efficiency Results

a. Panels and Doors

In the preliminary analysis, DOE plotted total energy consumption in kilowatt-hours per 

day versus the increasing cost of representative walk-in envelopes. Because DOE is proposing to 

set component level standards, each of the three main products that make up walk-in envelopes 

have independent cost-efficiency curves. For panels, DOE measured the U-factor, a measure of 

thermal conductivity expressed in British thermal units per hour-square foot-Fahrenheit (Btu/hftft2

-F); that is, the heat conducted through the panel per unit time, per square foot of panel 

thicknesssurface area, per degree Fahrenheit. A lower U-factor corresponds to less heat 

conducted through the panel, indirectly decreasing the energy use of the walk-in because the 

refrigeration system does not have to expend additional energy to remove heat from the walk-in. 

DOE plotted the decrease in U-factor versus the increase in cost of a single panel. For nondisplay doors and display doors, DOE plotted energy consumption in kWh/day versus the 

increasing cost of an individual non-display door. For a more detailed description of the 

engineering analysis results, see appendix 5A of the TSD. 

b. Refrigeration

In the preliminary analysis, DOE chose refrigeration system sizes that best represented 

the market, but did not attempt to match the refrigeration systems to any particular envelope in 

the engineering analysis. DOE received several comments on the preliminary analysis regarding 

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matching the refrigeration system to the envelope size. American Panel suggested that, because 

of their interdependence, refrigeration and walk-in size should be analyzed together. (American 

Panel, Public Meeting Transcript, No. 0045 at p. 115) NEEA, NPCC, Heatcraft, and American 

Panel recommended that the refrigeration system size match the envelope size. (NEEA and 

NPCC, No. 0059.1 at p. 9, Heatcraft, No. 0069.1 at p. 1, American Panel, No. 0048.1 at p. 4)

DOE is proposing to regulate the refrigeration system as an individual component in 

accordance with its proposed component-level approach, and is also analyzing the individual 

components of an envelope (panels and doors), rather than the entire envelope. For these reasons, 

DOE did not attempt to match refrigeration systems with any particular envelope size. Rather, 

DOE chose refrigeration system sizes for the analysis that capture the range of systems that 

might be used in a walk-in. 

In the preliminary analysis, DOE plotted the cost-efficiency data points using normalized 

energy consumption for its engineering analysis. AHRI recommended using AWEF and 

commented that the normalized values favor design options, which, in its view, do not 

necessarily reduce energy consumption. The Joint Utilities believed that non-normalized values 

would be helpful to understand the analyses,.. (AHRI, No. 0055.1 at pp. 2–3; Joint Utilities, 

Public Meeting Transcript, No. 0045 at p. 171) Consistent with the test procedure final rule and 

AHRI’s suggestion, DOE is using AWEF to construct its cost-efficiency curves. See 76 FR 

21597-21598, 10 CFR 431.302.
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In chapter 5, Appendix A of the preliminary TSD, DOE provided cost-efficiency curves 

for all the equipment classes. Numerous stakeholders requested that DOE provide more detail 

about the methodology behind the cost efficiency curves because they are concerned about the 

accuracy of these curves. (Emerson, Public Meeting Transcript, No. 0045 at p. 165; AHRI, 

Public Meeting Transcript, No. 0045 at p. 169 and No. 0055.1 at p. 2,4; Manitowoc, No. 0056.1 

at p. 2 and Public Meeting Transcript, No. 0045 at p. 125) Additionally, Manitowoc suggested 

that a broader view of the industry’s costs and sizes is required to improve the accuracy of the 

results (Manitowoc, Public Meeting Transcript, No. 0045 at p. 162)

DOE appreciates the stakeholder comments and notes that it has updated its initial costefficiency curves based on changes to its analysis. Notably, DOE alteredhas provided more 

detail in this NOPR and the NOPR TSD about the calculation methodology used in the 

engineering analysis, particularly due to the publication of the test procedure final rule. DOE also 

updated its analysis to account for newwith the most recent pricing data related to the costs of 

materials and purchased parts and adjusted the projected energy savings of certain design options 

as detailed in section IV.C.5.b. 

c. Numerical Results

Table IV-8, Table IV-9, Table IV-10, and Table IV-11 present cost-efficiency data for 

panels, display doors, non-display doors, and refrigeration systems, respectively. For 

refrigeration systems, because of the large number of analysis points, DOE presents results for 

only one classtype of system, DC.L.O, in this notice. See appendix 5A of the TSD for complete 

cost-efficiency results.

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Table IV-8 Cost-Efficiency Results for Panels

XXXV. XXXVI. Efficiency Level

Class/Size

Baselin eBaseline

1 2 3 4 5 6 

SP.M.SML

Cost [$]

$55.805

4

$59.465

8

$65.196

1

$71.836

7

$78.167

3

$93.0486

$237.9723 1

U-factor 

[Btu/h-ft-F] 0.082 0.046 0.040 0.032 0.027 0.024 0.011

SP.M.MED

Cost [$]

$159.19

153

$163.83

159

$178.95

165

$194.69

179

$209.53

192

$248.1222 9$634.6061 5

U-factor 

[Btu/h-ft-F] 0.061 0.043 0.038 0.030 0.025 0.024 0.011

SP.M.LRG

Cost [$]

$249.39

240

$255.03

247

$278.37

256

$302.13

276

$324.45

296

$383.8135 4$981.6495 1

U-factor 

[Btu/h-ft-F] 0.056 0.042 0.037 0.030 0.025 0.024 0.011

SP.L.SML

Cost [$]

$61.015

6

$65.196

1

$71.836

7

$78.167

3

$93.048

6

$237.9723 1 - 

U-factor 

[Btu/h-ft-F] 0.073 0.040 0.032 0.027 0.024 0.011 - 

SP.L.MED

Cost [$]

$173.64

159

$178.95

165

$194.69

179

$209.52

192

$248.11

229

$634.5961 5 - 

U-factor 

[Btu/h-ft-F] 0.053 0.038 0.030 0.025 0.024 0.011 - 

SP.L.LRG

Cost [$]

$271.93

249

$278.37

256

$302.13

276

$324.45

296

$383.81

354

$981.6495 1 - 

U-factor 

[Btu/h-ft-F] 0.050 0.037 0.030 0.025 0.024 0.011 - 

FP.L.SML

Cost [$]

$92.648

5

$103.73

93

$111.34

97

$119.80

104

$127.83

111

$285.8027 0 - 

U-factor 

[Btu/h-ft-F]

0.07507 10.04204 10.03703 6 0.030 0.02602 5 0.018 - 

FP.L.MED

Cost [$]

$192.48

176

$211.59

190

$226.71

195

$242.45

209

$257.29

222

$600.5556 6 - 

U-factor 

[Btu/h-ft-F]

0.06105 90.04103 90.03603 5 0.029 0.02502 4 0.016015 - 

FP.L.LRG

Cost [$]

$329.52

301

$359.77

322

$385.22

331

$411.01

353

$435.24

374

$1,032.40

973 - 

U-factor 

[Btu/h-ft-F]

0.05605 40.04003 9 0.035 0.02902 8 0.024 0.014 - 

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20131002_OIRA compare document dated 9-26.docx

Table IV-9 Cost-Efficiency Results for Display Doors

XXXVII. XXXVIII. Efficiency Level

Class/

Size Baseline 1 2 3 4 5 6 

DD.M. 

SML

Cost [$] $261.702

77

$324.072

74

$443.603

40

$557.934

23

$636.515

44

$793.667

10

$1,423.61

375

Energy Use 

[kWh/day] 3.532.50 2.421.74 1.320.98 0.841.08 0.9268 0.8058 0.5338

DD.M.

MED

Cost [$] $337.783

57

$400.153

54

$519.694

20

$634.025

30

$737.956

51

$945.838

70

$1,779.09

751

Energy Use 

[kWh/day] 4.082.91 2.6215 1.5214 1.280.96 1.070.80 0.9166 0.5540

DD.M.L

RG

Cost [$] $445.054

70

$507.414

78

$689.315

44

$803.646

92

$943.338

13

$1,222.71

108

$2,342.62

291

Energy Use 

[kWh/day] 5.263.76 3.292.78 1.8843 1.6118 1.320.99 1.100.81 0.6246

DD.L. 

SML

Cost [$] $481.225

09

$638.375

06

$757.916

27

$916.407

93

$1,030.73

960

$1,423.61

375 -

Energy Use 

[kWh/day] 6.325.22 4.6534 3.554.14 2.6873 2.4402 2.011.66 -

DD.L.M

ED

Cost [$] $608.026

43

$815.906

40

$935.437

61

$1,145.07

980

$1,259.40

202

$1,779.09

751 -

Energy Use 

[kWh/day] 7.816.47 5.5758 4.475.39 3.3249 3.082.56 2.5108 -

DD.L. 

LRG

Cost [$] $786.798

31

$1,066.18

839

$1,248.08

135

$1,529.83

432

$1,644.16

553

$2,342.62

291 -

Energy Use 

[kWh/day] 10.308.54 7.2740 5.854.83 4.303.57 4.043.36 3.262.70 -

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20131002_OIRA compare document dated 9-26.docx

Table IV-10 Cost-Efficiency Results for Non-Display Doors

XXXIX. XL. Efficiency Level

Class/Size Baselin

e 1 2 3 4 5 6 7 8 

9

PD.M.SM

L 

Cost [$]

$189.87

180

$193.35

184

$217.60

210 $214 $222.11

$231.14273$279.64281

$474.02

487

$483.05

655

$646.01 -

Energy 

Use 

[kWh/da

y]

0.30130 0.26927 0.22122 0.21522 0.20721 0.16717 0.04216 0.03704 0.02802-

PD.M.ME

D 

Cost [$]

$223.31

210

$227.19

214

$251.44

240

$257.07

245

$268.33

255 $306 $316.83 $328.09 $522.47

$735.09

741

-

Energy 

Use 

[kWh/da

y]

0.32032 0.28528 0.23624 0.22923 0.21822 0.17818 0.17117 0.04605 0.03403-

PD.M.LR

G 

Cost [$]

$286.47

265

$290.95

270

$315.19

296

$322.89

303

$338.29

316

$386.78368$402.18381

$596.56

587

$903.75

904

-

Energy 

Use 

[kWh/da

y]

0.35536 0.31431 0.26527 0.25425 0.23924 0.19920 0.18819 0.06306 0.04504-

PD.L.SML

Cost [$]

$242.38

235

$246.36

240

$294.85

291

$343.76

342

$352.79

351

$361.82359$424.18425

$545.41

553

$618.13

728

-

Energy 

Use 

[kWh/da

y]

7.08 6.96 6.52 6.26 6.23 6.20

6.15

6.07 6.0401 5.98-

PD.L.ME

D 

Cost [$]

$276.88

265

$281.32

270

$329.81

322

$378.71

373

$389.98

383

$401.24393$463.60459

$584.84

587

$679.62

814

-

Energy 

Use 

[kWh/da

y]

7.82 7.69 7.25 6.99 6.95 6.92 6.8679 6.7872 6.7367-

PD.L.LRG

Cost [$]

$342.02

322

$347.14

328

$395.63

380

$444.54

431 $445 $459.93

$475.33524

$537.69

653

$658.92

978

$795.72 -

Energy 

Use 

[kWh/da

9.03 8.88 8.43 8.18 8.11 8.07 8.017.94 7.9388 7.8579-

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20131002_OIRA compare document dated 9-26.docx

y]

FD.M.SM

L 

Cost [$]

$372.36

356

$377.44

362

$401.68

388

$413.73

398

$437.83

417

$486.33469$680.71489

$704.81

694

$1,109.

00119

-

Energy 

Use 

[kWh/da

y]

0.39339 0.34635 0.29730 0.28328 0.26126 0.22222 0.09721 0.08208 0.05805-

FD.M.ME

D 

Cost [$]

$599.01

574

$605.27

581

$648.38

647

$666.80

662

$703.63

692

$789.84738$1,135.41768 $860 $1,172.

24225

$1,814.

44899

Energy 

Use 

[kWh/da

y]

0.65465 0.59660 0.50646 0.48344 0.45040 0.37636 0.15234 0.13031 0.09125 0.19

FD.M.LR

G 

Cost [$]

$754.42

719

$761.88

727

$804.99

793

$829.25

813

$877.77

853

$963.98898 $938 $1,309.

55029

$1,358.

08394

$2,217.

25296

Energy 

Use 

[kWh/da

y]

0.73373 0.66366 0.57353 0.54249 0.49845 0.42441 0.19938 0.17035 0.11729 0.21

FD.ML.S

ML

Cost [$]

$432.18

416

$437.98

423

$486.47

474

$535.38

526

$559.48

546

$575.26566$637.63632

$821.19

760

$942.42

1,194

-

Energy 

Use 

[kWh/da

y]

10.325 10.108 9.63 9.38 9.29 9.23 9.1710 9.0503 8.9792-

FD.ML.M

ED

Cost [$]

$702.74

679

$709.90

688

$772.26

753

$858.47

845

$895.30

875

$919.04905$1,005.98997 $1,297.

35225

$1,512.

87911

-

Energy 

Use 

[kWh/da

y]

13.771 13.549 12.958 12.313 12.211.

99 12.111.90 11.

867 11.655 11.535-

FD.ML.L

RG

Cost [$]

$863.83

828

$872.35

838

$934.72

904

$1,020.

93995

$1,069.

45035 $1,100.52075 $1,187.46167 $1,577.11394

$1,792.

642,310

-

Energy 

Use 

[kWh/da

y]

15.662 15.436 14.745 14.200 14.013.

81 13.

969 13.645 13.334 13.206-

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20131002_OIRA compare document dated 9-26.docx

Table IV-11 Cost-Efficiency Results for Refrigeration Systems

XLI XLII Efficiency Level

Cla

ss/ 

Size

Ba

se-

line

1 2 3 4 5 6 7 8 9 10 11 12

13

DC.

L.O.

,HE R.*,

006

6 

kBt u

Cost 

[$]

$15

06.6 81,

591

$1531.681,

616

$15

56.6 81,

641

$15

86.6 81,

671

$16

54.8 81,

745

$16

83.1 71,

749

$17

42.2 21,

760

$17

53.1 81,

798

$1992.291,848

$19

99.0 81,

898

$20

99.0 82,

058

$214

9.08-

$229

2.07-

AW

EF 

[Btu/

W-h]

2.40 2.62 2.812.973.303.313.343.43 3.56 3.623.65

--

DC.

L.O,

HE

R,

9 

kBt u

Cost 

[$]

$1,

720$1,745 $1,

770

$1,

800

$1,

876

$1,

881

$1,

919

$1,

969 $1,980 $2,144

$2,

194

--

AW

EF 

[Btu/

W-h]

2.5

91

2.72

3.10

2.93

3.11

27

3.473.6

86

3.9

87

3.94

96

4.52

07 4.5409 4.7138

4.79

44

4.87-

-

DC.

L.O.

HE

R., 

SCR,

009

6 

kBt u

Cost 

[$]

$16

02.5

1,8

38

$1655.81,8

63

$16

80.8

1,8

88

$17

05.8

1,9

18

$17

35.8

1,9

92

$17

65.8 61,

996

$18

44.6 12,

034

$21

15.1 42,

084

$2126.12,095

$21

32.8 92,

250

$22

32.8 92,

300

$228

2.89-

$242

5.88-

AW

EF 

[Btu/

W-h]

2.9

786 3.4114 3.6539

3.86

70

4.074.26

09

4.68

24

5.41

4.44

5.454.48

5.47

4.79

5.62

4.89

5.69-5.77-

DC.

L.O.

,SCR.,

009

9 

kBt u

Cost 

[$]

$17

81.5 51,

944

$1811.551,

969

$18

36.5 51,

999

$18

61.5 52,

024

$19

34.8 52,

100

$20

10.6 82,

105

$20

60.3 62,

143

$20

71.3 22,

193

$2078.112,204

$25

25.1 52,

381

$26

25.1 52,

531

$26

75.1 52,

581

$282

5.15-

$2968.14

AW

EF 

[Btu/ W-h]

3.8

570 4.213.98 4.5635

4.87

64

5.38

11

5.91

13

6.14

5.28

5.48 5.52 5.866.18

15

6.2

25

7.12-

7.39 7.5 7.75 7.9

DC.

L.O.

,SCR.,

Cost 

[$]

$49

94.6 36,

93

$5024.636,

968

$50

74.6 37,

018

$51

24.6 37,

068

$52

40.2 77,

188

$52

90.2 77,

288

$54

41.6 67,

312

$55

41.6 67,

362

$5586.027,512

$57

36.0 27,

594

$58

18.2 210

,31

$71

80.7 710

,33

$74

79.4 311

,06

$7513.39

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164 

20131002_OIRA compare document dated 9-26.docx

054

54 

kBt u

8272

AW

EF 

[Btu/

W-h]

4.1

809 4.5544 4.92

5.04

38

5.52

93

6.09

27

6.22

34

6.46

43 6.

658 6.66

64

6.81

7.77

6.87

7.78

7.95

91

8.1 8.11

DC.

L.O.

,SE M.,

006

6 

kBt u

Cost 

[$]

$19

62.5

2,0

95

$1987.52,1

20

$20

12.5

2,1

45

$20

55.0 82,

175

$20

85.0 82,

248

$21

58.0 82,

253

$21

69.0 42,

291

$21

75.8 42,

341

$2246.652,352

$22

96.6 52,

402

$23

96.6 52,

555

$303

3.96-

$317

6.94-

AW

EF 

[Btu/

W-h]

2.5

747 2.8169

3.03

2.90

3.36

15

3.57

48

3.93

50

3.96

60

3.97

74 4.133.77 4.2

3

.84

4.34

3.93

5.01- 5.1

-

DC.

L.O.

,SE M.,

009

9 

kBt u

Cost 

[$]

$21

07.4 12,

270

$2136.532,

295

$21

61.5 32,

320

$21

86.5 32,

350

$22

16.5 32,

426

$22

95.2 82,

430

$23

73.4 12,

468

$23

84.3 72,

518

$2391.162,666

$24

91.1 62,

677

$25

41.1 62,

727

$324

4.34-

$338

7.33-

AW

EF 

[Btu/ W-h]

2.8

778 3.352.96 3.5812

3.79

40

3.773.783.863.96 4.0428 4.46

30

4.64

36

4.67-4.68-

4.79 4.85 5.65 5.72

DC.

L.O.

,SE M.,

054

54 

kBt u

Cost 

[$]

$58

70.5 27,

776

$5875.797,

806

$59

25.7 97,

856

$59

55.7 97,

906

$60

05.7 98,

006

$60

61.3 98,

129

$61

11.3 98,

208

$62

69.0 68,

258

$6319.068,340

$65

15.1 511

,254

$65

97.3 511

,720

$83

62.2 211

,804

$843

8.63-

AW

EF 

[Btu/

W-h]

3.5

436 3.8763

4.23

3.99

4.46

32

4.85

74

5.04

24

5.22

36

5.75

43 5.8747 6.

1

37

6.15

52

7.08

6.54

7.1-

DC.

L.O.

,SE M.,

072

72 

kBt u

Cost 

[$]

$73

53.1 29,

772

$7383.129,

802

$74

27.1 39,

877

$75

02.1 39,

952

$75

77.1 310

,075

$77

29.1 510

,175

$77

90.3

10,

225

$78

40.3

10,

304

$78

90.3

10,

427

$81

50.51

$82

73.81

$10

615. 7

$10

692.

11,

091

$13

,999

$14

,083

-

AW

EF 

[Btu/ W-h]

3.5

441 3.8470 4.

1

11

4.57

50

5.01

4.96

5.5

36

5.68

44

5.86

53 5.9958 5.79

6.22

71

6.28

72

7.23-

7.24

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165 

20131002_OIRA compare document dated 9-26.docx

*HER indicates a hermetic compressor, SCR indicates a scroll compressor, and SEM indicates a semi-hermetic 

compressor.
166 

20131002_OIRA compare document dated 9-26.docx

A.D. Markups Analysis 

This section explains how DOE developed the distribution channel and supply 

chain markups to determine installed costs for the end-users of refrigeration systems and 

envelope components. 

In the preliminary analysis, DOE described different distribution channels for the 

two broadly defined segments of the WICF market: the food sales (grocery) segment and 

the food service segment. for the purposes of calculating markups. In the food sales 

segment, the refrigeration systems are predominantly unit coolers connected to multiplex 

condensing systems. In the food service and convenience store market segment, the 

refrigeration systems are mostly dedicated condensing systems. DOE acknowledged that 

walk-in units may also be assembled in the field, with key components sourced from 

different vendors through different channels. However, in the preliminary analysis, DOE 

conducted the markups analysis on complete walk-in systems and did not apply separate 

markups for different components. Consequently, DOE assumed in the preliminary 

analysis that the refrigeration system and the envelope followed identical distribution 

channels even if they were manufactured by a different set of manufacturers. 

One interested party recommended that DOE include an additional distribution 

channel. Heatcraft commented that the refrigeration system manufacturers often sell 

directly to the envelope manufacturers, who integrate the refrigeration systems with the 

envelopes and then sell the assembled units. (Heatcraft, Public Meeting Transcript, No. 

0045 at p. 187) Heatcraft identified this market segment as OEMs and observed that this 

Formatted: Don't swap indents on facing

pages
167 

20131002_OIRA compare document dated 9-26.docx

important channel of distribution was not considered by DOE, even though 50 percent of 

the refrigeration system business is distributed through the OEM market segment. 

The revised NOPR analysis uses component-level standards for specific envelope 

components and for the refrigeration systems. Because of this component-level standards 

approach, DOE conducts all the key analysis steps separately for the refrigeration 

systems and the selected envelope components in the NOPR analysis. As part of this 

approach, DOE includes a distinct OEM distribution channel in the markup analysis. 

Based on interviews with several manufacturers, DOE estimates that the percentage share 

of the aggregate shipments of refrigeration systems attributable to the OEM segment of 

the market is 55 percent for all dedicated condensing refrigeration systems, similar to the 

50 percent share indicated by Heatcraft.

Another interested party commented on the relative shares of the different market 

segments DOE identified. In the preliminary analysis, DOE estimated that for walk-ins 

with dedicated condensing units, 50 percent of aggregate sales were for the food service 

segment and the remaining 50 percent were for the convenience and small grocery stores 

segment. American Panel commented that for walk-in equipment sold with dedicated 

condensing equipment, the share of the food service segment across the two broad market 

segments should be 80 percent and the share of the convenience and small grocery stores 

segment should be 20 percent. (American Panel, No. 0048.1 at p. 8) In the NOPR, DOE 

revised its shipment analysis as described in chapter 9 of the TSD and noted that for the 

walk-ins with dedicated condensing equipment, the relative shares for the food service 

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168 

20131002_OIRA compare document dated 9-26.docx

segment and the convenience and small grocery stores segment are now 78 percent and 

22 percent, respectively, whichcompared to 50 percent each for these two segments 

estimated in the preliminary analysis. These new values closely matchesmatch the 

percentage shares indicated by American Panel...

Several interested parties commented on the shares of different distribution 

channels across the market segments that DOE previously applied. In the preliminary 

analysis, DOE indicated that the percentage share of the aggregate shipments of 

refrigeration systems through refrigeration wholesalers was 15 percent for multiplex 

equipment and 57.5 percent for dedicated condensing equipment on an average basis for 

all the market segments. Heatcraft stated that the percentage share of the aggregate 

shipments of refrigeration systems through the refrigeration wholesalers is 50 percent. 

(Heatcraft, Public Meeting Transcript, No. 0045 at p. 284) Based on information 

gathered through interviews with manufacturers of refrigeration systems, DOE has 

revised its estimates for the percentage share of the aggregate shipments of refrigeration 

systems through wholesalers. For the NOPR, DOE revised these estimates to 42 percent 

for dedicated condensing systems and 45 percent for the unit coolers connected to a 

multiplex condensing system. 

In the preliminary analysis, DOE assumed that the share of electronic commerce 

(E-commerce) resellers in the food service market for dedicated condensing systems is 10 

percent. American Panel commented that this figure was too high and should be 1 percent 

or, at most, 2 percent. (American Panel, Public Meeting Transcript, No. 0045 at p. 195 

Comment [A21]: Edits made per OIRA.
169 

20131002_OIRA compare document dated 9-26.docx

and No. 0048.1 at p. 8) Manitowoc pointed out that E-commerce resellers often represent 

food service equipment distributors selling to territories outside the specific territory 

assigned to them by the manufacturer and that their sales could be considered distributor 

sales. In its view, if this aspect is considered, then the share of the E-commerce business 

estimated by DOE in the preliminary analysis is too high. (Manitowoc, Public Meeting 

Transcript, No. 0045 at p. 195) NEEA and NPCC reinforced the observations made by 

American Panel and Manitowoc, and suggested that DOE adjust the markup analysis 

accordingly. (NEEA and NPCC, No. 0059.1 at p. 9) DOE agrees with Manitowoc’s 

observation that the E-commerce share of total sales is essentially composed of sales 

through the distributor segment and, therefore, there is no need to identify this channel of 

distribution separately. As a result of this observation, DOE did not identify this as a 

separate distribution channel in the NOPR analysis.

American Panel noted that the distribution channel shares described by DOE for 

walk-ins with dedicated condensing equipment sold in the food service market segment 

are accurate for the national accounts and distributors under the current economic 

situation, but it expected to see the market share of the national chains increase to 20 

percent with the economy improving in the next 2 to 3 years. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 144) American Panel also pointed out that, for walkins with dedicated condensing equipment sold to the food service segment, the market 

share for contractors should be 5 percent instead of 10 percent. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 194),) In the NOPR markup analysis, DOE has 
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factored American Panel’s estimates and revised the corresponding market shares to 10 

percent for the national chains and 5 percent for the contractors.

Regarding the values of the markup multipliers presented in chapter 76 of the 

preliminary TSD, several interested parties commented on the methodology for arriving 

at the multiplier. AHRI stated that, when multiple-stage markups (manufacturer, 

distributor, dealer, and contractor) are estimated separately and multiplied to estimate the 

overall markups, the errors in the different stages are compounded in the final result. 

(AHRI, No. 0055.1 at p. 3) AHRI suggested that DOE avoid compounding errors and 

instead use retail prices in the analysis. DOE notes that the current methodology of the 

markup analysis is standardized in DOE’s economic analysis in its energy conservation 

rulemaking activities. A retail price analysis is not feasible, because a representative 

sample of direct end-user prices is difficult to obtain from distributors and contractors 

because pricing data are considered business-sensitive. Furthermore, these parties often 

use aggregate markups on the entire contract and separate markups for labor and/or 

equipment installations cannot be established. Therefore, DOE continues to use a markup 

analysis in this NOPR. 

Craig Industries commented that the mechanical contractor may not always 

purchase envelope components from the distributor, but can purchase them directly from 

the manufacturers and, therefore, the baseline markup for the mechanical contractor 

should not include the distributor markup. (Craig Industries, No. 0064.1 at p. 1) In the 

NOPR, DOE is proposing component-level standards for the envelope components and 

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has revised the markup analysis accordingly. DOE assumes that the general contractors 

would purchase the envelope components directly from the manufacturer, and hence, did 

not include the markup percentages of the distributors in the estimated overall markups 

for sales through the contractor channel in the NOPR analysis. 

Regarding the values of the markup multipliers presented in chapter 6 of the 

preliminary TSD, American Panel commented that the markup multiplier values were too 

high and should correspond to approximately 10–12 percent of the markup. (American 

Panel, Public Meeting Transcript, No. 0045 at p. 201) American Panel also questioned 

DOE’s assumption that the markup multipliers for unit coolers connected to multiplex 

systems would be substantially lower than the multipliers for the dedicated condensing 

equipment, when both types of equipment move through the same channel of distribution. 

(American Panel, No. 0048.1 at p. 8) In response to the first comment, DOE notes that 

the markup multipliers obtained in the revised analysis are consistent with the markup 

multipliers derived for other refrigeration products that often share the same distribution 

channels with walk-in coolers and freezers. Therefore, DOE considers the markup 

multipliers to be representative of the industry. Regarding the second comment, DOE 

notes that the overall markup multipliers depend not only on the channels through which 

the products are sold, but also on the relative shares of sales of the distribution channels. 

Because unit coolers connected to multiplex condensing systems are predominantly used 

in food sales, and a larger percentage of such equipment is sold directly to contractors, 

the equipment would be expected to have lower weighted average markup multipliers. 
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The NOPR analysis uses weighted average baseline markup multipliers for multiplex and 

non-multiplex equipment of 1.43 and 1.5251, respectively.

One interested party commented on DOE’s data sources. NEEA and NPCC

recommended that, in view of the several comments DOE received on the markup 

analysis and ongoing restructuring and consolidation of the food retailing industry, DOE 

should obtain manufacturer assistance in re-crafting the markup estimates for each 

distribution channel. (NEEA and NPCC, No. 0059.1 at p. 9) In the NOPR analysis, DOE 

has revised many of its estimates of the shares of individual channels based on comments 

received from interested parties. Given their general reliability, in estimating the markup 

multipliers in specific distribution channels, DOE uses data from trade associations and 

economic census data from the U.S. Census Bureau. The NOPR analysis relies on the 

most recently available data to derive the markup multipliers.

Table IV-12 shows the overall weighted average baseline and incremental 

markups for sales of refrigeration systems and envelope components. Chapter 6 and 

appendix 6A of the TSD provide complete details of the methodology and data used in 

the estimation of the markup multipliers.
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Table IV-12 Overall Markup Multipliers for All ProductEquipment Classes

Description ProductEquipment

Class

Markup Multipliers

Baseline Incremental

Multiplex 

Refrigeration 

Equipment

MCDC.M.I* 1.4351 1.2419

MCDC.L.I*

Dedicated 

Refrigeration 

Equipment

DC.M.IO*

1.5251 1.1819

DC.L.IO*

DCMC.M.O

1.5243 1.1825

DCMC.L.O

Structural 

Panels

SP.M

1.2116 1.1009

SP.L

Display 

Doors

DD.M

1.4541 1.3329

DD.L

Passage 

Doors

PD.M

1.2116 1.1009

PD.L

Freight 

Doors

FD.M

1.2116 1.1009

FD.L

Note: For the display doors, DOE included the cost of installation in the markup multiplier, because no data 

on the installation costs of the display doors were obtained. For all other products, DOE estimated the cost 

of installation separately and the markup multipliers do not include these costs.

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

.

B.E. Energy Use Analysis 

The energy use analysis estimates the annual energy consumption of refrigeration 

systems serving walk-ins and the energy consumption that can be directly ascribed to the 

selected components of the WICF envelopes. These estimates are used in the subsequent 

LCC and PBP analyses (chapter 8 of the TSD) and NIA (chapter 10 of the TSD). 

In the preliminary analysis, DOE estimated the annual energy consumption for a 

complete theoretical walk-in consisting of an envelope and a matched refrigeration 

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system, each at a specific efficiency level, using a set of assumptions for product loading, 

duty cycle, and other associated conditions. In the NOPR, DOE is proposing energy 

consumption standards separately for the refrigeration systems and a selected set of 

envelope components: panels, non-display doors, and display doors. Consequently, DOE 

revised the methodology for estimating the annual energy consumption to reflect the new 

approach. 

For the envelopes, the estimates of product and infiltration loads are no longer 

used in estimating energy consumption in the analysis because these factors are not 

intended to be mitigated by any of the component standards. DOE calculated only the 

transmission loads across the envelope components under test procedure conditions and 

combined that with the annual energy efficiency ratio (AEER) to arrive at the annual 

refrigeration energy consumption associated with the specific component. AEER is a 

ratio of the net amount of heat removed from the envelope in Btu/h by the refrigeration 

system and the annual energy consumed in watt-hours using bin temperature data 

specified in AHRI 1250-2009 to calculate AWEF. The AEER metric characterizes

refrigeration systems at a given efficiency level at which the energy consumption of the 

envelope component is determined. To estimate the annual energy consumption of the 

refrigeration system, DOE assumed that the refrigeration system is sized according to 

prevalent industry practice and operates under the assumptions implied in the assumed 

sizing methodology.

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In the preliminary analysis, DOE estimated aggregate refrigeration loads of three 

sizes of complete WICF envelopes in each of the four envelope classes (i.e., storage and 

display coolers and freezers.) In the NOPR, given the component-level approach, DOE 

estimated the annual energy consumption per unit of the specific envelope components 

by calculating the transmission load of the component over 24 hours under the test 

procedure conditions, and then calculating the annual refrigeration energy consumption 

attributed to that component by applying an appropriate AEER value. 

A key change from the preliminary analysis methodology for estimating the 

annual energy consumption is that in the NOPR analysis, DOE is no longer matching the 

refrigeration systems to specific envelope sizes. The estimates for the annual energy 

consumption of each analyzed representative refrigeration system (see section IV.C.2) 

were reached by assuming that (1) the refrigeration system is sized such that it follows a 

specific daily duty cycle for a given number of hours per day at full rated capacity, and

(2) the refrigeration systems produce no additional refrigeration effect for the remaining 

period of the 24-hour cycle. These assumptions are consistent with the present industry 

practice for sizing refrigeration systems. This methodology assumes that the refrigeration 

system is paired with an envelope that generates a load profile such that the rated hourly 

capacity of the paired refrigeration system, operated for the given number of run hours 

per day, produces adequate refrigeration effect to meet the daily refrigeration load of the 

envelope with a safety margin to meet contingency situations. Thus, the annual energy 

consumption estimates for the refrigeration system depends on the methodology adopted 

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for sizing, the implied assumptions and the extent of oversizing. The sizing methodology 

adopted in this NOPR analysis is further discussed later in this section.

For the envelopes, the estimates of product and infiltration loads are no longer 

used in estimating energy consumption in the analysis because these factors are not 

intended to be mitigated by any of the component standards. DOE calculated only the 

transmission loads across the envelope components under test procedure conditions and 

combined that with the annual energy efficiency ratio (AEER) to arrive at the annual 

refrigeration energy consumption associated with the specific component. AEER is a 

ratio of the net amount of heat removed from the envelope in Btu by the refrigeration 

system and the annual energy consumed in watt-hours using bin temperature data 

specified in AHRI 1250-2009 to calculate AWEF. The annual electricity consumption 

attributable to any envelope component is the sum of the direct electrical energy 

consumed by electrically-powered sub-components (e.g., lights and anti-sweat heaters) 

and the refrigeration energy, which is computed by dividing the transmission heat load 

traceable to the envelope component by the AEER metric, where the AEER metric 

represents the efficiency of the refrigeration system with which the envelope is paired.

In the preliminary analysis, DOE estimated aggregate refrigeration loads of three 

sizes of complete WICF envelopes in each of the four envelope classes (i.e., storage and 

display coolers and freezers.) In the NOPR, given the component-level approach, DOE 

estimated the annual energy consumption per unit of the specific envelope components 

by calculating the transmission load of the component over 24 hours under the test 

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procedure conditions, and then calculating the annual refrigeration energy consumption 

attributed to that component by applying an appropriate AEER value.

1. Sizing Methodology for the Refrigeration System

In the preliminary analysis, DOE calculated the required size of the refrigeration 

system for a given envelope by assuming that the rated capacity of the refrigeration 

system would be adequate to meet the refrigeration load of a walk-in cooler or freezer 

during the high-load condition. The load profile of WICF equipment that DOE used 

broadly followed the load profile assumptions of the industry test procedure for 

refrigeration systems -- —AHRI 1250-2009, Standard for Performance Rating of WalkIn Coolers and Freezers (“AHRI 1250-2009”). As noted earlier, that protocol was

incorporated into DOE’s test procedure. 76 FR 33631 (June 9, 2011). 

As a result, the DOE test procedure incorporates an assumption that, during a 24-

hour period, a WICF refrigeration system experiences a high-load period of 8 hours 

corresponding to frequent door openings, product loading events, and other design load 

factors, and a low-load period for the remaining 16 hours, corresponding to a minimum 

load resulting from conduction, internal heat gains from non-refrigeration equipment, and 

steady-state infiltration across the envelope surfaces. During the high-load period, the 

ratio of the envelope load to the net refrigeration system capacity is 70 percent for coolers 

and 80 percent for freezers. During the low-load period, the ratio of the envelope load to 

the net refrigeration system capacity is 10 percent for coolers and 40 percent for freezers. 

The relevant load equations correspond to a duty cycle for refrigeration systems, where 

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the system runs at full design point refrigeration capacity for 7.2 hours per day for coolers 

and 12.8 hours per day for freezers. Specific equations to vary load based on the outdoor 

ambient temperature are also specified. 

DOE received several comments on its duty cycle assumptions in the preliminary 

analysis. American Panel pointed out that the average envelope load hourly distributions 

for low and high loads used by DOE in the preliminary analysis represented a light 

loading condition and should be reversed, implying that a typical refrigeration system 

would experience 16 hours of high load and 8 hours of low load per day, rather than 

DOE’s assumptions of 8 hours and 16 hours for high and low load, respectively. 

(American Panel, Public Meeting Transcript, No. 0045 at p. 212) For the restaurant 

market segment in particular, American Panel noted that the high-load and low-load 

periods would both typically be 12 hours each. (American Panel, No. 0048.1 at p. 8) 

American Panel also commented that its own heat load calculations use 18 hours of 

maximum refrigeration system run time for the freezers and noted that this is the industry 

standard. (American Panel, No. 0048.1 at p. 3) Manitowoc and Heatcraft, however, 

agreed with DOE’s assumptions of the hourly load distributions for the high-load and 

low-load periods, which are consistent with AHRI 1250-2009. (Manitowoc, Public 

Meeting Transcript, No. 0045 at p. 215; Heatcraft, Public Meeting Transcript, No. 0045 

at p. 213) NEEA and NPCC noted that the duty cycle assumptions for the energy use 

analysis were credible and did not recommend any changes to this part of the analysis. 

(NEEA and NPCC, No. 0059.1 at p. 10) AHRI also commented that the assumptions 

made by DOE to calculate the duty cycle are acceptable for the analysis. (AHRI, No. 
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0055.1 at p. 3) Manitowoc noted that the envelope load assumptions are not supported 

with measurements from real life walk-in monitoring but are based on conservative sizing 

practices followed by the industry to ensure that even in worst-case situations, the walkin will maintain the necessary temperature. (Manitowoc, No. 0056.1 at p. 3) 

In light of the comments received from American Panel on current industry sizing 

practices, and Manitowoc’s comment that actual duty cycles differ from the AHRI test 

procedure conditions, DOE tentatively concludes that the duty cycle assumptions of 

AHRI 1250-2009 should not be used for the sizing purposes because they may not 

represent the average conditions for WICF refrigeration systems for all applications 

under all conditions. DOE recognizes that test conditions are often designed to effectively 

compare the performance of equipment with different features under the same conditions. 

 

For the energy use analysis, DOE revisited the duty cycle issue and found that the 

current industry practice for sizing the refrigeration system is based on providing a 10 

percent safety margin multiplier to the calculated aggregate refrigeration load over a 24-

hour daily cycle and assuming a nominal run time of 16 hours for coolers and 18 hours 

for freezers for sizing the refrigeration system. DOE’s key assumption in the preliminary 

analysis of equating the refrigeration capacity to the high-box load is not practiced in the 

industry and DOE has made no attempt to model the peak load. The nominal run time 

varies only in special situations—such as when freezers use hot gas defrost or when the 

temperature of the evaporator coil is higher than 32 °F. Consequently, DOE adopted the
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industry practice described above for calculating the energy use and load 

characterization. 

In this NOPR, DOE proposes a nominal run time of 16 hours per day for coolers 

and 18 hours per day for freezers to calculate the capacity of a “perfectly” sized 

refrigeration system. A fixed oversize factor is then applied to this size to calculate the 

actual runtime. With the oversize factor applied, DOE assumes that the runtime of the 

refrigeration system is 13.3 hours per day for coolers and 15 hours per day for freezers at 

full design point capacity. The reference outside ambient temperatures for the design 

point capacity conform to the AHRI 1250-2009 conditions incorporated into the DOE test 

procedure and are 95 °F and 90 °F for refrigeration systems with outdoor and indoor 

condensers, respectively. 

DOE notes that the AHRI assumptions for high-load and low-load conditions 

were supported by some interested parties and acknowledges that the distribution of highload and low-load hour assumptions could be relevant to the equipment energy 

consumption. DOE has observed, however, that the high-load situation is not taken into 

account by the industry in its standard sizing methods and would not represent current

industry practices. Thus, for the NOPR analysis, DOE has revised its sizing methodology 

to be consistent with its understanding of the current industry practice. DOE requests 

comment on the sizing methodology.
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2. Oversize Factors

American Panel commented that DOE’s preliminary analysis assumptions 

regarding duty cycle and sizing conflicted with the prevalent practice in the industry, 

which resulted in considerable oversizing of the refrigeration systems when paired with a 

given envelope. Oversizing leads to higher first cost estimates for the refrigeration 

equipment and distorts the LCC and PBP results because the energy savings are not 

commensurate with the first costs. American Panel further commented that because the 

refrigeration systems examined as part of the preliminary analysis are poorly matched to 

the envelopes, no meaningful conclusion can be drawn from the accompanying LCC, 

PBP, and NIA results. (American Panel, No. 0048.1 at p. 8 and p. 11) Regarding the 

annual energy calculations presented in chapter 7 of the TSD, American Panel did not 

believe that DOE properly matched the refrigeration systems and enevelopes --

envelopes—which yielded an estimated 8 hours or less of runtime per day. In its view, 

this preliminary estimate is incorrect. (American Panel, No. 0048.1 at p. 9) American 

Panel also submitted additional documentation demonstrating its own methodology for 

matching the selected refrigeration system capacity to the estimated heat load of a walkin expressed in Btu/h. (American Panel, No. 0048.1 at p. 9) DOE investigated further and 

found that the load calculation manuals and sizing software of several refrigeration 

system manufacturers supported American Panel’s recommendation on the approach to 

sizing. 

As stated previously, DOE observed that the typical and widespread industry 

practice for sizing the refrigeration system is to calculate the daily heat load on the basis 

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of a 24-hour cycle and divide by 16 hours of runtime for coolers and 18 hours of runtime 

for freezers. DOE also found that it is customary in the industry to allow for a 10 percent 

safety margin to the aggregate 24-hour load resulting in 10 percent oversizing of the 

refrigeration system. 

In the preliminary analysis, DOE considered a scaled mismatch factor in addition 

to the oversizing related to its duty cycle assumptions. DOE recognized that an exact 

match for the calculated refrigeration capacity may not be available for the refrigeration 

systems available in the market because most refrigeration systems are mass-produced in 

discrete capacities. The capacity of the best matched refrigeration system is likely to be 

the nearest higher capacity refrigeration system available. This consideration led DOE to 

develop a scaled mismatch factor that could be as high as 33 percent for the smaller 

refrigeration system sizes, and was scaled down for the larger sized units. In the 

preliminary analysis, DOE applied this mismatch oversizing factor to the required 

refrigeration capacity at the high-load condition to determine the required capacity of the 

refrigeration system to be paired with a given envelope. 

DOE received multiple comments regarding the mismatch factor. Manitowoc 

pointed out that the mismatch factors used by DOE in the preliminary analysis are high:.

DOE assumed that compressors are available only in capacity increments of 6000 Btu/h 

but Manitowoc noted that compressors are available at capacity increments of 2000,

Btu/h and 1500, Btu/h for medium- and low-temperature systems, respectively. 

(Manitowoc, No. 0056.1 at p. 3; Manitowoc, Public Meeting Transcript, No. 0045 at p. 
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220 and p. 222) American Panel pointed out that the maximum mismatch factor could be 

15 percent. (American Panel, Public Meeting Transcript, No. 0045 at p. 220) Heatcraft 

stated that DOE’s assumption that the sizes of refrigeration systems available in the 

market are at 0.5-ton intervals is not applicable for larger sized systems. For sizes from 

5–10 horsepower, the compressors are available in 2.5-horsepower intervals, and for sizes 

from 10–30 horsepower, compressors are available in 5-horsepower intervals. (Heatcraft, 

No. 0069.1 at p. 2)

Based on these comments, DOE recalculated the mismatch factor because 

compressors for the lower capacity units are available at smaller size increments than 

what DOE assumed in the preliminary analysis. DOE also agrees with Manitowoc that 

for larger sizes, the size increments of available capacities are higher than size increments 

available for the lower capacities. DOE further noted as part of the revised analysis that 

under current industry practice, if the exact calculated size of the refrigeration system 

with a 10 percent safety margin is not available in the market, the user may choose the 

closest matching size even if it has a lower capacity, allowing the daily runtimes to be 

somewhat higher than their intended values. The designer would recalculate the revised 

runtime with the available lower capacity and compare it with the target runtime of 16 

hours for coolers and 18 hours for freezers and, if this value falls within acceptable limits, 

then the chosen size of the refrigeration system is accepted and there is no mismatch 

oversizing. 
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DOE further examined the data of available capacities in published catalogs of 

several manufacturers and noted that the range of available capacities depends on 

compressor type and manufacturer. Furthermore, because smaller capacity increments are 

available for units in the lower capacity range and larger capacity increments are 

available for units in the higher capacity range, the mismatch factor is generally uniform 

over the range of equipment sizes. For the NOPR, DOE tentatively concluded from these 

data that a scaled mismatch factor linked to the target capacity of the unit may not be 

applicable, but that the basic need to account for discrete capacities available in the 

market is still valid. To this end, DOE is now applying a uniform average mismatch 

factor of 10 percent over the entire capacity range of refrigeration systems. 

3. Product Load

The NOPR analysis does not include an explicitly modeled product load to 

determine the annual energy consumption. Instead, the annual energy consumption 

estimates for the refrigeration systems are based on industry practice duty cycle 

assumptions. This approach does not require any explicit modeling of the product load. 

However, for the shipment analysis of refrigeration systems, DOE expressed annual 

shipments and stocks in terms of installed refrigeration capacity (Btu/h). The shipments 

of the refrigeration system were linked to the shipments of envelopes, which required 

DOE to estimate the required refrigeration capacity for the units shipped. DOE included 

several assumptions about product loads in these calculations. These assumptions are 

discussed in the relevant section on shipment (Section IV.G of this NOPR).

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4. Other Issues

DOE received one comment on the issue of the interaction of building airconditioning systems with WICF systems installed within them. Ingersoll Rand stated 

that envelope improvements may not lead to significant energy savings because the load 

on the refrigeration systems of the WICF unit would be replaced by the load on the 

building air-conditioning system. DOE did not account for the difference in overall 

energy use that could be directly attributed to the improvement of envelope components 

on the whole building cooling load and, correspondingly, any space-cooling energy 

impacts. At the same time, any envelope component improvements may also result in a 

decrease in the use of heating energy within the buildings. This impact on building 

heating and cooling loads would only occur for WICF units located indoors. The relative 

cooling-energy-use penalty to heating-energy-use benefit is a function of the climate of 

the region in which the building is located, the building type and size, and the placement 

of the WICF units within the building. The relative monetary benefits are also a function 

of the relative heating and cooling fuel costs. The quantification of the relative benefits 

impact would have required an extensive analysis of building climate-control 

performance, which is both unnecessary and outside the scope framed by Congress.

For the refrigeration systems, DOE calculated the annual energy consumption for 

all six classes of refrigeration systems at various capacity points with all available 

compressor options and at all efficiency levels for which results of engineering analysis 

were available. The annual energy consumption results were used as inputs to the LCC 

and PBP analyses. Based on the results of the LCC analysis, DOE selected the most costFormatted: Indent: Left: 0", Don't adjust

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efficient combination of compressors and other components at a given AWEF level for a

specific capacity point. Fourteen efficiency options were selected from the entire range of 

available AWEF values for each capacity point analyzed. To simplify further analysis, 

however, DOE chose two points from a set of four or five capacity points in each of the 

four dedicated condensing productequipment classes, and one for each of the two 

multiplex condensing productequipment classes. DOE used the shipment data to derive a 

shipment weighted AEER value for each TSL option for the refrigeration system. For the 

envelope components, DOE estimated the associated refrigeration energy at each of the 

TSL options and each level of efficiency of the components. The units of analysis were 

the unit area for the panels and each whole door for the doors. DOE added the direct 

electrical energy consumed for each of the doors at different efficiency levels to the 

refrigeration energy to arrive at the total annual energy consumption. The annual energy 

consumption results for the components were used as inputs to the LCC and PBP 

analyses for the components. Chapter 7 of the TSD shows the annual average energy 

consumption estimates by equipment class and efficiency level for both the refrigeration 

system and the components.

C.F. Life-Cycle Cost and Payback Period Analyses

DOE conducts LCC and PBP analyses to evaluate the economic impacts of 

potential energy conservation standards for walk-ins on individual consumers—that is, 

buyers of the equipment. As stated previously, DOE adopted a component-based 

approach for developing performance standards for walk-in coolers and freezers. 

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Consequently, the LCC and PBP analyses were conducted separately for the refrigeration 

system and the envelope components: panels, non-display doors, and display doors. 

The LCC is defined as the total consumer expense over the life of a product, 

consisting of purchase, installation, and operating costs (expenses for energy use, 

maintenance, and repair). To calculate the operating costs, DOE discounts future 

operating costs to the time of purchase and sums them over the lifetime of the product. 

The PBP is defined as the estimated number of years it takes consumers to recover the 

increased purchase cost (including installation) of a more efficient product. The increased 

purchase cost is derived from the higher first cost of complying with the higher energy 

conservation standard. DOE calculates the PBP by dividing the increase in purchase cost 

(normally higher) by the change in the average annual operating cost (normally lower) 

that results from the standard.

NEEA and NPCC suggested that, when estimating equipment lifetimes, DOE 

should consider both the economic and physical lifetimes of WICF equipment. (NEEA 

and NPCC, No. 0559.1 at p. 11) The physical lifetime refers to the duration before the 

equipment fails or is replaced, whereas the economic lifetime refers to the duration before 

the walk-in cooler and freezer equipment is taken out of service because the owner is no 

longer in business. In its energy conservation standards rulemakings, DOE does not 

typically consider the change of ownership of a distressed property due to business 

failure or insolvency of the first owner. The underlying assumption in this approach is 

that the higher efficiency equipment would continue to serve over its physical lifetime 
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irrespective of ownership changes. Interested parties commented, however, that, in the 

case of walk-ins, the economic lifetime could be significantly lower. Owners at high risk 

of business failure or insolvency would be less likely to buy higher efficiency equipment 

because they likely would not see the long-term life cycle benefits of energy savings. 

In response to these comments, the NOPR analysis provides an economic lifetime 

study for the restaurant sector. The study includesDOE attempted to include alternative 

Weibull probability distributions, which attempts in the NOPR analysis to capture the 

effects of a reduced economic lifetime of WICF equipment for small restaurants. Due, 

but due to the increased complexity resulting from the component-level approach and 

lack of data on reduced lifetimes on account of change of ownership of walk-in 

equipment, DOE did not incorporate thea shorter restaurant sector economic lifetime in 

the NOPR life cycle cost model. In many, if not most, cases when there is a change in 

ownership, equipment is not disassembled, but is sold “as is.”

For any given efficiency level, DOE measures the PBP and the change in LCC 

relative to the base-case equipment efficiency levels. The base-case estimate reflects the 

market without new or amended energy conservation standards. For walk-ins, the basecase estimate assumes that newly manufactured walk-in equipment complies with the 

existing EPCA requirements and either equals or exceeds the efficiency levels achievable 

by EPCA-compliant equipment. Inputs to the economic analyses include the total 

installed operating, maintenance, and repair costs.
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Inputs to the calculation of total installed cost include the cost of the product—

which consists of manufacturer costs, manufacturer markups, distribution channel 

markups, and sales taxes—and installation costs. Inputs to the calculation of operating

expenses include annual energy consumption, energy prices and price projections, repair 

and maintenance costs, product lifetimes, discount rates, and the year that compliance 

with standards is required. DOE created probability distributions for product lifetime 

inputs to account for their uncertainty and variability.

DOE developed refrigeration and envelope component spreadsheet models used 

for calculating the LCC and PBP. Chapter 8 of the TSD and its appendices provide 

details on the refrigeration and envelope subcomponent spreadsheet models and on all the 

inputs to the LCC and PBP analyses.

Table IV-13 summarizes DOE’s approach and data used to derive inputs to the 

LCC and PBP calculations for both the preliminary TSD and the changes made for 

today’s NOPR. The subsections that follow discuss the initial inputs and methods and the 

changes DOE made for the NOPR.

For refrigeration systems, DOE analyzed all possible compressor technology 

options available for a given capacity of the refrigeration system. From the results of the 

individual compressor technology LCC analysis, DOE developed LCC savings plots in 

which the LCC savings over the LCC cost at the lowest total installed price option was 

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plotted against the refrigeration system efficiency metric (AWEF). The LCC savings 

plots for the individual compressor technologies were superimposed into a single plot as 

shown in Figure IV-1 below.. A full range of optimal technology options were obtained 

by choosing the compressor technology available from the suite of available technologies 

that can reach a given efficiency level with the highest calculated LCC savings. The 

series of technology choices over the entire range of AWEF values from baseline to the 

highest achievable efficiency level obtained in this manner comprise the optimal path in 

developing higher efficiency equipment.

Figure IV-1 Superimposed Plot Sample: Life-Cycle Costs for a 9,000 Btu/hr LowTemperature Refrigeration System with Alternative Compressor Technologies and 

Options Chosen

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Table IV-13 Summary of Inputs and Methods in the LCC and PBP Analysis*

XLIII. Inputs XLIV. Preliminary Analysis XLV. Changes for the NOPR

XLVI. Installed Costs

XLVII. Equipm

ent Cost

XLVIII.Derived by multiplying 

manufacturer cost by manufacturer 

and retailer markups and sales tax, 

as appropriate.

XLIX. Included factor for estimating price trends due 

to manufacturer experience.

L. Installat

ion Costs

LI. Based on RS Means 

Mechanical Cost Data 2009. 

Assumed no change with efficiency 

level.

LII. Based on RS Means Mechanical Cost Data 

20102012. Assumed no change with efficiency level.

LIII. Operating Costs

LIV. Annual 

Energy Use

LV. DOE calculated the 

average annual energy use for each 

WICF envelope class matched with 

outdoor condenser systems using a 

load profile described in AHRI 

1250-2009 (8 hours of high load 

and 16 hours of low load per day).

LVI. Daily load profile of the refrigeration system 

revised to 13.3 hours runtime per day for coolers and 

15 hours for freezers, at full rated capacity and at 

outside air temperatures corresponding to the reference 

rating temperatures. 

LVII. Energy 

Prices

LVIII. EIA (Energy Information 

Administration). Form EIA-861 for 

2006.

Source for Commercial and Industrial Retail Prices of 

Electricity: Form EIA-826 Database Monthly Electric 

Utility Sales and Revenue Data (EIA-826 Sales and 

Revenue Spreadsheets). 

www.eia.doe.gov/cneaf/electricity/page/eia826 . 

Accessed June 12, 2009September 30, 2012. 

.html

Energy Price 

Trends

Forecasted using AEO2009 price 

forecasts.

Forecasts updated using AEO2010AEO2013. 

Repair and 

Maintenance 

Costs

Annualized repair and maintenance 

costs of the combined system were 

derived from RS Means 2009 walkin cooler and freezer maintenance 

data. Doors and refrigeration 

systems were replaced during the 

lifetime.

Revised to RS Means 20102012 walk-in cooler and 

freezer maintenance data and maintenance data; 

maintenance and repair costs for the refrigeration 

system and the envelope components were individually 

estimated.

Present Value of Operating Cost Savings

Equipment

Lifetime

Based on manufacturer interviews.

Variability: characterized using 

Weibull probability distributions.

Revised to reflect stakeholder comments.

Discount Rates Based on the 2009 commercial 

refrigeration equipment final rule 

(72 FR 1092); vary across 

commercial building types.

1. Based on Damodaran Online, May 

2010October 2012. 

2. Compli

ance Date 

3. 2015 No change2017. 

* References for the data sources mentioned in this table are provided in the sections following the table or 

in chapter 8 of the TSD.

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4.1. Equipment Cost

To calculate consumer equipment costs, DOE multiplied the MSPs from the 

engineering analysis by the supply-chain markups described above (along with sales 

taxes). DOE used different markups for baseline products and higher efficiency products 

because, as discussed previously, DOE applies an incremental markup to the MSP 

increase associated with higher-efficiency products.

On February 22, 2011, DOE published a Noticenotice of Data Availabilitydata 

availability (NODA, 76 FR 9696) stating that DOE may consider improving its 

regulatory analysis by addressing equipment price trends. Consistent with the NODA, 

DOE examined historical producer price indices (PPI) for refrigeration equipment in 

general and found both positive and negative short-term real price trends. Over the 

historical long term DOE found slightly negative time real price trends. Therefore, DOE 

assumes in its price forecasts for this NOPR that the real prices of refrigeration 

equipment decrease slightly over time. DOE performed a sensitivity analysis of the NPV 

results for refrigeration equipment to the observed range of uncertainty in this long term 

price trend. DOE projected the price of the panels and doors using constant real 

20102012$ prices (See chapter 8 and chapter 10 of the TSD). DOE is aware that there 

have been significant changes in both the regulatory environment and equipment 

technologies during this period that create analytical challenges for estimating longerterm product price trends from the product-specific PPI data. DOE performed price trend 

sensitivity calculations to examine the dependence of the analysis results on different 

analytical assumptions. A more detailed discussion of price trend modeling and 

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calculations is provided in Appendix 8A8D of the TSD. DOE invites comment on 

methods to improve its equipment price forecasting, as well as any data supporting 

alternate methods.

5.2. Installation Cost

Installation cost includes labor, overhead, and any miscellaneous materials and 

parts needed to install the equipment. For the preliminary analysis, DOE derived baseline 

installation costs for walk-in coolers and freezers from data in RS Means Mechanical 

Cost Data 2009. 

DOE estimated installation costs separately for panels, non-display doors, and 

display doors. Installation costs for panels were calculated per square foot of area while 

installation costs for non-display doors were calculated per door. Display door 

installation costs were omitted and assumed to be included in the panel installation costs 

for display walk-ins. DOE assumed that display doors are either installed by the 

assembler or manufacturer of the walk-in unit, and the installation costs for the display 

doors are included in the “mark-up” amounts for the OEM channel.

For the NOPR analysis, DOE included refrigeration system component 

installation costs based on RS Means Mechanical Cost Data 20102012. Refrigeration 

system installation costs included separate installation costs for the condensing unit and 

unit cooler. American Panel commented that these units are installed simultaneously by 

the same installation crew and quoted as a combined price. (American Panel, Public 

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Meeting Transcript, No. 0045 at p. 246 and No. 0048.1 at p. 9) RS Means 20102012

provides these installation costs separately, although the installation activities may be 

performed by the same crew. DOE proposes to be consistent with the approach of the 

cost data source because this approach permits one to estimate the installation costs of 

many combinations of unit coolers and condensing units.

In the preliminary analysis, DOE did not distinguish between installation costs for 

indoor and outdoor systems. Manitowoc stated that indoor and outdoor systems would 

likely incur different installation costs. (Manitowoc, Public Meeting Transcript, No. 0045 

at p. 245) Installation cost differences between indoor and outdoor condensing units were 

not reported in the RS Means data because the costs shown are based only on unit 

capacity. DOE assumed that the installation costs reported in the RS Means data are 

based on a weighted average of outdoor and indoor units -- —accordingly, DOE used 

identical installation costs for indoor and outdoor condensing units. 

6.3. Annual Energy Consumption

To estimate the annual energy consumption, DOE assumed that the installed 

refrigeration capacity is 20 percent larger than the refrigeration load calculated in the 

sizing methodology. The prevailing industry practice is to recommend that the rated 

capacity for refrigeration equipment selection includes a 10 percent “safety factor”. DOE 

chose to use a somewhat higher oversizing factor to account for the differences between 

the sizes calculated, using load estimation software programs, and the discrete sizes 

available in the market (that is, the mismatch factor). To determine annual energy 

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consumption, DOE calculated, using the industry practice described above, that a 

refrigeration system with the selected oversizing factor would be required to run 13.3 

hours per day for coolers and 15 hours per day for freezers at full rated capacity at the 

reference outside air temperatures to meet the aggregate refrigeration load of the paired 

walk-in envelope. These time periods were determined from DOE’s sizing methodology, 

as discussed in section IV.E.1. DOE used reference temperatures of 90 °F and 95 °F for 

indoor and outdoor condensing refrigeration systems, respectively, which is consistent 

with the standard rating conditions incorporated by DOE from AHRI 1250-2009. 

 

7.4. Energy Prices

DOE calculated average commercial electricity prices using Form EIA-826 

Database Monthly Electric Utility Sales and Revenue Data (EIA-826 Sales and Revenue 

Spreadsheets) (www.eia.doe.gov/cneaf/electricity/page/eia826.html; accessed June 12, 

2010).September 30, 2012). DOE calculated an average national commercial price by (1) 

estimating an average commercial price for each utility by dividing the commercial 

revenues by commercial sales; and (2) weighting each utility by the number of 

commercial consumers it served in that regionstate, across the nation. For the preliminary 

TSD, DOE used the electricity price data from 2009. DOE updated the NOPR analysis 

using 20102012 data.

8.5. Energy Price Projections

To estimate energy prices in future years for the preliminary TSD, DOE 

multiplied the average regionalstate energy prices described above by the forecast of 

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annual average commercial energy price indices developed in the Reference Case from 

AEO2009,AEO2013, which forecasted prices through 20302040.19. AHRI supported 

DOE’s approach for estimating current and future energy prices. (AHRI, No. 0055.1 at p. 

3) DOE did not change its general approach, but today’s NOPR analysis updates the 

initial energy price forecasts using AEO2010AEO2013, which has an end year of 2035.20

To estimate the price trends after 2035, DOE used the average annual rate of change in 

prices from 20362026 to 20452035. 

9.6. Maintenance and Repair Costs

DOE calculated both maintenance and repair costs for the analysis. Maintenance 

costs are associated with maintaining the equipment operation, whereas repair costs are 

associated with repairing or replacing components that have failed in the refrigeration 

system and the envelope (i.e. panels and doors). In the preliminary analysis, DOE 

considered only general maintenance costs (e.g., checking and maintaining refrigerant 

charge levels, checking settings, and cleaning heat exchanger coils) and lighting 

maintenance activities. The NOPR analysis applies the same lighting maintenance 

assumptions for display doors with lights as DOE previously applied during the 

preliminary analysis phases. The remaining data on general maintenance for an entire 

walk-in were apportioned between the refrigeration system and the envelope doors. 

Based on the descriptions of maintenance activities in the RS Means 20102012 Facilities 

 

19 The spreadsheet tool that DOE used to conduct the LCC and PBP analyses allows usersuser0s to select 

price forecasts from either AEO’s High Economic Growth or Low Economic Growth Cases. Users can 

thereby estimate the sensitivity of the LCC and PBP results to different energy price forecasts. 20 U.S. Energy Information Administration. Annual Energy Outlook 2010. April 2010.2013. May 2013.

U.S. Energy Information Administration: Washington, DC.

Comment [A24]: Edits made per OIRA.

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Maintenance and Repair Cost Data (available on CD-ROM) and manufacturer interviews, 

DOE assumed that the general maintenance associated with the panels is minimal and did 

not include any maintenance costs for panels in its analysis. RS Means 20102012 data 

provided general maintenance costs for display and storage walk-ins. 

In response to this approach, American Panel suggested that DOE contact the 

Commercial Food Equipment Service Association (CFESA) to obtain additional 

maintenance and repair information. (American Panel, No. 0048.1 at p. 8) At American 

Panel’s recommendation, DOE contacted CFESA, who expressedexplained that they did 

not have the information requested. 

Of the total annual maintenance costs for a walk-in unit, which ranges from $161–

$246170–$262, DOE assumed $150 would be spent on the refrigeration system and the 

rest would be spent on the display and passage doors of the envelope. DOE made this 

assumption as part of its preliminary analyses based on comments and research that 

pointed to this value as the likely amount that would need to be expended to cover 

refrigeration system-related costs. Maintenance costs were assumed to be the same across 

small, medium, and large door sizes in the case of both non-display doors and display 

doors. (DOE derived the envelope-related costs as the difference between the total 

maintenance costs for a walk-in and the assumed maintenance costs for the refrigeration 

system.) As stated previously, annual maintenance costs for the envelope wall and floor 

panels were assumed to be negligible and were not considered.
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Interested parties commented on maintenance costs associated with refrigerant 

leakage and refrigerant charge. Emerson stated that DOE’s estimated maintenance costs 

should account for higher refrigerant costs due to higher leakage rates and other issues in 

systems with higher refrigerant charge. (Emerson, Public Meeting Transcript, No. 0045 at 

p. 238) However, Emerson also commented that higher refrigerant costs could lead to the 

use of refrigerant leakage-reduction devices that offset the increased repair costs due to 

higher refrigerant charge and loss. (Emerson, Public Meeting Transcript, No. 0045 at p. 

239) DOE did not receive any data for refrigeration maintenance costs, but based on the 

comments from Emerson, DOE assumes as part of the NOPR analysis that the $150 

maintenance cost for a refrigeration system would include expenses related to refrigerant 

charge maintenance costs. DOE seeks data from interested parties on refrigerant charge 

maintenance costs applicable to walk-ins. 

Other interested parties commented on potential climate change legislation. AHRI 

suggested that DOE study the impact of climate change legislation on the future

availability and price of HFC refrigerants. (AHRI, No. 0055.1 at p. 3) Emerson also said 

that any future cap-and-trade bill would increase refrigerant costs significantly. 

(Emerson, Public Meeting Transcript, No. 0045 at p. 238) NEEA and NPCC suggested 

that refrigerant leakage and climate change responses should be evaluated in a manner 

that seeks to reduce refrigerant leakage rather than focusing solely on managing 

refrigerant replacement costs, particularly since maintenance costs are rising. (NEEA and 

NPCC, No. 0059.1 at p. 10) DOE acknowledges the concerns of interested parties 

regarding the effect of climate change legislation on refrigerant leakage and refrigerant 
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costs. DOE does not speculate on pending legislation and potential climate change 

impacts related to refrigerants, which areis outside the scope of this rulemaking.

DOE also updated its methodology for determining repair costs for the NOPR in 

response to earlier comments. In the preliminary analysis, DOE assumed that both the 

unit cooler and the condensing unit of the refrigeration system are replaced when the 

refrigeration system fails. Master-Bilt commented that repairing a failed refrigeration 

system typically would require replacement of the compressors, not the entire system, 

and that approximately five percent of refrigeration systems would require a compressor 

replacement during a 10-year span. (Master-Bilt, Public Meeting Transcript, No. 0045 at 

p. 287) American Panel agreed and noted that, when a refrigeration system fails the entire 

refrigeration system is not typically replaced; rather, only compressors or fan motors are 

replaced. (American Panel, Public Meeting Transcript, No. 0045 at p. 11) After carefully 

considering these comments, DOE assumed for the NOPR analysis that five5 percent of 

systems require compressor replacement and 10 and 15 percent of systems require fan 

motor replacement for evaporators and condensers, respectively, over the lifetime of the 

system. Aftermarket prices for fan motors and compressors were obtained from data 

collected during the engineering analysis and multiplied by a trade channel markup. DOE 

estimated installation costs using the RS Means Mechanical Cost Data 20102012 and 

calculated the total repair cost per occasion of replacement. DOE then calculated the 

annualized repair costs by multiplying the discounted total replacement cost per occasion 

by the replacement lifetime percentage.
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Under this approach, for the envelope components (panels, non-display doors, and 

display doors), the NOPR analysis factored repair costs for lighting repairs pertaining to 

the lighting of the display doors. Data from the RS Means Electrical Cost Data 20102012

were used to obtain the labor installation cost for lighting replacements. For refrigeration 

systems, DOE observed that estimated repair costs often increased with increasing 

efficiency levels, particularly for higher-efficiency compressors and fan motors. 

In the preliminary analysis, DOE assumed that annualized maintenance and repair 

costs were constant across all efficiency levels. Manitowoc and Master-Bilt stated that 

maintenance and repair cost increases across efficiency levels should not be negligible 

because more efficient equipment is more complex and may have design options that lead 

to the incorporation of additional or more expensive parts, which would cost more to 

maintain and replace. (Manitowoc, Public Meeting Transcript, No. 0045 at p. 241; 

Master-Bilt, No. 0046.1 at p. 1) Heatcraft agreed that maintenance and repair costs may 

increase with higher efficiency levels, stating that more efficient equipment would incur 

higher maintenance and repair costs because higher efficiency evaporator and condenser 

coils are larger and heavier, making them more difficult and costly to maintain. 

(Heatcraft, No. 0069.1 at p. 1) AHRI stated that larger evaporator and condenser coils 

require more refrigerant and concluded that the maintenance and cost repair differences 

across efficiency levels are evident. (AHRI, No. 0055.1 at p. 3 and 4) NEEA and NPCC

stated, however, that there are no data available to support the contention that the 

complexity of electronics systems used in the controls of higher efficiency equipment 

leads to higher maintenance costs. (NEEA and NPCC, No. 0059.1 at p. 10)
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In the NOPR analysis, DOE considered these comments and examined whether 

each design option would have higher maintenance and repair costs associated with it. As 

stated earlier, DOE agreed with comments made by Master-Bilt and American Panel on 

repair costs and found that certain design options that entail substitution of either 

evaporator and condenser fan motors or higher efficiency compressors would likely incur 

higher maintenance and repair costs because of the higher cost of these components. The 

NOPR analysis accounts for these observations. In summary, DOE believes that repair 

costs will increase with efficiency level whereas all non-lighting maintenance costs will 

not increase with efficiency level. 

10.7. Product Lifetime

In the preliminary analysis, DOE estimated an average product lifetime of 15 

years for envelopes and 7 years for refrigeration systems. The NOPR analysis alters this 

approach by estimating lifetimes for the individual components analyzed, instead of the 

entire envelope. DOE estimated an average lifetime of 15 years for panels and 14 years 

for display and non-display doors. DOE also revised the average refrigeration system 

lifetime to 12 years. Weibull distributions were derived around average lifetime estimates 

to obtain specific failure rates at each year of equipment life. See chapter 8 of the NOPR 

TSD for further details on the method and sources DOE used to develop product 

lifetimes.

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11.8. Discount Rates

In calculating LCC, DOE applies discount rates to estimate the present 

value of future operating costs. DOE did not have sufficient information in preparing its 

preliminary analysis to derive discount rates for walk-ins. Instead, DOE used discount 

rates from the 2009 commercial refrigeration equipment final rule as a surrogate to 

approximate the rates that would apply to walk-ins. 72 FR 1092 (January 9, 2009). For 

the NOPR, DOE developed commercial discount rates for various market segments based 

on the commercial cost of capital data found in Damodaran Online, May 201021

• Grocery: 5.23.7 percent

.72 FR at 

1123 (January 9, 2009). For the NOPR, DOE derived the discount rates for the walk-in 

cooler and freezer equipment analysis by estimating the cost of capital for a large number 

of companies similar to those that could purchase walk-in cooler and freezer equipment 

and then sampling them to characterize the effect of a distribution of potential customer 

discount rates. The cost of capital is commonly used to estimate the present value of cash 

flows to be derived from a typical company project or investment. Most companies use 

both debt and equity capital to fund investments, so their cost of capital is the weighted 

average of the cost to the company of equity and debt financing. Average discount rates 

(real) in these updated analyses by service building type are as follows:

• Food service: 53.9 percent

• Convenience Store: 7.25.0 percent

• Restaurant: 7.96.2 percent

 

21 Damodaran, A. Damodaran Online. Historical Returns on Stocks, Bonds and Bills – United States. (Last 

accessed May 10, 2011.) <http://pages.stern.nyu.edu/~adamodar>

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• Other Food Service: 5.53.8 percent

 

DOE estimated the cost of equity financing by using the Capital Asset Pricing 

Model (CAPM).22 The CAPM, among the most widely used models to estimate the cost 

of equity financing, assumes that the cost of equity is proportional to the amount of 

systematic risk associated with a company. The cost of equity financing tends to be high 

when a company faces a large degree of systematic risk, and it tends to be low when the 

company faces a small degree of systematic risk.

See chapter 8 of the TSD for further details on the development of commercial 

discount rates.

12.9. Compliance Date of Standards

EPCA prescribes that DOE establish performance-based standards for walk-ins by 

2012. (42 U.S.C. 6313(f)(4)(A)) The standards apply to equipment manufactured 

beginning on the date 3 years after the final rule is published unless DOE determines, by 

rule, that a 3-year period is inadequate, in which case DOE may extend the compliance 

date for that standard by an additional two2 years. (42 U.S.C. 6314(f)(4)(B)) In the 

absence of any information indicating that 3 years is inadequate, DOE proposes a

compliance date for the standards of 20152017. Therefore, DOE calculated the LCC and 

 

22 Harris, R.S. Applying the Capital Asset Pricing Model. UVA-F-1456. Available at SSRN: 

http://ssrn.com/abstract=909893.

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PBP for walk-in coolers and freezers under the assumption that compliant equipment 

would be purchased in the year when compliance with the new standard is required –

2015–2017. DOE seeks comments and information on the adequacy of the 3-year 

compliance date. 

13.10. Base-Case and Standards-Case Efficiency Distributions

To accurately estimate the share of consumers who would likely be impacted by a 

standard at a particular efficiency level, DOE’s LCC analysis considers the projected 

distribution of product efficiencies that consumers purchase under the base case (i.e., the 

case without new energy efficiency standards). DOE refers to this distribution of product 

efficiencies as a base-case efficiency distribution. DOE examined the range of standard 

and optional equipment features offered by refrigeration manufacturers and estimated that 

for. For refrigeration systems, DOE estimated that 75 percent of the equipment sold 

under the base case would be at DOE’s assumed baseline level—that is, the equipment 

would comply with the existing standards in EPCA, but have no additional features that 

improve efficiency. The remaining 25 percent of equipment would have features that 

would increase its efficiency. While manufacturers could have many options, DOE 

assumed that the average efficiency level of this equipment would correspond to the 

efficiency level achieved by the baseline equipment with the first design option in the 

sequence of design options in the engineering analysis ordered by their relative costeffectiveness. (See Section IV.C). The current analysis assumes that all consumers

purchase only the minimally compliant equipment from 2015 on, when the walk-in 

cooler and freezer standard is in effect.DOE estimated that for panels and non-display 

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doors, 100 percent of the equipment sold under the base case would consist of equipment 

at DOE’s assumed baseline level—that is, minimally compliant with EPCA. For cooler 

display doors, DOE assumed that 25 percent of the current shipments are minimally 

compliant with EISA and the remaining 75 percent are higher-efficiency (45 percent are 

assumed to have LED lighting, corresponding to the first efficiency level above the 

baseline in the engineering analysis, and 30 percent are assumed to have LED lighting 

plus anti-sweat heater wire controls, corresponding to the second efficiency level above 

the baseline). For freezer display doors, DOE assumed that 80 percent of the shipments 

would be minimally compliant with EPCA and the remaining 20 percent have LED 

lighting, corresponding to the first efficiency level above the baseline. (See Section IV.C

and chapter 5 of the TSD for a discussion of the efficiency levels and design options in 

the engineering analysis). The current analysis assumes that all consumers purchase only 

the minimally compliant equipment from 2017 on, when the walk-in cooler and freezer 

standard is in effect. DOE requests comment on the distribution of product efficiencies in 

the absence of standards, particularly with respect to the magnitude of market penetration 

of any specific higher-efficiency technologies. For further information on DOE’s 

estimate of base-case efficiency distributions, see chapter 8 of the TSD. 

14.11. Inputs to Payback Period Analysis

The payback period is the number of years that it takes the consumer to recover 

the additional installed cost of more efficient products, compared to baseline products, 

through energy cost savings. The simple payback period does not account for changes in 

operating expense over time or the time value of money. Payback periods that exceed the 

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life of the product mean that the increased total installed cost is not recovered in reduced 

operating expenses (based on the first year’s estimated operating cost).

The inputs to the PBP calculation are the total installed costs to the consumer of 

the equipment for each efficiency level and the average annual operating expenditures for 

each efficiency level in the first year. The PBP calculation uses the same inputs as the 

LCC analysis, except that discount rates are not used. 

Interested parties raised several concerns regarding the LCC and PBP analyses. 

American Panel commented that the LCC and PBP presented in the preliminary analysis 

may be inaccurate because the refrigeration systems were not properly matched to the 

walk-in envelope, and the refrigeration system would be oversized for food safety and 

have a shorter run time. American Panel recommended that DOE select the refrigeration 

system capacity based on the heat load of the envelope size to achieve realistic LCC and 

PBP results. (American Panel, No. 0048.1 at p. 8) To account for this possibility, the 

current analysis now assumes that the refrigeration system is oversized by 20 percent 

over the aggregate refrigeration load of the walk-in unit. 

American Panel submitted several comments relating to PBP issues for specific 

market segments. During the public meeting, American Panel commented that small 

business owners, such as non-chain restaurants or independent food service operators, 

generally attempt to avoid higher first costs due to the uncertainty of business success, 

while food service franchisees can afford to consider a longer term view of future 
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savings. (American Panel, Public Meeting Transcript, No. 0045 at p. 252) American 

Panel cited data from the National Restaurant Association indicating that approximately 

70 percent of all restaurants and 90 percent of small restaurants that open in the same 

building as a previously failed business fail in the first year due to insufficient up-front 

capital. American Panel predicted from these data that increased equipment costs 

resulting from new energy standards would have a serious negative impact on the small 

business restaurant owner, especially during the first year of restaurant operation, and that 

these entities would be able to sustain equipment efficiency improvements with a 

payback period of only 1 year or less. (American Panel, No. 0048.1 at p. 10) Owners and 

operators of franchised restaurant chains could afford to consider a longer payback period 

(e.g., 2 years or more). (American Panel, Public Meeting Transcript, No. 0045 at p. 254)

DOE will continue to use the standard LCC and PBP methods to convey the 

economic impacts of energy efficiency standards on walk-ins. DOE recognizes the 

particular PBP considerations of various market segments, however, including small 

businesses and independent restaurants. In preparing this NOPR, DOE examined the 

“business lifetime” (also referred to as the “economic lifetime”), which is an issue 

prevalent in the restaurant market sector. According to submitted comments, the 

economic lifetime of WICF equipment used in certain businesses may significantly differ 

from the operational lifetime. This issue could potentially impact the LCC and NIA 

analyses and is further discussed in section IV.G.1.b of this document. The walk-in 

lifetime details are also discussed in chapter 8 of the TSD. 
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15.12. Rebuttable-Presumption Payback Period

As noted above, EPCA, as amended, establishes a rebuttable presumption that a 

standard is economically justified if the Secretary finds that the additional cost to the 

consumer of purchasing a product that complies with an energy conservation standard 

level will be less than three times the value of the consumer’s first-year energy (and, as 

applicable, water) savings derived as a result of the standard, as calculated under the test 

procedure in place for that standard. (42 U.S.C. 6295(o)(2)(B)(iii)) For each considered 

efficiency level, DOE determined the value of the first year’s energy savings by 

calculating the quantity of those savings in accordance with the applicable DOE test 

procedure, and multiplying that amount by the average energy price forecast for the year 

in which compliance with the new standard would be required. 

American Panel commented that the 3-year PBP established in EPCA should be 

decreased to 1 or 1.5 years at the most. (American Panel, No. 0048.1 at p. 11) DOE 

acknowledges the economic impacts on small businesses resulting from implementing 

energy efficiency standards but has maintained the 3-year PBP guideline as an initial step 

for determining economic justification, consistent with 42 U.S.C. 6295(o). However, 

DOE routinely conducts a full economic analysis that considers the full range of impacts 

to the consumer, manufacturer, nation, and environment and will consider other 

applicable criteria in determining whether a proposed standard is economically justified, 

including impacts on small businesses. For the results of DOE’s detailed analysis of 

economic impacts on commercial customers and manufacturers, see sections V.B.1 and 

V.B.2. 

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For the NOPR analysis, DOE calculated a rebuttable presumption payback period 

at each TSL for WICF equipment. Rather than using distributions for input values, DOE 

used discrete values and, as required by EPCA, based the calculation on the assumptions 

in the DOE WICF test procedure. As a result, DOE calculated a single rebuttable 

presumption payback value, rather than a distribution of payback periods. Table IV-14

and Table IV-15 show the rebuttable presumption payback periods at TSL 4 for 

refrigeration systems and envelope components, respectively. 

Table IV-14 WICF Refrigeration Systems Rebuttable Payback Period at TSL 4

LIX. Equipment 

Class

Equipment 

Capacity

(kBTU/hr)

Compressor Type Analyzed Rebuttable Payback Period

DC.M.I.SEM, < 

9,000

6 SEM 3.54.7

DC.M.I.SCR, ≥ 9,000 18 SCR 1.98

DC.L.I.HERM.O, < 9,000 6SEM HER3.9 2.1

DC.L.I.SCRM.O, ≥ 

9,000

9 SCR 23.1

DC.M.O.SEML.I, < 9,000 6SCR SEM2.1 3.8

DC.M.O.SCRL.I, ≥ 

9,000

18 SCR 2.73

DC.L.O.HER, < 9,000 6SCR HER1.7 2.5

DC.L.O.SCR, ≥ 

9,000

9 SCR 3.51

MC.M.N 9- - 0.68

MC.L.N 9- - 0.87

Table IV-15 WICF Envelope Components Rebuttable Payback Period at TSL 4

LX. Equipment 

Class LXI. Equipment Size LXII. Rebuttable Payback Period

SP.M

Small 4.15.3

Medium 4.05.2

Large 4.05.1

SP.L

Small 2.83.1

Medium 3.68

Large 4.01

FP.L

Small 3.28

Medium 4.46

Large 5.31

DD.M Small 52.5

Medium 4.72.2

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While DOE examined the rebuttable-presumption criterion, it considered whether 

the standard levels considered are economically justified through a more detailed analysis 

of the economic impacts of these levels consistent with the approach laid out in 42 U.S.C. 

6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE to evaluate the 

economic justification for a potential standard level (thereby supporting or rebutting the 

results of any preliminary determination of economic justification).

A.G. National Impact Analysis – National Energy Savings and Net Present Value

The NIA assesses the national energy savings (NES) and the net present value 

(NPV) of total consumer costs and savings that would be expected to result from the new 

energy conservation standards. (“Consumer” in this context refers to customers of the 

product being regulated.) The NES and NPV are analyzed at specific efficiency levels 

separately for the refrigeration systems and components of the envelope (panels, nondisplay doors, and display doors). DOE calculates the NES and NPV based on 

projections of annual equipment shipments, along with the annual energy consumption 

Large 4.81.9

DD.L

Small 6.4N/A

Medium 6.5N/A

Large 7.0.4

PD.M

Small 4.6.2

Medium 4.76.1

Large 4.76.0

PD.L

Small 3.54.7

Medium 4.07

Large 2.94.6

FD.M

Small 4.6.0

Medium 4.6.0

Large 4.65.9

FD.L

Small 3.85

Medium 2.84

Large 2.74

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and total installed cost data from the energy use and LCC analyses. For the NOPR 

analysis, DOE forecasted the energy savings, operating cost savings, product costs, and 

NPV of consumer benefits for products sold from 20152017 through 2071—2073 -- the 

year in which the last standards- -- compliant equipment shipped during the 30-year 

analysis period beginning in 2015 retires2017 operates. 

DOE evaluates the impacts of the new standards by comparing base-case 

projections with standards-case projections. The base-case projections characterize 

energy use and consumer costs for each productequipment class in the absence of any 

new energy conservation standards. DOE compares these projections with projections 

characterizing the market for each productequipment class if DOE adopted the new 

standard at specific energy efficiency levels (that is, the TSLs or standards cases) for that 

productequipment class. For the base case forecast, DOE considered a mix of two levels 

of efficiency for the refrigeration systems and a single efficiency level for the 

components, except for cooler display doors as noted in Table IV-16. For the standards 

cases, DOE considered a “roll-up” scenario in which DOE assumes that product 

efficiencies that do not meet the standard level under consideration would roll-up to meet 

the new standard level, and those already above the proposed standard level would 

remain unaffected. 

DOE uses a Microsoft Excel spreadsheet model to calculate the energy savings 

and the national consumer costs and savings from each TSL. The NOPR TSD and other 

documentation that DOE provides during the rulemaking helps explain the models and 
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how to use them and also allow interested parties to review DOE’s analyses. The NIA 

spreadsheet model uses average values as inputs (as opposed to probability distributions 

of key input parameters from a set of possible values).

For the current analysis, the NIA used projections of energy prices and 

commercial building starts from the AEO2010AEO2013 Reference case. In addition, 

DOE analyzed scenarios that used inputs from the AEO2010AEO2013 Low Economic 

Growth and High Economic Growth cases. These cases have higher and lower energy 

price trends compared to the Reference case, as well as higher and lower commercial 

building starts, which result in higher and lower walk-in shipments to new commercial 

buildings. NIA results based on these cases are presented in appendix 10-A10E of the 

NOPR TSD.

Table IV-16 summarizes the inputs and key assumptions DOE used for both the 

preliminary analysis and NOPR with respect to the NIA analysis. Discussion of these 

inputs and changes follows the table. See chapter 10 of the NOPR TSD for further 

details.
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Table IV-16 Summary of Inputs and Key Assumptions for the National Impact 

Analysis

LXIII. Inputs LXIV. Preliminary Analysis LXV. Changes for the NOPR 

Analysis

Shipments Annual shipments from the shipments 

model for complete walk-in units.

Annual shipments from the shipments 

model calculated separately for 

refrigeration systems and components.

Compliance Date of 

Standard

2015 No change.2017

Base-Case 

Forecasted 

Efficiencies

No efficiency distributions assumed for 

the base case and the current baseline 

level was assumed to represent the 

market for the forecasted shipments of 

complete walk-in systems.

EISA23

Panels and non-display doors.: For the 

EISA shipments, 100 percent of 

shipments are assumed to be at the 

baseline.

and Pre-EISA shipments are 

assumed to have a distribution of 

efficiencies at two levels for the 

refrigerationRefrigeration systems.: For 

the components, all EISA* shipments, 

75 percent of shipments are assumed to 

be at the baseline and 25 percent of 

shipments are assumed to have a 

singlebe equivalent to the first

efficiency level except forin the cooler 

engineering analysis.

Display doors: For EISA shipments, 25 

percent of cooler display doors shipped 

in the pre-EISA period, it is assumed 

that 20% of the shipped quantities are 

fitted with anti-sweat heaters and 

haveare assumed to be at the baseline 

and 75 percent are higher -efficiency 

levels. (45 percent with LED lighting 

and 30 percent with LED lighting and 

lighting controls); and 80 percent of 

freezer doors are assumed to be at the 

baseline and 20 percent are higherefficiency (with LED lighting).

Standards-Case 

Forecasted 

Efficiencies

No efficiency distributions assumed for 

the standards case. A single efficiency 

level was assumed to represent the 

market for the forecasted shipments of 

complete walk-in systems.

No efficiency distributions assumed for 

the standards casecompliant shipments. 

Shipped efficiencies for the forecasted 

shipments of refrigeration systems and 

components are represented by a roll up 

to the minimum standard level being 

analyzed.

Annual Energy 

Consumption per 

Unit

DOE calculated the average annual 

energy use for each WICF envelope 

class matched with outdoor condenser 

DOE changed the daily load profile of

the refrigeration system to 13.3 hours 

runtime per day for coolers and 15 

 

23 EISA 2007 amended EPCA to establish prescriptive standards for walk-in coolers and freezers 

manufactured on or after January 1, 2009. EISA shipments refer to the shipments complying with these 

prescriptive standards. Pre-EISA shipments refer to shipments before 2009 when there was no Federal 

energy efficiency standard in place.

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systems using a load profile described in 

AHRI 1250-2009 (8 hours of high load 

and 16 hours of low load per day).

hours for freezers, at full rated capacity 

corresponding to the reference rating 

outside air temperatures. 

Total Installed Cost 

per Unit

Manufacturer’s selling price is estimated 

from Engineering Analysis. Installation 

costs are based on RS Means 

Mechanical Cost Data 2009. Assumed 

no change with efficiency level.

Updated to RS Means Mechanical Cost 

Data 20102012. 

Annual Energy Cost 

per Unit

Annual Energy consumption per unit 

was multiplied by the Annual energy 

cost. Costs were discounted and summed 

over the analysis period for the net 

present value calculations. 

No change.

Repair and 

Maintenance Cost 

per Unit

Annualized repair and maintenance costs 

of the combined system were derived 

from RS Means 2009 walk-in cooler and 

freezer maintenance data. Doors and 

refrigeration systems could be replaced 

during the lifetime of the envelope.

Updated to RS Means 20102012 walkin cooler and freezer repair and 

maintenance data; repair and 

maintenance costs for the refrigeration 

system and the envelope components 

were estimated separately.

Energy Prices Forecasted using AEO2009 price 

forecasts.

Updated to AEO2010AEO2013

forecasts.

Energy Site-toSource Conversion 

Factor

Varies yearly and is generated by 

NEMS-BT (2009); applied from 2014 

through 2045. 

Updated to modified NEMS-BT

(2010** (2012), and applied from 

20142017 through 20712073. 

Discount Rate 3% and 7% real. No change.

Present Year Future expenses discounted to 2010. No change.Future expenses discounted 

to 2013

*EISA 2007 amended EPCA to establish prescriptive standards for walk-in coolers and freezers 

manufactured on or after January 1, 2009. EISA shipments refer to the shipments complying with these 

prescriptive standards. This is in contrast to pre-EISA shipments, which would refer to shipments before 

2009 when there was no Federal energy efficiency standard in place.

**Site-to-source factors modified by Lawrence Berkley National Laboratories.

American Panel noted that the NIA results in the preliminary analysis were not 

meaningful because the refrigeration system capacities were not properly matched to the 

walk-in envelope. As stated earlier in the LCC and PBP sections, American Panel 

contended that DOE should select the refrigeration system capacity based on the 

envelope heat load to make the economic analyses realistic. (American Panel, No. 0048.1 

at p. 11) In the NOPR, DOE conducted the NIA analysis for the refrigeration systems and 

the selected envelope components independent of each other and then combined the 

results to arrive at the trial standard levels. This approach did not directly pair the walk-in 

units with the matched capacity refrigeration system because minor inconsistencies in the 

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matching of individual units could have large effects on the overall NIA results, as noted 

by American Panel. Rather, the NOPR analysis involved combining the results in the 

aggregate to arrive at a more accurate estimate of overall energy savings across the range 

of covered equipment. 

 

1. Shipments

Forecasts of product shipments are used to calculate the national impacts of 

standards on energy use, NPV, and future manufacturer cash flows. DOE developed 

shipment forecasts for refrigeration systems and envelope components based on an 

analysis of growth trends of specific building types housing the walk-in units. In DOE’s 

shipments model, shipments of walk-in units and their components are driven by new 

purchases and stock replacements due to failures. The envelope component model and 

refrigeration system shipments model take an accounting approach, tracking market 

shares of each productequipment class and the vintage of units in the existing stock. 

Stock accounting uses product shipments as inputs to estimate the age distribution of inservice product stocks for all years. The age distribution of in-service product stocks is a 

key input to calculations of both the NES and NPV because operating costs for any year 

depend on the age distribution of the stock. DOE also considers the impacts on shipments 

from changes in product purchase price and operating cost associated with higher energy 

efficiency levels.

American Panel, NEEA and NPCC suggested that DOE contact the National 

Association of Food Equipment Manufacturers (NAFEM),) and major refrigeration 

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system manufacturers such as Heatcraft and Russell, to obtain shipment information. 

(American Panel, Public Meeting Transcript, No. 0045 at pp. 274–275; NEEA and 

NPCC, Public Meeting Transcript, No. 0045 at p. 281) DOE contacted NAFEM, which 

provided DOE with copies of that organization’s “Size and Shape of the Industry” 

reports. These reports contain data on the annual sales of walk-in units in the food service 

sector for 2002–2010. DOE analyzed the data received from NAFEM and also obtained 

other data from manufacturer interviews and other sources. DOE used these data to 

develop equipment class size share distributions, and are documented in the current 

shipment models.

a. Share of Shipments and Stock Across Equipment Classes

In response to the shipments analysis results in the preliminary analysis, DOE 

received several comments regarding the share of shipments and stock across 

productequipment classes, dedicated condensing and multiplex systems, indoor and 

outdoor systems, cooler and freezer envelopes, and envelope sizes. 

In the preliminary analysis, DOE estimated that 46 percent of the existing stock of 

walk-in systems is served by multiplex systems. American Panel commented that the 

ratio between multiplex to dedicated condensing refrigeration systems was too high and 

stated that, historically, 68 percent of their sales are for dedicated condensing 

refrigeration systems. American Panel suggested that DOE’s estimate of the share of 

stocks of dedicated condensing refrigeration systems should be 70 percent. (American 

Panel, Public Meeting Transcript, No. 0045 at pp. 192 and 275; American Panel, No. 

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0048.1 at p. 4) Heatcraft supported this observation by stating that multiplex medium 

temperature refrigeration system stock share should be only 15 percent. (Heatcraft, Public 

Meeting Transcript, No. 0045 at p. 269) 

DOE considered these comments and re-examined its analyses in developing its 

revised analysis for the NOPR. As part of this revised analysis, DOE developed a 

shipment model that provided the key inputs required by the shipment models for the 

envelope components and refrigeration systems. Based on this shipment analysis, DOE 

estimated that dedicated condensing units account for approximately 70 percent of the 

refrigeration market and the remaining 30 percent consists of unit coolers connected to 

multiplex condensing systems. DOE estimated that medium temperature unit coolers 

connected to multiplex systems account for about 25 percent of the shipments and stock. 

Regarding American Panel’s comment on the relative shares of stock between the 

multiplex and the dedicated condensing refrigeration systems shown in the preliminary 

TSD (Table 3.2.8), DOE noted that Table 3.2.8 addressed shipments and not refrigeration 

system stock data. (American Panel, Public Meeting Transcript, No. 0045 at p. 269) 

DOE received two comments regarding the stock share for outdoor and indoor 

dedicated condensing refrigeration systems. Heatcraft stated that a 30 percent share for 

outdoor dedicated condensing refrigeration systems was a reasonable assumption for 

DOE’s economic analyses. (Heatcraft, Public Meeting Transcript, No. 0045 at p. 268) 

Manitowoc stated that the share of indoor dedicated condensing refrigeration systems 

should be higher than predicted, approximately 10 percent. (Manitowoc, Public Meeting 
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20131002_OIRA compare document dated 9-26.docx

Transcript, No. 0045 at p. 274) DOE considered these comments in light of other 

available data and estimated for the NOPR analysis that approximately 6566 percent and 

53 percent of the shipments and stocks of the refrigeration systems are accounted for by 

the outdoor and indoor dedicated condensing refrigeration systems, respectively. 

Regarding the relative shares of stock or shipment between walk-in coolers and 

freezers, American Panel commented that DOE’s estimates of 70 percent and 30 percent 

shares for cooler and freezer envelopes, respectively, were reasonable. (American Panel, 

Public Meeting Transcript, No. 0045 at p. 275) DOE has slightly adjusted these estimates 

in the NOPR shipment model to 71 percent (coolers) and 29 percent (freezers) based on 

updated calculations and data. 

NEEA and NPCC stated that DOE correctly apportioned walk-ins by business 

type in the preliminary analysis, but noted that significant market shifts are taking place 

in the grocery and convenience store sectors. (NEEA and NPCC, No. 0059.1 at p. 11) 

NEEA and NPCC did not elaborate on the significance or nature of the market shifts. 

American Panel stated that DOE’s estimate of twice as many large walk-in coolers as 

small walk-in coolers seemed inaccurate, and stated it would provide data. (American 

Panel, Public Meeting Transcript, No. 0045 at p. 293) American Panel then submitted a 

written comment with its own historical shipment data showing that walk-in cooler and 

freezer shipments for small, medium, and large units are 40 percent, 56 percent, and 4 

percent, respectively, which differs significantly from DOE’s estimates of 14 percent, 58 

percent, and 28 percent for small, medium, and large units, respectively, in the 
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preliminary analysis. (American Panel, No. 0048.1 at p. 11) In the NOPR analysis, DOE 

adjusted its estimates based in part on American Panel’s feedback. For the NOPR, DOE 

estimated that size distributions of stocks and shipments of walk-in units are 52 percent, 

40 percent, and 8 percent for small, medium, and large, respectively. 

b. Lifetimes and Replacement Rates

As discussed in the previous section on LCC and PBP analyses, the preliminary 

analysis assumed an envelope lifetime of approximately 15 years. American Panel agreed 

with DOE’s 15-year lifetime estimate for the envelopes. (American Panel, Public 

Meeting Transcript, No. 0045 at p. 283) Kysor mentioned that the envelope lifetime 

could vary depending on the traffic within it. For example, an 8- to 10-year envelope 

lifetime can be expected if pallet jack or forklifts are used in the walk-in, while a longer 

envelope lifetime is likely if activity is limited to foot traffic or lighter hand trucks. 

(Kysor, Public Meeting Transcript, No. 0045 at p. 287) Master-Bilt suggested that most 

envelopes have a 20-year lifetime. (Master-Bilt, No. 0046.1 at p. 1) American Panel 

concurred with the 5 percent replacement rate for walk-in cooler and freezer envelopes, 

which corresponds to a 20-year lifetime. (American Panel, No. 0048.1 at p. 11) AHRI 

commented that based on its own experience, it believes envelope wall and floor panels

tend to have a longer lifetime—12 to 25 years would be typical—but provided no data in 

support of this view. (AHRI, No. 0055.1 at p. 4) Hill Phoenix noted that failure of 

envelope components is usually evident by visual inspection, and panels would not 

usually fail from condensation or ice formation in the insulation. (Hill Phoenix, No. 

0066.1 at p. 3) Given that most of these comments provided only anecdotal evidence and 

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not supporting data, In view of the comments provided by interested parties during the 

preliminary analysis, DOE continues to assume a 15-year average lifetime for panels in 

the current analysis. 

DOE assumed the typical lifetime of envelope doors to be 5 years in the 

preliminary analysis. American Panel commented that the door replacement rate of 5 

years is not supported by its in-house data, which show a door replacement rate of 5 

percent, with the door lasting throughout the walk-in cooler and freezer envelope 

lifetime. (American Panel, No. 0048.1 at p. 9) In addition, American Panel stated that the 

number of replacement non-display doors represented 5 percent of their annual door 

shipments, which is inconsistent with the assumption that doors only last 5 years. 

(American Panel, Public Meeting Transcript, No. 0045 at p. 14 and p. 284) In light of 

these comments on the door replacement rates, DOE has revised its assumptions of door 

lifetimes to more closely match envelope lifetimes. The NOPR shipment model assumes 

an average lifetime of approximately 14 years for both display and non-display doors. 

For refrigeration systems, DOE assumed an average lifetime of 7 years in the 

preliminary analysis. Master-Bilt stated that refrigeration system lifetimes were 

comparable to the envelope lifetime of approximately 20 years -- —it estimated that

refrigeration system lifetimes would be about 80–100 percent of envelope lifetimes. 

(Master-Bilt, Public Meeting Transcript, No. 0045 at p. 287) Master-Bilt also stated that a 

15 percent replacement rate for the refrigeration systems, which corresponds to a lifetime 

of 7 years, is too high, and actual replacement rates should be only half as much. (Master-
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Bilt, No. 0046.1 at p. 1) AHRI stated that a typical mechanical equipment lifetime is 

between 8 and 12 years. (AHRI, No. 0055.1 at p. 4) Master-Bilt also mentioned that the 

economy has reduced the frequency at which walk-in coolers and freezers are completely 

replaced with new equipment because of the high cost. Instead, existing equipment is 

often being refurbished with users typically replacing only one or a few individual 

components. (Master-Bilt, No. 0046.1 at p. 1) Master-Bilt also stated that doors are the 

most commonly repaired or replaced envelope component, while the most common 

replacement part for a refrigeration system is the compressor. It noted that only 5 percent 

of refrigeration systems require replacement compressors over a 10-year span. (MasterBilt, Public Meeting Transcript, No. 0045 at p. 287) American Panel agreed that the 

entire refrigeration system is not typically replaced and only a compressor or fan motor is 

replaced when the system fails. Consequently, American Panel disagreed with the 15 

percent average replacement rate used in the preliminary analysis for the refrigeration 

systems and suggested DOE use a refrigeration system replacement rate of 10 percent. 

(American Panel, No. 0048.1 at p. 11) In view of the comments received from interested 

parties, DOE revised its assumption of the average lifetime of the refrigeration system to 

12 years, corresponding to a replacement rate of about 8 percent. 

In the preliminary analysis, DOE assumed a higher replacement rate for 

refrigeration systems than for envelopes. American Panel commented that DOE’s 

estimated shipment ratio of 3 to 1 between refrigeration systems and envelopes was too 

high and that a more appropriate shipment ratio between refrigeration systems and 

envelopes would be about 1.3 to 1. (American Panel, Public Meeting Transcript, No. 
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0045 at p. 192 and No. 0048.1 at p. 4) As explained, in the NOPR shipment model, the 

refrigeration system lifetime has been revised downward from 15 to 12 years. (DOE has 

retained the 15-year lifetime for envelopes.) In the revised shipment model, refrigeration 

system replacements account for about 30–41 percent of all refrigeration system 

shipments. While this estimate exceeds the suggested shipment ratio of 1.3, DOE 

believes that the average lifetimes of walk-in envelopes and refrigeration systems, which

are based on manufacturer interviews and stakeholder comments, are reasonable.

NEEA and NPCC stated that economic lifetimes are different from physical 

lifetimes and suggested that DOE use both economic and physical lifetimes depending on 

the building type in which the walk-in cooler and freezer resides. (NEEA and NPCC, No. 

0059.1 at p. 11) The physical lifetime refers to the duration before the equipment fails or 

is replaced, whereas the economic lifetime refers to the duration before the walk-in cooler 

and freezer equipment is taken out of service because the owner is no longer in business. 

In the event of an economic lifetime failure, however, a WICF would likely not leave the 

national stock, but would instead be sold to a third party, which would represent a 

transfer of goods and would not impact WICF shipments or stock at a national level. For 

a more detailed discussion of economic lifetimes see life-cycle cost discussion in section 

IV.F.7. 

c. Growth Rates

The preliminary analysis used a shipments growth rate of approximately 2 

percent. Several interested parties commented on this assumption. American Panel agreed 

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with DOE’s assumption that walk-in growth will match growth seen in building stock 

square footage. (American Panel, No. 0048.1 at p. 11) Others stated that the preliminary 

analysis shipment growth rate was overestimated. AHRI, NEEA and NPCC predicted 

that the walk-in market would be flat and any growth would be less than 1 percent. 

(AHRI, No. 0055.1 at p. 4; NEEA and NPCC, Public Meeting Transcript, No. 0045 at p. 

292) Master-Bilt, NEEA and NPCC stated that the shipment analysis should use a 

maximum growth rate of 1 percent. (Master-Bilt, No. 0046.1 at p.1; NEEA and NPCC, 

Public Meeting Transcript, No. 0045 at p. 292) One stakeholder stated that its business 

has grown annually at a simple rate of 10 percent, although it added that this may not be 

representative and may have been driven by gaining market share from other 

manufacturers. (American Panel, Public Meeting Transcript, No. 0045 at pp. 290–291) 

American Panel suggested that NAFEM may provide walk-in growth rates across 

industry. American Panel observed that shipments grow about 7 percent in normal 

financial times; however, they can decline 10 percent per year during a recession. In 

particular, the restaurant sector business has dropped by 60 percent while walk-in cooler 

and freezer business in the school sector has grown. (American Panel, No. 0048.1 at p. 

11) Considering these stakeholder comments, DOE modeled its growth rate projections 

for the NOPR analysis by adjusting the rate downward to 1 percentusing the commercial 

building floor space growth rates from the AEO 2013 NEMS-BT model. 

d. Other Issues

DOE developed a core shipment model for estimating the annual shipments and 

stocks of complete WICFs that formed the basis for the shipment analysis of refrigeration 

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systems and envelope components. DOE expressed annual shipments and stocks of 

refrigeration systems in terms of installed refrigeration capacity (Btu/h) which required 

DOE to estimate the required refrigeration capacity for the WICF units shipped. As part 

of the process, product loads were estimated for different envelope sizes and types. 

In the preliminary analysis, product load estimates were central to the annual 

energy consumption projections and were presented in the same context. American Panel 

stated that while the product-specific heat and product pull-down temperature values used 

in the preliminary analysis were correct, it disagreed with the product-loading values 

assumed for various types of equipment. American Panel suggested that the productloading estimates should be 2 pounds per cubic foot for small coolers and 1 pound per 

cubic foot for medium and large coolers (not 4 and 2 respectively, as DOE had assumed), 

and 1 pound per cubic foot for small, medium, and large freezers (not 1 for small freezers 

and 0.5 for medium and large freezers, as DOE had assumed). (American Panel, Public 

Meeting Transcript, No. 0045 at p. 209) Master-Bilt stated that it is difficult to have 

product load assumptions that are valid for all applications and DOE should explicitly 

state that the product load assumptions currently used are valid only for specific 

situations but may not necessarily be representative of all applications. (Master-Bilt, No. 

0046.1 at p. 1) 

DOE agrees with Master-Bilt’s observation that it is it is difficult to make 

assumptions on product load that are valid for all sizes and all applications. DOE 

revisited the issue and concluded that the loading ratios indicated by American Panel
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could be representative of the food service segment of the market, which accounts for 

about 35 percent of the aggregate installed refrigeration capacity for the walk-ins. From 

the available product brochures and indicated product loads for different sizes of WICF 

equipment, DOE believes that the loading ratios used for the other market segments are

closer to ratios used in the preliminary analysis. Consequently, DOE did not change the 

loading ratios for the NOPR analysis. 

2. Forecasted Efficiency in the Base Case and Standards Cases

A key component of the NIA is the trend in energy efficiency forecasted for the 

base and standards cases. Using data collected from manufacturers and an analysis of 

market information, DOE developed a base-case energy efficiency distribution (which 

yields a shipment-weighted average efficiency) for each of the considered 

productequipment classes for the first year of the forecast period. To project the

efficiency trend over the entire forecast period, DOE considered the current market 

distribution and recent trends. For envelope components, all base case shipments are 

assumed to have only a single EPCA-compliant efficiency level except for cooler display 

doors. For cooler display doors, shipments would be a mix of 25 percent EPCAcompliant equipment and 75 percent higher efficiency equipment. For freezer display 

doors, shipments would be a mix of 80 percent EPCA-compliant equipment and 20 

percent higher efficiency equipment. For refrigeration systems, DOE assumed, based on 

manufacturer interviews, that in the absence of standards (the base case), shipments 

would be a mix of 75 percent EPCA-compliant equipment and 25 percent higher 

efficiency equipment. For both refrigeration systems and envelope components, DOE 

assumed no improvement of energy efficiency in the base case and held the base-case 

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energy efficiency distribution constant throughout the forecast period. DOE requests 

comment on this assumption.

To estimate efficiency trends in the standards cases, DOE has used a “roll-up” 

scenario in its standards rulemakings. The roll-up scenario represents a standards case in 

which all product efficiencies in the base case that do not meet the standard would roll up 

to meet the new standard level. Consumers in the base case who purchase walk-in 

equipment above the standard level are not affected as they are assumed to continue to 

purchase the same equipment. The roll-up scenario characterizes consumers primarily

driven by the first-cost of the analyzed products and characterizes the efficiency trends 

currently found in the market.

Under In summary, under the roll-up scenario DOE 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. 

3. National Energy Savings

For each year in the forecast period, DOE calculates the NES for each standard 

level by multiplying the stock of equipment affected by the energy conservation 

standards by the per-unit annual energy savings. DOE typically considers the impact of a 

rebound effect, introduced in the energy-use analysis, in its calculation of national energy 

savings for a given product. A rebound effect occurs when users operate higher efficiency 

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equipment more frequently and/or for longer durations, thus offsetting estimated energy 

savings. However, DOE assumed a rebound factor of one, or no effect, because walk-ins 

must cool their contents at all times and it is not possible for consumers to operate them 

more frequently. For a further discussion of the rebound effect, see chapter 10 of the 

TSD. DOE seeks comment on the assumption that there is no rebound effect associated 

with these products.

To estimate the national energy savings expected from appliance standards, DOE 

uses a multiplicative factor to convert site energy consumption (at the home or 

commercial building) into primary or source energy consumption (the energy required to 

convert and deliver the site energy). These conversion factors account for the energy used 

at power plants to generate electricity and losses in transmission and distribution, as well 

as for natural gas losses from pipeline leakage and energy used for pumping. For 

electricity, the conversion factors vary over time due to projected changes in generation 

sources (that is, the power plant types projected to provide electricity to the country). The 

factors that DOE developed are marginal values, which represent the response of the 

system to an incremental decrease in consumption associated with appliance standards.

In the preliminary analysis, DOE used annual site-to-source conversion factors 

based on the version of NEMS that corresponds to AEO2009. For this NOPR, DOE 

updated its conversion factors based on the U.S. energy sector model NEMS-BT

corresponding to AEO2013. 
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Section 1802 of the Energy Policy Act of 2005 (EPACT 2005) directed DOE to 

contract a study with the National Academy of Science (NAS) to examine whether the 

goals of energy efficiency standards are best served by measuring the amount of energy 

consumed and the impact of efficiency improvements at the actual point-of-use or 

through the use of the full-fuel-cycle, which would begin at the source of energy 

production. (Pub. L. No. 109-58 (Aug. 8, 2005)). NAS appointedhas historically 

presented NES in terms of primary energy savings. In response to the recommendations 

of a committee on “Point-of-Use and Full-Fuel-Cycle Measurement Approaches to 

Energy Efficiency Standards” to conduct the study, which was completed in May 2009. 

The NAS committee defined full-fuel-cycle energy consumption as including, in addition 

to site energy use, the following: energy consumed in the extraction, processing, and 

transport of primary fuels such as coal, oil, and natural gas; energy losses in thermal 

combustion in power generation plants; and energy losses in transmission and 

distribution to homes and commercial buildings.24 

In evaluating the merits of using point-of-use and full-fuel-cycle measures, the 

NAS committee noted that appointed by the National Academy of Science, DOE uses 

what the committee referred to as “extended site” energy consumption to assess the 

impact of energy use on the economy, energy security, and environmental quality. The 

extended site measure of energy consumption includes the energy consumed during the 

generation, transmission, and distribution of electricity, but, unlike the full-fuel-cycle 

 

24 The National Academies, Board on Energy and Environmental Systems, Letter to Dr. John Mizroch, 

Acting Assistant Secretary, U.S. DOE, Office of EERE from James W. Dally, Chair, Committee on Pointof-Use and Full-Fuel-Cycle Measurement Approaches to Energy Efficiency Standards, May 15, 2009.
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measure, does not include the energy consumed in extracting, processing, and 

transporting primary fuels. A majority of the NAS committee concluded that extended 

site energy consumption understates the total energy consumed to make an appliance 

operational at the site. As a result, the NAS committee recommended that DOE consider 

shiftingannounced its analytical approach over time to use a full-fuel-cycle measure of 

energy consumption when assessing national and environmental impacts, especially with 

respect to the calculation of greenhouse gas emissions. The NAS committee also 

recommended that DOE provide more comprehensive information to the public through 

labels and other means, such as an enhanced website. For those appliances that use 

multiple fuels, such as water heaters, the NAS committee indicated that measuring fullfuel-cycle energy consumption would provide a more complete picture of energy 

consumed and permit comparisons across many different appliances, as well as an 

improved assessment of impacts.

In response to the NAS recommendations, DOE issued, on August 20, 2010, 

(75 FR 51423), a Notice of Proposed Policy proposing to incorporate a full-fuel cycle 

analysis into the methods it uses to estimate the likely impacts of energy conservation 

standards on energy use and emissions. Specifically, DOE proposedintention to use fullfuel-cycle (FFC) measures of energy and greenhouse gas (GHG) emissions, rather than 

the primary (extended site) energy measurement it currently uses. Additionally, DOE 

proposed to work collaboratively with the Federal Trade Commission (FTC) to make 

FFC energy and GHG emissions data available to the public to enable consumers to make 

cross-class comparisons. On October 7, 2010, DOE held an informal public meeting to 

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discuss and receive comments on its planned approach. The materials related to this 

proposed policy are available at: 

www.regulations.gov/search/Regs/home.html#docketDetail?R=EERE-2010-BT-NOA0028. DOE recently published a final policy statement addressing this issue.use and 

greenhouse gas and other emissions in the national impact analyses and emissions 

analyses included in future energy conservation standards rulemakings. 76 FR 51281 

(Aug.August 18, 2011).) While DOE stated in that notice that it intended to use the 

Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) 

model to conduct the analysis, it also said it would review alternative methods, including 

the use of NEMS. After evaluating both models and the approaches discussed in the 

August 18, 2011 notice, DOE published a statement of amended policy in the Federal 

Register in which DOE explained its determination that NEMS is a more appropriate tool 

for its FFC analysis and its intention to use NEMS for that purpose. 77 FR 49701 

(August 17, 2012). DOE received one comment, which was supportive of the use of 

NEMS for DOE’s FFC analysis.25 

The approach used for today’s NOPR, and the FFC multipliers that were applied, 

are described in appendix 10G of the NOPR TSD. NES results are presented in both 

primary and summarized by TSL in terms of FFC savings in section V.B.3.a.

 

25 Docket ID: EERE-2010-BT-NOA-0028, comment by Kirk Lundblade.

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4. Net Present Value of Consumer Benefit

The inputs for determining the NPV of the total costs and benefits experienced by 

walk-in equipment consumers are: (1) total annual installed cost; (2) total annual savings 

in operating costs; and (3) a discount factor. DOE calculates net savings each year as the 

difference between the base case and each standards case in total savings in operating 

costs and total increases in installed costs. DOE calculates operating cost savings over the 

life of each product shipped induring the forecast period. 

DOE multiplies the net savings in future years by a discount factor to determine 

their present value. For the preliminary analysis, DOE estimated the NPV of appliance 

consumer benefits using both a 3 percent and a 7 percent real discount rate. The 7 percent 

real value is an estimate of the average before-tax rate of return to private capital in the 

U.S. economy. The 3 percent real value represents the “societal rate of time preference,” 

which is the rate at which society discounts future consumption flows to their present. 

NEEA and NPCC urged DOE to focus on the 3-percent discount rate as the primary basis 

for the analyses because the issues largely pertain to the aggregate costs and benefits 

accruing to society at large. (NEEA and NPCC, No. 0059.1 at p. 12) DOE uses these 

discount rates in accordance with guidance provided by the Office of Management and 

Budget (OMB) to Federal agencies on the development of regulatory analysis.26

 

26 OMB Circular A-4 (Sept. 17, 2003), section E, “Identifying and Measuring Benefits and Costs.” 

Available at: 

Therefore, for today’s NOPR, DOE continued to estimate the NPV of appliance 

www.whitehouse.gov/omb/memoranda/m03-21.html. 

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consumer benefits using both a 3 percent and a 7 percent real discount rate as directed by 

OMB.

5. Benefits from Effects of Standards on Energy Prices

The reduction in electricity consumption associated with new standards for walkins could reduce the electricity prices charged to consumers in all sectors of the economy 

and thereby reduce their electricity expenditures. In chapter 2 of the preliminary TSD, 

DOE explained that, because the power industry is a complex mix of fuel and equipment 

suppliers, electricity producers and distributors, it did not plan to estimate the value of 

potentially reduced electricity costs for all consumers associated with new or amended 

standards for walk-ins. 

For this rule, DOE used NEMS-BT to assess the impacts of the reduced need for 

new electric power plants and infrastructure projected to result from standards. In NEMSBT, changes in power generation infrastructure affect utility revenue requirements, which 

in turn affect electricity prices. DOE estimated the impact on electricity prices associated 

with each considered TSL. Although the aggregate benefits for electricity users are 

potentially large, there may be negative effects on some entities involved in electricity 

supply, particularly power plant providers and fuel suppliers. Given the uncertainty about 

the extent to which the benefits for electricity users from reduced electricity prices would 

be a transfer from those involved in electricity supply to electricity users, DOE continues

to investigate the extent to which electricity price changes projected to result from 

standards represent a net gain to society.

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B.H. Consumer Subgroup Analysis

In analyzing the potential impact of new or amended standards on commercial 

consumers, DOE evaluates the impact on identifiable groups (i.e., subgroups) of 

consumers, such as different types of businesses that may be disproportionately affected 

by an energy conservation standard. DOE gathered data for all business types identified 

in the analysis: grocery stores; convenience stores (including specialty food stores); 

convenience stores without gasoline stations; and restaurants that purchase their own 

walk-in coolers or freezers. 

Comments submitted by American Panel and Manitowoc recommended that DOE 

consider non-chain restaurants independently of chain restaurants. (American Panel, 

Public Meeting Transcript, No. 0045 at p. 252; Manitowoc, Public Meeting Transcript, 

No. 0045 at p. 254) Further comments by American Panel suggested that small 

restaurants are more vulnerable to potential economic consequences of an efficiency 

standard. (American Panel, No. 0048.1 at p. 10) DOE agrees with these comments and 

believes that its current models accurately represent chain restaurants because data used 

to characterize the restaurant business type is dominated by multi-establishment chain 

restaurants. Hence, small, non-chain restaurants are included in the subgroup analysis. 

After reviewing the data and submitted comments (see TSD chapter 11 for more 

details), DOE identified small restaurant owners because this subgroup likely includes 

owners of high-cost walk-in coolers and freezers, has the highest capital costs of all

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subgroups, and potentially experiences the shortest equipment economic lifetimes. These 

conditions make it likely that this subgroup will have the lowest life-cycle cost savings of 

any major consumer group. 

 

DOE estimated the impact on the identified consumer subgroup using the LCC 

spreadsheet model. The standard LCC and PBP analyses (described in section IV.F) 

include various types of businesses that own and use walk-in coolers and freezers. The 

LCC spreadsheet model allows for the identification of one or more subgroups of 

businesses, which can then be analyzed by sampling only each subgroup. The results of 

DOE’s LCC subgroup analysis are summarized in section V.B.1.bV.B and described in 

detail in chapter 11 of the TSD.

C.I. Manufacturer Impact Analysis

1. Overview 

DOE performed an MIA to estimate the financial impact of energy conservation 

standards on manufacturers of walk-in equipment and to calculate the impact of such 

standards on employment and manufacturing capacity. Manufacturers of panels, doors, 

and refrigeration, as well as manufacturers of completed walk-ins, were considered in the 

analysis. 

The MIA has both quantitative and qualitative aspects. The quantitative portion of 

the MIA primarily relies on the Government Regulatory Impact Model (GRIM), an 

industry cash-flow model customized for this rulemaking. The key GRIM inputs are data 

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on the industry cost structure, product costs, shipments, and assumptions about markups 

and conversion expenditures. The key output is the industry net present value (INPV). 

Different sets of assumptions (markup scenarios) will produce different results. The 

qualitative portion of the MIA addresses factors such as product characteristics and

industry and market trends. Chapter 12 of the NOPR TSD describes the complete MIA.

 

DOE conducted the MIA for this rulemaking in three phases. In Phase 1 of the 

MIA, DOE prepared a profile of the walk-in cooler and freezer industry, which includes a 

top-down cost analysis of manufacturers that DOE used to derive preliminary financial 

inputs for the GRIM (e.g., sales general and administration (SG&A) expenses; research 

and development (R&D) expenses; and tax rates). DOE used public sources of 

information, including company Securities and Exchange Commission (SEC) 10–K 

filings, Moody’s company data reports, corporate annual reports, the U.S. Census 

Bureau’s Economic Census, and Dun and Bradstreet reports.

In Phase 2 of the MIA, DOE prepared an industry cash-flow analysis to quantify 

the impacts of a new energy conservation standard. In general, new or more stringent 

energy conservation standards can affect manufacturer cash flow in three distinct ways: 

(1) create a need for increased investment, (2) raise production costs per unit, and (3) 

alter revenue due to higher per-unit prices and possible changes in sales volumes. 

In Phase 3 of the MIA, DOE conducted interviews with a representative crosssection of manufacturers. During these interviews, DOE discussed engineering, 
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manufacturing, procurement, and financial topics to validate assumptions used in the 

GRIM and to identify key issues or concerns. See section IV.I.4 for a description of the 

key issues manufacturers raised during the interviews.

Phase 3 also includes an evaluation of sub-groups of manufacturers that may be 

disproportionately impacted by standards or that may not be accurately represented by the 

average cost assumptions used to develop the industry cash-flow analysis. For example, 

small manufacturers, niche players, or manufacturers exhibiting a cost structure that 

largely differs from the industry average could be more negatively affected. Thus, during 

Phase 3, DOE analyzed small manufacturers as a subgroup. 

The Small Business Administration (SBA) defines a small business for North 

American Industry Classification System (NAICS) 333415 “Air-Conditioning and Warm 

Air Heating Equipment and Commercial and Industrial Refrigeration Equipment 

Manufacturing” as having 750 employees or fewer. During its research, DOE identified 

multiple companies that manufacture products covered by this rulemaking and qualify as 

a small business under the SBA definition. The small businesses were further sub-divided 

into small manufacturers of panels, doors, and refrigeration equipment, and doors to 

better understand the impacts of the rulemaking on those entities. The small business 

subgroup is discussed in Chapter 12 of the NOPR TSD and in sections V.B.2.d and VI.B

of today’s notice and in Chapter 12 of the NOPR TSD. 

 
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2. Government Regulatory Impact Model Analysis

As discussed previously, DOE uses the GRIM to quantify the changes in cash 

flow that result in a higher or lower industry value from new standards. The GRIM 

analysis uses a discounted cash-flow methodology that incorporates manufacturer costs, 

markups, shipments, and industry financial information as inputs. The GRIM models 

changes in costs, distribution of shipments, investments, and manufacturer margins that 

could result from new energy conservation standards. The GRIM spreadsheet uses the 

inputs to arrive at a series of annual cash flows, beginning in 2011,2013 (the base year of 

the analysis,)) and continuing to 2046. DOE calculated INPVs by summing the stream of 

annual discounted cash flows during these periods. DOE applied discount rates derived 

from industry financials and then modified them according to feedback during 

manufacturer interviews. Discount rates ranging from 9.4– to 10.5 percent were used 

depending on the component being manufactured. 

The GRIM calculates cash flows using standard accounting principles and 

compares changes in INPV between the base case and each TSL (the standards case). 

Essentially, the difference in INPV between the base case and a standards case represents 

the financial impact of the new standard on manufacturers. Additional details about the 

GRIM, the discount rate, and other financial parameters can be found in chapter 12 of the

TSD.

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DOE typically presents its estimates of industry impacts by grouping the major 

productequipment classes served by the same manufacturers. For the WICF industry, 

DOE groups results by panels, doors, and refrigeration systems. 

a. Government Regulatory Impact Model Key Inputs

i. Manufacturer Production Costs

Manufacturing a higher-efficiency product is typically more expensive than 

manufacturing a baseline product due to the use of more expensive components and 

larger quantities of raw materials. The changes in the manufacturer production cost 

(MPC) of the analyzed products can affect revenues, gross margins, and cash flow of the 

industry, making these product cost data key GRIM inputs for DOE’s analysis. 

In the MIA, DOE used the MPCs for each considered efficiency level calculated 

in the engineering analysis, as described in section IV.C and further detailed in chapter 5 

of the TSD. In addition, DOE used information from its teardown analysis, described in 

section IV.C.3.a, to disaggregate the MPCs into material, labor, and overhead costs. To 

calculate the MPCs for products above the baseline, DOE added the incremental material, 

labor, and overhead costs from the engineering cost-efficiency curves to the baseline 

MPCs. These cost breakdowns and product mark-ups were validated with manufacturers 

during manufacturer interviews.

 

ii. Shipments Forecast

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The GRIM estimates manufacturer revenues based on total unit shipment 

forecasts and the distribution of shipments by productequipment class. For the base-case 

analysis, the GRIM uses the NIA base-case shipment forecasts from 20102013, the base 

year for the MIA analysis, to 20452046, the last year of the analysis period. 

For the standards case shipment forecast, the GRIM uses the NIA standards case 

shipment forecasts. The NIA assumes zero elasticity in demand as explained in section 

IV.G.1.9.3.1 in chapter 9 of the TSD. Therefore, the total number of shipments per year 

in the standards case is equal to the total shipments per year in the base case. DOE 

assumes a new efficiency distribution in the standards case, however, based on the energy 

conservation standard. DOE assumed that product efficiencies in the base case that did 

not meet the standard under consideration would “roll up” to meet the new standard in 

the standard year. See section IV.G.1 above for additional details.

iii. Product and Capital Conversion Costs

New energy conservation standards will cause manufacturers to incur conversion 

costs to bring product designs into compliance. DOE evaluated the level of conversionrelated capital expenditures needed to comply with each efficiency level in each 

productequipment class. For the purpose of the MIA, DOE classified these conversion 

costs into two major groups: (1) product conversion costs and (2) capital conversion 

costs. Product conversion costs are investments in research, development, testing, and 

marketing focused on making product designs comply with the new energy conservation 

standards. Capital conversion costs are investments in property, plant, and equipment to 

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adapt or change existing production facilities so that new equipment designs can be 

fabricated and assembled.

To evaluate the level of capital conversion expenditures manufacturers would 

likely incur to comply with energy conservation standards, DOE used the manufacturer 

interviews to gather data on the level of capital investment required at each efficiency 

level. DOE validated manufacturer comments through estimates of capital expenditure 

requirements derived from the product teardown analysis and engineering model 

described in sections IV.C.2 and IV.C.3. 

DOE assessed the product conversion costs at each level by integrating data from 

quantitative and qualitative sources. DOE considered feedback from multiple 

manufacturers at each efficiency level to determine conversion costs such as R&D 

expenditures and certification costs. Manufacturer numbers were aggregated to better 

reflect the industry as a whole and to protect confidential information. 

In general, DOE assumes that all conversion-related investments occur between 

the year of publication of the final rule and the year by which manufacturers must comply 

with the standard. The investment figures used in the GRIM can be found in section 

V.B.2.a of today’s notice. For additional information on the estimated product conversion 

and capital conversion costs, see chapter 12 of the TSD.
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b. Government Regulatory Impact Model Scenarios

i. Markup Scenarios

As discussed above, MSPs include direct manufacturing production costs (i.e.,

labor, material, and overhead estimated in DOE’s MPCs) and all non-production costs 

(i.e., SG&A, R&D, and interest), along with profit. To calculate the MSPs in the GRIM, 

DOE applied non-production cost markups to the MPCs estimated in the engineering 

analysis for each productequipment class and efficiency level. Modifying these markups 

in the standards case yields different sets of impacts on manufacturers. For the MIA, 

DOE modeled two standards case markup scenarios to represent the uncertainty 

regarding the potential impacts on prices and profitability for manufacturers following 

the implementation of new energy conservation standards: (1) a preservation of gross 

margin percentage and (2) a preservation of operating profit. These scenarios lead to 

different markups values which, when applied to the input MPCs, result in varying 

revenue and cash flow impacts. 

Under the “preservation of gross margin percentage” scenario, DOE applied a 

single uniform gross margin percentage markup across all efficiency levels. As 

production costs increase with efficiency, this scenario implies that the absolute dollar 

markup will increase as well. DOE assumed the non-production cost markup—which 

includes SG&A expenses, research and development expenses, interest, and profit—to be 

1.32 for panels, 1.50 for solid doors, 1.62 for display doors, and 1.35 for refrigeration. 

These markups are consistent with the ones DOE assumed in the engineering analysis. 

Manufacturers have indicated that it is optimistic to assume that, as manufacturer 

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production costs increase in response to an energy conservation standard, manufacturers 

would be able to maintain the same gross margin percentage markup. Therefore, DOE 

assumes that this scenario represents a high bound to industry profitability under an 

energy conservation standard.

 In the preservation of operating profit scenario, manufacturer markups are set so 

that operating profit one year after the compliance date of the new energy conservation 

standards is the same as in the base case. Under this scenario, as the cost of production 

and the cost of sales rise, manufacturers are generally required to reduce their markups to 

a level that maintains base case operating profit. The implicit assumption behind this 

markup scenario is that the industry can maintain only its operating profit in absolute 

dollars after the standard. Operating margin in percentage terms is squeezed (reduced)

between the base case and standards case.

3. Discussion of Comments

Interested parties commented on the assumptions and results of the preliminary 

analysis, particularly on the cumulative regulatory burden, inventory levels, and scope of 

the manufacturer impact analysis.

a. Cumulative Regulatory Burden

AHRI stated that DOE must take into account the impact of new regulations that 

California is working on as part of Title 20 that will establish new prescriptive design 

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requirements for walk-in coolers and freezers in 2011. (AHRI, Public Meeting Transcript, 

No. 0045 at p. 5)

DOE reviewed California Code of Regulations Title 20, Section 1605, which 

establishes walk-in requirements for insulation levels, motor types, and use of automatic 

door-closers. The latest set of regulations, published in the 2010 Appliance Efficiency 

Regulations and effective 2011, includes design standards required for all walk-ins 

manufactured on or after January 1, 2009. However, these standards are identical to the 

ones that have already been established in EPCA and are therefore unlikely to contribute 

to additional regulatory burden.These state regulations are identical to Federal regulations 

that are set forth in EPCA (see 42 U.S.C. 6313(f)), and that are already in place. As a 

practical matter, the Federal regulations mirror those that the State of California had 

previously prescribed. As a result there was no incremental cost differential between the

Federal standards promulgated in 2007 and California standards. The energy 

conservation standards that DOE is considering in this standards rulemaking are more 

stringent than the already-prescribed levels. 

AHRI also expressed concern over California regulations to limit greenhouse gas 

emissions, in particular the California Air Resources Board (CARB) provisions to reduce 

the use of high global warming potential refrigerants, such as hydrofluorocarbons 

(HFCs). (AHRI, Public Meeting Transcript, No. 0045 at p. 5)
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CARB is currently limiting the in-state use of high-GWP refrigerants in nonresidential refrigeration systems through its Refrigerant Management Program, effective 

January 1, 2011. According to this new regulation, facilities with refrigeration systems 

that have a refrigerant capacity exceeding 50 pounds must repair leaks within 14 days of 

detection, maintain on-site records of all leak repairs, and keep receipts of all refrigerant 

purchases. The regulation applies to any person or company that installs, services, or 

disposes of appliances with high-GWP refrigerants. According to EPCA, walk-in coolers 

and freezers are enclosed storage spaces that can be walked into and have a total chilled 

storage area of less than 3,000 square feet. (42 U.S.C. 6311(20) (defining the term “walkin cooler; walk-in freezer”)) Due to this size limit, it is unlikely that a walk-in 

refrigeration system will contain over 50 pounds of refrigerant and therefore, making 

application of the CARB provisions are unlikely to apply.

27 

b. Inventory Levels

In the preliminary analysis, DOE determined from U.S. Census data that the endof-year inventory for the air-conditioning and warm air heating equipment and 

commercial and industrial refrigeration equipment manufacturing industry (NAICS code 

333415) was approximately 10 percent of shipment value from 2002 to 2007 (U.S. 

Census Bureau Annual Survey of Manufacturers) and presented these data in Table 

12.3.3 of chapter 12 in the preliminary TSD. American Panel expressed concerns that the 

inventory percentages shown in Table 12.3.3 of chapter 12 in the Preliminary TSD are 

 

27 DOE estimates that walk-ins meeting the statutory definition would likely use between 5 and 40 pounds 

of refrigerant, below the threshold established under the California regulations.

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inaccurate and noted that their end-of-year inventory value has been only 2.5 percent of 

annual shipment value on average. (American Panel, No. 0048.1 at p. 11) The U.S. 

Census percentages represent values for the air-conditioning and warm-air heating 

equipment and commercial and industrial refrigeration equipment manufacturing 

industry, which includes a wide range of products and companies. DOE agrees that the 

U.S. Census figures may not necessarily be representative of inventory levels for specific 

walk-in cooler and freezer manufacturers. The figure is used to characterize the industry 

and is not a component of any quantitative analysis. DOE has factored American Panel’s 

inventory number into its qualitative understanding of the walk-insin industry. 

c. Manufacturer Subgroup Analysis

AHRI suggested that DOE should enlarge the scope of the manufacturer impact 

analysis to examine the impact of the rulemaking on all manufacturers of different 

productequipment classes—including panel, door, and refrigeration system

manufacturers. (AHRI, Public Meeting Transcript, No. 0045 at p. 4) 

To better reflect the structure of the rulemaking, DOE has expanded its analysis of 

manufacturers to include the impact of the rulemaking on key component suppliers,—,

including panel manufacturers, door manufacturers, and refrigeration system 

manufacturers. Additionally, small manufacturers of panels, doors, and refrigeration 

systems are considered as separate sub-groups in the MIA. 

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4. Manufacturer Interviews

As part of the MIA, DOE discussed potential impacts of standards with eight 

panel manufacturers, six door manufacturers, and three refrigeration systems 

manufacturers. In the interviews, DOE asked manufacturers to describe their major 

concerns about this rulemaking. The following sections discuss manufacturers’ most 

significant concerns. 

a. Cost of testing

All door, panel, and refrigeration manufacturers expressed concern regarding the 

cost of testing. The majority of walk-ins sold are not standard combinations of box sizes, 

refrigeration components, and doors. Almost every walk-in unit is tailored to meet 

consumer specifications. According to manufacturers, DOE-mandated testing of every 

configuration sold is not realistic and could become a financial burden that would 

negatively impact manufacturers’ profitability. Beyond DOE compliance testing, energy 

conservation standards may lead to product redesigns that require new certifications, such 

as Underwriters Laboratories (UL) fire safety, NSF 2 food service, and NSF 7 

commercial refrigerator and freezer standards compliance. 

The cost of compliance testing includes the engineering support necessary to 

design and run tests, the cost of the units tested, and the cost of third-party testing 

support. Some manufacturers indicated that it may be necessary to set up new test labs to 

deal with compliance requirements. Beyond DOE compliance testing, energy 

conservation standards may lead to product redesigns that require new certifications, such 

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Comment [A25]: Edit made per OIRA.
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as Underwriters Laboratories (UL) fire safety, NSF 2 food service, and NSF 7 

commercial refrigerator and freezer standards compliance. 

Multiple door, panel, and refrigeration manufacturers expressed concern that 

these compliance and certification testing costs may lead to less customization in the 

industry. As an example, one door manufacturer was concerned that walk-in 

manufacturers would offer fewer door choices and partner with fewer door companies to 

reduce testing burden. As another example, a manufacturer that produces only unit 

coolers indicated that the need to certify the complete refrigeration system would force 

them to leave the WICF market. As the unit cooler supplier, the manufacturer does not 

have the ability to certify the entire system because they do not supply the condensing 

unit portion of the system. Today, the manufacturer’s consumers pair the unit coolers 

with condensing units from other suppliers to assemble a walk-in refrigeration system. 

The manufacturer speculated that, in a regulated environment, their consumers would 

switch from buying refrigeration components from manufacturers of unit coolers to 

buying complete systems with matched unit coolers and condensing units from larger 

competitors that build complete systems rather than components. Their customers would 

make this change to avoid the test burden on refrigeration systems. Other manufacturers 

mentioned that the cost of testing could ultimately lead to conditions in which small panel 

manufacturers would be forced out of the market. 

 

Finally, walk-in manufacturers were concerned about pricing and availability of 

third-party testing. Several walk-in manufacturers noted that it is unclear whether a 
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sufficient number of qualified third parties exist to carry out the performance testing 

mandated by DOE for the entire industry. One manufacturer was concerned that an 

insufficient number of test facilities would leadinglead to higher testing costs and delays 

in achieving compliance.

b. Enforcement and Compliance 

All of the interviewed manufacturers expressed concern that an energy 

conservation standard rulemaking could result in unfair competition if the standard is not 

properly enforced. Interviewed manufacturers claimed that numerous manufacturers, 

particularly small one-to-two person operations, are not currently complying with the 

existing walk-in regulations in EPCA, which took effect January 1, 2009. The 

manufacturers explained that smaller operations often have an incentive to be noncompliant. By using materials that do not comply with existing regulations, the noncompliant manufacturers maintain a price advantage over compliant industry 

players.manufacturers. 

Manufacturers emphasized the need to have well-defined compliance 

responsibilities. WICF units can be manufactured and delivered as per standard by the 

manufacturer, but the end user may decide to remove some of the efficiency features, 

such as strip curtains. Additionally, the quality of installation at the client site is often a 

factor that manufacturers cannot control because field assembly is managed by 

contractors. Manufacturers also noted that, for some installations, the contractors 

purchase the walk-in envelope and refrigeration equipment from separate suppliers, 

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making it impossible for the equipment manufacturers to determine the efficiency of the 

installed product. Multiple manufacturers requested clarification to better understand 

which party bears responsibility for ensuring field-assembled walk-ins meet federal 

standards. 

In this NOPR, DOE discusses issues surrounding compliance and enforcement. In 

particular, DOE proposes that each component manufacturer would be responsible for 

certifying to DOE that the components they manufacture comply with the standards. 

DOE believes that the component-based approach provides for effective certification and 

enforcement of any standards while ensuring that the walk-in industry has sufficient 

flexibility to meet the applicable standards. For more details on DOE’s proposed 

approach, see section III.D. 

c. Profitability Impacts 

Walk-in manufacturers discussed how new energy conservation standards could 

affect profit levels. Manufacturers considered the walk-in industry to be a low marginbusiness. Price competition can be very aggressive, particularly for large orders and for 

name-brand client accounts. Manufacturers stated that low margins leave little room for 

the added costs that energy conservation standards could impose. Manufacturers noted 

that they will have to absorb the additional costs or pass the costs onto the consumer. 

Specifically, manufacturers emphasized their concerns about the impact of thicker 

panels, thicker doors, and more efficient refrigeration on profitability. Thicker panels 

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require more material and longer processing times. The end result could be a reduction in 

factory throughput coupled with increased cost. Additionally, manufacturers noted that 

thicker panels are heavier, which leads to higher shipping costs. Similar concerns exist 

for solid doors. To achieve higher refrigeration efficiencies, manufacturers would have to 

purchase larger coils, more efficient compressors, and more expensive control systems. 

All these components increase the cost of goods sold for the completed walk-in.

Manufacturers speculated that passing all these costs onto their customers would 

lead to lower-volume orders, as consumers with set budgets would not be able to 

purchase as many walk-ins (in the case of chain stores) or as much walk-in space (in the 

case of individual operations) for the same dollar amount. Alternatively, absorbing these 

costs would significantly reduce profit margins.

In the manufacturer impact analysis, DOE has examined the impacts of standards 

on manufacturers’ profit margins. For the results of DOE’s analysis, see section V.B.2.a. 

d. Excessive Conversion Cost 

According to panel manufacturers, a new energy conservation standard that 

requires increased levels of thickness could result in high conversion costs. Much of the 

existing production equipment is designed to produce panels 3.5–5 inches thick. Panels 

that are 6 or more inches thick are less common in the industry. Any standard that results 

in the market moving to 5-inch thick panels would require some conversion cost as 

factories that use foam-in-place technology must accommodate increased curing times. 

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Manufacturers indicated that the conversion costs could range from $100,000 to 

$500,000, depending on the manufacturer’s existing equipment. Any standard that 

requires 6-inch thick panels would involve significant additional investment by most 

manufacturers. At this level of thickness, manufacturers estimate conversion costs would 

range from $200,000 to $1 million. Any standard that requires 7-inch thick panels would 

require all manufacturers to reevaluate- their manufacturing process. Conversion costs 

would range from $1.5 million to $4 million. Based on manufacturer statements, any 

standard that moved the industry to 6-inch thick panels would likely put some of the top 

10 panel manufacturers out of business.

DOE considers conversion costs in the manufacturer impact analysis. For details 

on DOE’s findings, see section V.B.2.a. 

e. Disproportionate Impact on Small Businesses

Most interviewed manufacturers noted that new energy conservation standards 

could have a disproportionate impact on small businesses as compared to larger 

businesses. The cost of testing, the potential increase in materials, and the potential need 

to obtain financing are the factors that could affect small business manufacturers 

producing refrigeration systems, panels, and doors more severely.

Manufacturers voiced concerns regarding the cost of both compliance testing and 

certification testing (e.g., UL and NSF certifications) on small businesses. According to 

manufacturers, the price tag for testing is likely to be similar for both small and large 

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companies due to the high level of product customization in the industry. For small 

businesses, the cost will spread across smaller sales volumes, making recuperation of the 

testing investment more difficult. Some manufacturers thought that compliance testing 

costs alone could force small manufacturers to exit the industry.

Additionally, small manufacturers indicated that they face a significant price 

disadvantage for foaming agents (used for insulation) and components due to their small 

purchasing quantities when compared to large manufacturers. Any standard that requires 

small manufacturers to use more foam or more expensive components will exacerbate the 

pricing gap. Given the price-sensitive nature and low margin of the industry, the small 

envelope manufacturers were concerned that requiring thicker panels provided a 

competitive advantage to large manufacturers that could obtain foaming agents at a lower 

price based on order quantities that are of larger magnitude. 

Several interviewed manufacturers are concernedexpressed concern that the 

current tightness in financial markets and reduced economic activity could negatively 

impact their ability to obtain the financing necessary to cover compliance costs. This is,

particularly true for small business operations, which generally have greater difficulty 

obtaining financing.

DOE has examined the impact on small manufacturers in its manufacturer subgroup analysis and regulatory flexibility analysis. For the results of these analyses, see 

sections V.B.2.d and VI.B. 
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f. Refrigerant Phase-Out 

Interviewed manufacturers are concerned aboutnoted the impacts of mandated 

changes in blowing agents and refrigerants. Currently, walk-in manufacturers use HFC404 and HFC-134a refrigerants. While HFC-404 is used exclusively as a refrigerant, 

HFC-134a is used as both a refrigerant and a blowing agent in the walk-in manufacturing 

industry. 

 

Several manufacturers expressed concern about the impact of a potential phasedown or phase-out of HFCs. The concern is acute because manufacturers stated that there 

is no clear alternative or substitute to HFCs for the industry. Without a clear replacement,

manufacturers are concerned that any phase-out would create a period of uncertainty as 

the industry identifies suitable alternatives and then redesigns both products and 

processes around the replacement. In generalIn the manufacturers’ experience, past 

phase-outs have led to more expensive and less efficient refrigerant replacements. 

For panelPanel manufacturers, expressed concern that conversion to a new 

blowing agent would be costly as they would have to go through a transition period in 

which foam would need to be reformulated. Production processes and facilities would 

need to adapt to the new foam blend. In the pastManufactures stated that previous , 

replacement blowing agents have been more expensive and have presented challenges to 

the production process because of different flow characteristics from the agents they 

replace. Finally, previousThey also noted that blowing agent substitutes have led to foam 

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blends with lower R-value, providing less insulation. LowerPanel manufacturers were 

concerned that lower insulation effectiveness results in thicker panels needed to meet a 

standard, which leads to increased production cost and therefore lower profit margins.

For refrigeration Refrigeration system manufacturers, expressed that an HFC 

phase-out would be costly as it would require redesign of all products. Some 

manufacturers stated that an HFC phase-out would force them to use flammable 

refrigerants. Manufacturers noted that some alternative refrigerants may require 

substantially larger systems to achieve the same levels of performance. 

As discussed in section IV.A.2.b, DOE has only considered HFC refrigerants in 

the analysis. DOE is unable to speculate on future legislation that may limit the use of 

these refrigerants.DOE did not consider whether foam blowing agents would cost more, 

less or stay the same and DOE understands there is a range of non-HFC foam blowing 

used already in these applications. 

D.J. Employment Impact Analysis

Employment impacts are one factor DOE considers in selecting an efficiency 

standard. Employment impacts include direct and indirect impacts. Direct employment 

impacts are any changes that affect employment of WICF manufacturers, their suppliers, 

and related service firms.. Indirect impacts are those employment changes in the larger 

economy that occur because of the shift in expenditures and capital investment caused by 

the purchase and operation of more efficient walk-ins. The MIA results in section 

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V.B.2.b of this notice and chapter 12 of the TSD address only the direct employment 

impacts on walk-in manufacturers. Chapter 13 of the TSD provides further information 

about other, primarily indirect, employment impacts discussed in this section. 

Indirect employment impacts from WICF standards consist of the net jobs created 

or eliminated in the national economy, excluding the manufacturing sector being 

regulated, as a consequence of (1) reduced spending by end-users on electricity, which 

could potentially be offset by the increased spending on maintenance and repair of higher 

efficiency equipment); (2) reduced spending on new energy supply by the utility industry; 

(3) increased spending on the purchase price of new walk-in coolers and freezers; and (4) 

the effects of those three factors throughout the economy. DOE expects the net monetary 

savings from standards to stimulate other forms of economic activity. DOE also expects 

these shifts in spending and economic activity to affect the demand for labor.

 

In developing this analysis in the NOPR, DOE estimated indirect national 

employment impacts using an input/output model of the U.S. economy, called ImSET 

(Impact of Sector Energy Technologies) developed by DOE’s Building Technologies 

Program. ImSET is a personal-computer based, economic analysis model that 

characterizes the interconnections among 188 sectors of the economy as national 

input/output structural matrices using data from the U.S. Department of Commerce’s 

1997 Benchmark U.S. input-output table. The ImSET model estimates changes in 

employment, industry output, and wage income in the overall U.S. economy resulting 

from changes in expenditures in various sectors of the economy. DOE estimated changes 
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in expenditures using the NIA model. ImSET then estimated the net national indirect 

employment impacts efficiency standards would have on employment by sector. 

 

The ImSET input/output model suggests that the proposed standards could 

increase the net demand for labor in the economy, and the gains would most likely be 

very small relative to total national employment. For more details on the employment 

impact analysis and its results, see chapter 13 of the TSD and section V.B.3.cIV.J of this 

notice.

E.K. Utility Impact Analysis

The utility impact analysis estimates theseveral important effects on the utility 

industry of adoptingthe adoption of new or amended standards on the utility industry. For 

this analysis, DOE used the NEMS-BT model to generate forecasts of electricity 

consumption, electricity generation by plant type, and electric generating capacity by 

plant type, that would result from each considered TSL. DOE conductedobtained the 

energy savings inputs associated with efficiency improvements to considered products 

from the NIA. DOE conducts the utility impact analysis as a scenario that 

departeddeparts from the latest AEO referenceReference case. In other wordsthe analysis 

for today’s rule, the estimated impactimpacts of a standard isstandards are the 

differencedifferences between the values forecasted by NEMS-BT and the values in the 

AEO2010 referenceAEO2013 Reference case. For more details on the utility impact 

analysis, see chapter 14 of the TSD.

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Chapter 14 of the TSD accompanying this notice presents results of the utility 

impact analysis.

F. Environmental Assessment

Pursuant to the National Environmental Policy Act of 1969 and the requirements 

of 42 U.S.C. 6295(o)(2)(B)(i)(VI), DOE has prepared a draft environmental assessment 

(EA) of the impacts of today’s proposed standards for walk-in coolers and freezers, 

which it has included as chapter 15 of the NOPR TSD.

In the EA, DOE estimated the reduction in power sector emissions of CO2, NOx, 

and Hg using the NEMS-BT computer model. In the EA, NEMS-BT is run similarly to 

the AEO NEMS, except that WICF energy use is reduced by the amount of energy saved 

(by fuel type) due to each TSL. The inputs of national energy savings come from the NIA 

spreadsheet model, while the output is the forecasted physical emissions from power 

plants. The net environmental benefit of each TSL in today’s NOPR is the difference 

between the forecasted emissions estimated by NEMS-BT at each TSL and the AEO 

2010 Reference Case. NEMS-BT tracks CO2 emissions using a detailed module that 

provides results from all sectors and includes interactive effects. For today’s NOPR, DOE 

used the AEO2010. For the final rule, DOE intends to revise the emissions analysis using 

the most current version of NEMS inputs.
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L. Sulfur dioxide (SO2)Emissions Analysis

In the emissions analysis, DOE estimates the reduction in power sector emissions 

of carbon dioxide (CO2), nitrogen oxides (NOx), sulfur dioxide (SO2), and mercury (Hg) 

from potential energy conservation standards for walk-in coolers and freezers . In 

addition, DOE estimates emissions impacts in production activities (extracting, 

processing, and transporting fuels) that provide the energy inputs to power plants. These 

are referred to as “upstream” emissions. Together, these emissions account for the fullfuel-cycle (FFC). In accordance with DOE’s FFC Statement of Policy (76 FR 51282 

(Aug. 18, 2011)), the FFC analysis includes impacts on emissions of methane (CH4) and 

nitrous oxide (N2O), both of which are recognized as greenhouse gases.

DOE conducted the emissions analysis using emissions factors that were derived 

from data in EIA’s Annual Energy Outlook 2013 (AEO 2013), supplemented by data 

from other sources. DOE developed separate emissions factors for power sector 

emissions and upstream emissions. The method that DOE used to derive emissions 

factors is described in chapter 15 of the NOPR TSD.

EIA prepares the Annual Energy Outlook using the National Energy Modeling 

System (NEMS). Each annual version of NEMS incorporates the projected impacts of 

existing air quality regulations on emissions. AEO 2013 generally represents current 

legislation and environmental regulations, including recent government actions, for 

which implementing regulations were available as of December 31, 2011.
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SO2 emissions from affected electric generating units (EGUs) are subject to 

nationwide and regional emissions cap-and-trade programs, and DOE has preliminarily 

determined that these programs create uncertainty about the potential new 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 statesStates and the District of Columbia 

(D.C.). SO2 emissions from 28 eastern states and D.C. were also limited under the Clean 

Air Interstate Rule (CAIR; 70 FR 25162 (May 12, 2005)), which created an allowancebased trading program. Although that operates along with the Title IV program. CAIR 

was remanded to the U.S. Environmental Protection Agency (EPA) by the U.S. Court of 

Appeals for the District of Columbia Circuit (D.C. Circuit), (seebut it remained in effect. 

See North Carolina v. EPA, 550 F.3d 1176 ([(D.C. Cir. 2008),]) it remained in effect 

temporarily as is consistent with the D.C. Circuit’s earlier opinion in); North Carolina v. 

EPA, 531 F.3d 896 (D.C. Cir. 2008). On July 6, 2010, EPAOn August 21, 2012, the D.C. 

Circuit issued the Transport Rule proposal, a replacement for CAIR, and on July 6, 

2011,a decision to vacate CSAPR. See EME Homer City Generation, LP v. EPA, 696 

F.3d 7, 38 (D.C. Cir. 2012). The court ordered EPA issued the final Transport Rule, 

entitled “Federal Implementation Plans: Interstate Transport of Fine Particulate Matter 

and Ozone and Correction of SIP Approvals,” but commonly referred to as the CrossState Air Pollution Rule or the Transport Rule. (http://www.epa.gov/crossstaterule/). 75 

FR 45210 (Aug. 2, 2010); 76 FR 48208 (Aug. 8, 2011). Because the final Transport Rule 

was published during the preparation of theto continue administering CAIR. The AEO 

2013 emissions factors used for today’s NOPR and the AEO 2010 NEMS assumes the 

implementation ofassume that CAIR, DOE has not been able to take into account the 

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effects of the Transport Rule for this rulemaking. 28 remains a binding regulation through 

2040.

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 impositionadoption of an efficiency standard could be 

used to permit offsetting increases in SO2 emissions by any regulated EGU. However, if 

the new standards resulted in a permanent increase in the quantity of unused emissions 

allowances, In past rulemakings, DOE recognized that there would be an overall 

reduction in SO2 emissions from the standards. While there remains somewas uncertainty 

about the ultimate effects of efficiency standards on SO2 emissions the NEMS-BT 

modelingcovered by the existing cap-and-trade system that DOE uses to forecast 

emissions reductions currently indicates, but it concluded that no physicalnegligible

reductions in power sector SO2 emissions would occur for SO2.as a result of standards. 

ABeginning in 2015, however, SO2 emissions will fall as a result of the 

Mercury and Air Toxics Standards (MATS) for power plants, which were announced by 

EPA on December 21, 2011. 77 FR 9304 (Feb. 16, 2012).29

 

28 DOE notes that future iterations of the NEMS-BT model will incorporate any changes necessitated by 

issuance of the Transport Rule.

In the final MATS rule, EPA 

established a standard for hydrogen chloride as a surrogate for acid gas hazardous air 

29 On July 20, 2012, EPA announced a partial stay, for a limited duration, of the effectiveness of national 

new source emission standards for hazardous air pollutants from coal- and oil-fired electric utility steam 

generating units. http://www.epa.gov/airquality/powerplanttoxics/pdfs/20120727staynotice.pdf

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pollutants (HAP), and also established a standard for SO2 (a non-HAP acid gas) as an 

alternative equivalent surrogate standard for acid gas HAP. The same controls are used 

to reduce HAP and non-HAP acid gas; thus, SO2 emissions will be reduced as a result of 

the control technologies installed on coal-fired power plants to comply with the MATS 

requirements for acid gas. AEO 2013 assumes that, in order to continue operating, coal 

plants must have either flue gas desulfurization or dry sorbent injection systems installed 

by 2015. Both technologies, which are used to reduce acid gas emissions, also reduce 

SO2 emissions. Under the MATS, NEMS shows a reduction in SO2 emissions when 

electricity demand decreases (e.g., as a result of energy efficiency standards). Emissions 

will be far below the cap that would be established by CSAPR, so it is unlikely that 

excess SO2 emissions allowances resulting from the lower electricity demand would be 

needed or used to permit offsetting increases in SO2 emissions by any regulated EGU. 

Therefore, DOE believes that efficiency standards will reduce SO2 emissions in 2015 and 

beyond.

CSAPR established a cap on NOx emissions affecting electric generating units in the 

CAIR region means that the energy in 28 eastern States and the District of Columbia. 

Energy conservation standards for WICF equipment mayare expected to have little or no 

physical effect on NOx emissions in the 28 eastern states and District of Columbiathose 

States covered by CAIR or any States covered by the Transport Rule. The proposed 

standards would, however, reduce CSAPR because excess NOx emissions in those 22 

statesallowances resulting from the lower electricity demand could be used to permit 

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offsetting increases in NOx emissions. However, standards would be expected to reduce 

NOx emissions in the States not affected by the CAIR.30

Similar to emissions of SO2 and NOx, future 

emissions of Hg would have been subject to emissions caps. In May 2005, EPA issued 

the Clean Air Mercury Rule (CAMR). 70 FR 28606 (May 18, 2005). CAMR would have 

permanently capped emissions of mercury for new and existing coal-fired power plants in 

all states by 2010. However, on February 8, 2008, the D.C. Circuit issued a decision in 

New Jersey v. Environmental Protection Agency, 517 F.3d 574 (D.C. Cir. 2008), in 

which it vacated CAMR. EPA has decided to develop emissions standards for power 

plants under Section 112 of the Clean Air Act, consistent with the DC Circuit’s opinion 

on CAMR. See www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending 

EPA’s forthcoming revisions to the rule, DOE is excluding CAMR from its 

environmental assessment. In the absence of CAMR, the proposed DOE standard for 

WICF refrigeration system and envelope components would likely reduce Hg emissions 

and DOE used NEMS-BT to estimate these reductions. However, DOE continues to 

review the impact of rules that reduce energy consumption on Hg emissions, and may 

revise its assessment of Hg emission reductions in future rulemakings. , so DOE 

estimated NOx emissions reductions from the standards considered in today’s NOPR for 

these States.

 

 

30 DOE notes that future iterations of the NEMS-BT model will incorporate any changes necessitated by 

issuance of the Transport Rule.

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The MATS limit mercury emissions from power plants, but they do not include 

emissions caps and, as such, DOE’s energy conservation standards would likely reduce 

Hg emissions. DOE estimated mercury emissions reduction using emissions factors based 

on AEO 2013, which incorporates the MATS. 

G.M. Monetizing Carbon Dioxide and Other Emissions Impacts

As part of the development of the standard in this NOPRamended rule, DOE 

considered the estimated monetary benefits likely to result from the reduced emissions of 

CO2 and NOx that are expected to result from each of the TSLs considered. In order to 

make this calculation similar to the calculation of the NPV of consumer benefit, DOE 

considered the reduced emissions expected to result over the lifetime of products shipped 

in the forecast period for each TSL. This section summarizes the basis for the monetary 

values used for each of these emissions and presents the values considered in this 

NOPRrulemaking. 

For today’s NOPR, DOE is relying on a set of values for the social cost of carbon 

(SCC) that was developed by an interagency process. A summary of the basis for these 

values is provided below, and a more detailed description of the methodologies used is 

provided as an appendix to chapter 16 of the TSD.

1. Social Cost of Carbon

 The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

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to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of carbon dioxide. A domestic SCC value is meant to 

reflect the value of damages in the United States resulting from a unit change in carbon

dioxide emissions, while a global SCC value is meant to reflect the value of damages 

worldwide.

Under section 1(b) of Executive Order 12866, agencies must, to the extent 

permitted by law, “assess both the costs and the benefits of the intended regulation and, 

recognizing that some costs and benefits are difficult to quantify, propose or adopt a 

regulation only upon a reasoned determination that the benefits of the intended regulation 

justify its costs.” The purpose of the SCC estimates presented here is to allow agencies to 

incorporate the monetized social benefits of reducing CO2 emissions into the cost-benefit 

analyses of regulatory actions that have small, or “marginal,” impacts on cumulative 

global emissions. The estimates are presented with an acknowledgement of the many 

uncertainties involved and with a clear understanding that they should be updated over 

time to reflect increasing knowledge of the science and economics of climate impacts.

As part of the interagency process that developed these SCC estimates, technical 

experts from numerous agencies met on a regular basis to consider public comments, 

explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values 

using a defensible set of input assumptions grounded in the existing scientific and 

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economic literatures. In this way, key uncertainties and model differences transparently 

and consistently inform the range of SCC estimates used in the rulemaking process.

a. Monetizing Carbon Dioxide Emissions

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of CO2. 

When attempting to assess the incremental economic impacts of CO2carbon

dioxide emissions, the analyst faces a number of serious challenges. A recent report from 

the National Research Council31 points out that any assessment will suffer from 

uncertainty, speculation, and lack of information about (1) future emissions of 

greenhouse gases, (2) the effects of past and future emissions on the climate system, (3) 

the impact of changes in climate on the physical and biological environment, and (4) the 

translation of these environmental impacts into economic damages. As a result, any effort 

to quantify and monetize the harms associated with climate change will raise serious 

questions of science, economics, and ethics and should be viewed as provisional. 

 

31 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and 

Use. 2009. National Academies Press: Washington, DC. (2009).

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Despite the serious limits of both quantification and monetization, SCC estimates 

can be useful in estimating the social benefits of reducing carbon dioxide emissions. 

Consistent with the directive in Executive Order 12866 quoted above, the purpose of the 

SCC estimates presented here is to make it possible for Federal agencies to incorporate 

the social benefits from reducing carbon dioxide emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” impacts on cumulative global 

emissions. Most Federal regulatory actions can be expected to have marginal impacts on 

global emissions.

For such policies, the agency can estimate the benefits from reduced (or costs 

from increased) emissions in any future year by multiplying the change in emissions in 

that year by the SCC value appropriate for that year. The net present value of the benefits 

can then be calculated by multiplying each of these future benefits by an appropriate 

discount factor and summing across all affected years. This approach assumes that the 

marginal damages from increased emissions are constant for small departures from the 

baseline emissions path, an approximation that is reasonable for policies that have effects 

on emissions that are small relative to cumulative global carbon dioxide emissions. For 

policies that have a large (non-marginal) impact on global cumulative emissions, there is 

a separate question of whether the SCC is an appropriate tool for calculating the benefits 

of reduced emissions. This concern is not applicable to this notice and DOE does not 

attempt to answer that question here, however. 

 

At the time of the preparation of this notice, the most recent interagency estimates 

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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,32

although preference is given to consideration of the global benefits of reducing CO2

emissions.

It is important to emphasize that the interagency process is committed to updating 

these estimates as the science and economic understanding of climate change and its 

impacts on society improves over time. Specifically, the interagency group has set a 

preliminary goal of revisiting the SCC values within 2 years or at such time as 

substantially updated models become available, and to continue to support research in 

this area. In the meantime, the interagency group will continue to explore the issues 

raised by this analysis and consider public comments as part of the ongoing interagency 

process.

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

To date, economicEconomic analyses for Federal regulations have used a wide 

range of values to estimate the benefits associated with reducing CO2carbon dioxide

 

32 It is recognized that this calculation for domestic values is approximate, provisional, and highly 

speculative. There is no a priori reason why domestic benefits should be a constant fraction of net global 

damages over time.

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emissions. In the final Model YearThe model year 2011 CAFECorporate Average Fuel 

Economy final rule, the U.S. Department of Transportation (DOT) used both a 

“domestic” SCC value of $2 per metric ton of CO2 and a “global” SCC value of $33 per 

metric ton of CO2 for 2007 emission reductions (in 2007$), increasing both values at 2.4 

percent per year.33 DOT also included a sensitivity analysis at $80 per metric ton of CO2.

(See Average Fuel Economy Standards Passenger Cars and Light Trucks Model Year 

2011, 74 FR 14196 (March 30, 2009) (Final Rule); Final Environmental Impact 

Statement Corporate Average Fuel Economy Standards, Passenger Cars and Light 

Trucks, Model Years 2011-2015 at 3-90 ([Oct. 2008) (Available]a at: 

http://www.nhtsa.gov/fuel-economy)..) A domestic SCC value is meant to reflect the 

value of damages in the United States resulting from a unit change in CO2 emissions, 

while a global SCC value is meant to reflect the value of damages worldwide.

34

 

33 Throughout this section, references to tons of CO2 refer to metric tons.

 A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per 

metric ton of CO2 (in 2006$) for 2011 emission reductions (with a range of $0−$-$14 for 

sensitivity analysis), also increasing at 2.4 percent per year. (See Average Fuel Economy 

Standards, Passenger Cars and Light Trucks, Model Years 2011-2015, 73 FR 24352 

(May 2, 2008) (Proposed Rule); Draft Environmental Impact Statement Corporate 

Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-

34 See Average Fuel Economy Standards Passenger Cars and Light Trucks Model Year 2011, 74 FR 14196 

(March 30, 2009) (Final Rule); Final Environmental Impact Statement Corporate Average Fuel Economy. 

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2015 at 3-58 (June 2008) (Available at: http://www.nhtsa.gov/fuel-economy)..35 A 

regulation for packaged terminal air conditioners and packaged terminal heat pumps 

finalized by DOE in October of 2008 used a domestic SCC range of $0–$ to $20 per 

metric ton of CO2 for 2007 emission reductions (in 2007$). 73 FR 58772, 58814 (Oct. 7, 

2008) In addition, EPA’s 2008 Advance Notice of Proposed Rulemaking on Regulating 

Greenhouse Gas Emissions Under the Clean Air Act identified what it described as “very 

preliminary” SCC estimates subject to revision. 73 FR 44354 (July 30, 2008). EPA’s 

global mean values were $68 and $40 per metric ton CO2 for discount rates of 

approximately 2 percent and 3 percent, respectively (in 2006$ for 2007 emissions).

In 2009, an interagency process was initiated to offer a preliminary assessment of 

how best to quantify the benefits from reducing carbon dioxide emissions. To ensure 

consistency in how benefits are evaluated across agencies, the Administration sought to 

develop a transparent and defensible method, specifically designed for the rulemaking 

process, to quantify avoided climate change damages from reduced CO2 emissions. The 

interagency group did not undertake any original analysis. Instead, it combined SCC 

estimates from the existing literature to use as interim values until a more comprehensive 

analysis could be conducted. The outcome of the preliminary assessment by the 

interagency group was a set of five interim values: global SCC estimates for 2007 (in 

2006$) of $55, $33, $19, $10, and $5 per metric ton of CO2. These interim values 

 

35 See, Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015, 73 

FR 24352 (May 2, 2008) (Proposed Rule); Draft Environmental Impact Statement Corporate Average Fuel 

Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-58 (June 2008) 

(Available at: http://www.nhtsa.gov/fuel-economy)
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representrepresented the first sustained interagency effort within the U.S. government to 

develop an SCC for use in regulatory analysis. The results of this preliminary effort were 

presented in several proposed and final rules and were offered for public comment in 

connection with proposed rules, including the joint EPA-DOT fuel economy and CO2

tailpipe emission proposed rules..

c. Current Approach and Key Assumptions

Since the release of the interim values, the interagency group reconvened on a 

regular basis to generate improved SCC estimates, which were considered in this NOPR 

for the proposed standard levels.. Specifically, the group considered public comments and 

further explored the technical literature in relevant fields. The interagency group relied on 

three integrated assessment models (IAMs) commonly used to estimate the SCC: the 

FUND, DICE, and PAGE models.36 These models are frequently cited in the peerreviewed literature and were used in the last assessment of the Intergovernmental Panel 

on Climate Change. Each model was given equal weight in the SCC values that were 

developed. 

Each model takes a slightly different approach to model how changes in 

emissions result in changes in economic damages. A key objective of the interagency 

process was to enable a consistent exploration of the three models while respecting the 

different approaches to quantifying damages taken by the key modelers in the field. An 

 

36 The models are described in appendix 16-A of the TSD.

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extensive review of the literature was conducted to select three sets of input parameters 

for these models: climate sensitivity, socio-economic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input 

into all three models. In addition, the interagency group used a range of scenarios for the 

socio-economic parameters and a range of values for the discount rate. All other model 

features were left unchanged, relying on the model developers’ best estimates and 

judgments.

The interagency group selected four sets of SCC values for use in regulatory 

analyses. Three sets of values are based on the average SCC from the three integrated 

assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth valueset, which 

represents the 95th percentile SCC estimate across all three models at a 3-percent discount 

rate, is included to represent higher-than-expected impacts from temperature change 

further out in the tails of the SCC distribution. For emissions (or emission reductions) 

that occur in later years, theseThe values estimated for 2010 grow in real terms over time, 

as depicted in Table IV-17Table IV-17. 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,37

 

37 It is recognized that this calculation for domestic values is approximate, provisional, and highly 

speculative. There is no a priori reason why domestic benefits should be a constant fraction of net global 

damages over time.

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global benefits of reducing CO2 emissions. Table IV-17 presents the values in the 2010 

interagency group report,38 which is reproduced in appendix 16-A of the NOPR TSD.

Table IV-17 Social Cost of CO2Annual SCC Values from 2010 Interagency Report, 

2010–2050 (in 2007 dollars per metric ton)

LXVI. Discount Rate

5% 3% 2.5% 3%

Average Average Average 95th percentile

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

 

The SCC values used for today’s notice were generated using the most recent 

versions of the three integrated assessment models that have been published in the peerreviewed literature.39 Table IV-18 shows the updated sets of SCC estimates in five year 

increments from 2010 to 2050. The full set of annual SCC estimates between 2010 and 

2050 is reported in appendix 16-A of the NOPR TSD. The central value that emerges is 

the average SCC across models at the 3 percent discount rate. However, for purposes of 

 

38 Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United States Government, February 2010. 

http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-forRIA.pdf. 39 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 

12866. Interagency Working Group on Social Cost of Carbon, United States Government. May 2013.

http://www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_update.pdf

 

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capturing the uncertainties involved in regulatory impact analysis, the interagency group 

emphasizes the importance of including all four sets of SCC values. 

Table IV-18 Annual SCC Values from 2013 Interagency Update, 2010–2050 (in 2007 

dollars per metric ton CO2)

Year

Discount Rate %

5 3 2.5 3

Average Average Average 95th Percentile

2010 11 33 52 90

2015 12 38 58 109

2020 12 43 65 129

2025 14 48 70 144

2030 16 52 76 159

2035 19 57 81 176

2040 21 62 87 192

2045 24 66 92 206

2050 27 71 98 221

It is important to recognize that a number of key uncertainties remain, and that 

current SCC estimates should be treated as provisional and revisable since they will 

evolve with improved scientific and economic understanding. The interagency group also 

recognizes that the existing models are imperfect and incomplete. The National Research 

Council report mentioned above points out that there is tension between the goal of 

producing quantified estimates of the economic damages from an incremental ton of 

carbon and the limits of existing efforts to model these effects. There are a number of 

concerns and problems that should be addressed by the research community, including 

research programs housed in many of the Federal agencies participating in the 

interagency process to estimate the SCC.
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DOE recognizes the uncertainties embedded in the estimates of the SCC used for 

cost-benefit analyses. As such, DOE and others in the U.S. Government intend The 

interagency group intends to periodically review and reconsider those estimates to reflect 

increasing knowledge of the science and economics of climate impacts, as well as 

improvements in modeling. In this context, statements recognizing the limitations of the 

analysis and calling for further research take on exceptional significance.

In summary, in considering the potential global benefits resulting from reduced 

CO2 emissions, DOE used the most recent values identified byfrom the 2013 interagency 

processreport, adjusted to 20102012$ using the GDP price deflator values for 2008–

2010.. For each of the four cases specified, the values used for emissions in 20102015

were $412.9, $22.3, $36.540.8, $62.2, and $67.6117 per metric ton avoided (values 

expressed in 2010$).40 To monetize2012$). DOE derived values after 2050 using the 

relevant growth rates for the 2040-2050 period in the interagency update. 

DOE multiplied the CO2 emissions reductions expected to result from new 

standardsreduction estimated for WICF equipment, DOE used the values identified in 

Table A1 of the “Social Cost of Carboneach year by the SCC value for Regulatory 

Impact Analysis Under Executive Order 12866,” which is reprintedthat year in appendix 

16-A of the NOPR TSD, appropriately adjusted to 2010$.each of the four cases. To 

calculate a present value of the stream of monetary values, DOE discounted the values in 

 

40 Table A1 presents SCC values through 2050. For DOE’s calculation, it derived values after 2050 using 

the 3-percent per year escalation rate used by the interagency group.

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each of the four cases using the specific discount rate that had been used to obtain the 

SCC values in each case. 

1.2. Valuation of Other Emissions Reductions

DOE investigated the potential monetary benefit of reduced NOx emissions from 

the TSLs potential standards it considered. As noted above, DOE has taken into account 

how new or amended energy conservation standards would reduce NOx emissions in 

those 22 states that were not affected by the CAIR. DOE estimated the monetized value 

of NOx emissions reductions resulting from each of the TSLs considered for today’s 

NOPR based on environmental damage estimates found in the relevant scientific 

literature. Available estimates suggest a very wide range of monetary values, ranging 

from $370 per ton to $3,800 per ton of NOx from stationary sources, measured ranging 

from $468 to $4809 per ton in 2001$ (equivalent to a range of $450 to $4,623 per ton in 

20102012$).41 In accordance with OMB guidance, 42 DOE conducted two calculations 

ofcalculated the monetary benefits derived using each of the economic values used for 

NOx, one using a NOX and real discount raterates of 3 percent and another using a real 

discount rate of 7 percent.43 

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 

 

41 For additional information, refer to U.S. Office of Management and Budget, Office of Information and 

Regulatory Affairs’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). 43 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).

Comment [A26]: Edits made per OMB.

Comment [A27]: Charlie – The draft from 

August 2012 indicates that we were going to revise 

this sentence. Maybe it fits better with the final text 

that immediately precedes it.

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has decided to await further guidance regarding consistent valuation and reporting of Hg 

emissions before it once again monetizes Hg emissions in its rulemakings.

DOE is evaluating appropriate monetization of SO2 and Hg emissions in energy 

conservation standards rulemakings. It has not included monetization in the current 

analysis.

LXVII.V. Analytical Results

A. Trial Standard Levels

As discussed in section III.B, DOE is proposing to set separate performance 

standards for the refrigeration system and for the envelope’s doors and panels. The 

manufacturers of these components would be required to comply with the applicable 

performance standards. For a fully assembled WICF unit in service, the aggregate energy 

consumption would depend on the individual efficiency levels of both the refrigeration 

system and the components of the envelope.

The refrigeration system removes heat from the interior of the envelope and 

accounts for most of the walk-in’s energy consumption. However, the refrigeration 

system and envelope interact with each other and affect each other’s energy performance. 

On the one hand, because the envelope components reduce the transmission of heat from 

the exterior to the interior of the walk-in, the energy savings benefit for any efficiency 

improvement for these envelope components depends on the efficiency level of the 

refrigeration system. Thus, any potential standard level for the refrigeration system would 

affect the energy that could be saved through standards for the envelope components. On 

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the other hand, the economics of higher-efficiency refrigeration systems depend on the 

refrigeration load profile of the WICF unit as a whole, which is partially impacted by the 

envelope components.

To accurately characterize the total benefits and burdens for each of its proposed 

standard levels, DOE developed TSLs that each consist of a combination of standard 

levels for both the refrigeration system and the set of envelope components that comprise 

a walk-in. In other words, each TSL DOE proposes in this NOPR consists of a standard 

for refrigeration systems, a standard for panels, a standard for non-display doors, and a 

standard for display doors. 

1. Trial Standard Level Selection Process

The paragraphs that follow describe how DOE selected the TSLs. First, DOE 

selected seven potential levels for refrigeration systems by performing LCC and NIA 

analyses for refrigeration systems. Second, DOE selected four levels for the envelope 

components by performing LCC and NIA analyses for the envelope components paired 

with each of the seven selected refrigeration system levels alone. Third, DOE chose six 

composite TSLs from the combinations of the seven potential levels for the refrigeration 

systems and the four potential levels for the envelope components. This process accounts 

for the fact that, as described above, the choice of refrigeration efficiency level affects the 

energy savings and NPV of the envelope component levels. These steps are described 

below.

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In selecting potential levels for the refrigeration systems, DOE focused on certain 

capacity points in the range it considered in the engineering analysis, discussed later in 

this section. DOE selected two representative capacity points in each of the four 

dedicated condensing (DC) product classes to capture the variation in the cost-efficiency 

relationships for products across the entire capacity range.. (For a list of all points 

considered in the engineering analysis, see section IV.C.1.b.) Specifically, DOE 

observed that higher-capacity equipment tended to be more efficient because of the 

availability of scroll compressors above a certain capacity. For the multiplex system 

product classes, DOE chose a single capacity point in each product class because DOE 

found that equipment capacity did not have a significant effect on the efficiency of the 

equipment. 

In selecting the refrigeration capacity points for further analysis, DOE chose

capacities with the highest relative shares of shipments in each equipment class. The 

selected capacities are listed in Table V-1. The lower refrigeration system capacity point 

represents all capacities lower than an intermediate threshold capacity, and the higher 

capacity point represents refrigeration systems having capacities higher than or equal to 

the threshold capacity. The proposed standard level chosen for a particular analyzed 

capacity applies to the entire capacity rangeThe proposed standard levels for each 

equipment class were then based on the analyzed capacities in each capacity range. The 

cost-efficiency tradeoff for the design options is similar over the range of sizes analyzed 

in the engineering analysis. 

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Table V-1 Refrigeration Equipment Class Capacities

LXVIII.Equipment 

Class

LXIX. Analyzed 

CapacityCapacities

(kBtu/hr)

DC.M.I, < 159,000 6

DC.M.I, ≥ 159,000 18

DC.L.I, < 15M.O, < 

9,000 6 

DC.L.I, < 15M.O, ≥

9,000 18,54

DC.M.O, < 7500L.I, < 

9,000 6 

DC.M.O, ≥ 7500L.I, ≥

9,000 9 

DC.L.O, < 75009,000 6 

DC.L.O, ≥ 75009,000 9,54

MC.M 9

MC.L 9 

DOE enumerated seven potential levels for each of the refrigeration system 

classes. Each analyzed capacity point in any refrigeration system class has between 3 and 

13 efficiency levels, each corresponding to an added applicable design option (described 

in section IV.C). DOE also analyzed three competing compressor technologies for each 

dedicated condensing refrigeration system class. These compressor technologies are: 

hermetic reciprocating, semi-hermetic, and scroll. 

At a given efficiency level, the compressor with the best life-cycle cost result was 

selected to represent the equipment at that efficiency level. From the set of possible 

efficiency levels for a given class, DOE selected seven for further analysis. For analyzed 

equipment having less than seven engineering design options (e.g., in the multiplex 

refrigeration system classes), the same efficiency level appeared more than once in the 

suite of seven efficiency levels. Five of the seven refrigeration system levels were based 

on their relative energy saving potential. The other two were based on maximizing the 

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national net present value (“Max NPV”)”), and on achieving the maximum energy 

savings that is possible using all of the compressor technologies (“All Compressors”). 

DOE decided to include an all-compressors criterion for the refrigeration systems 

in response to stakeholder comments that DOE did not consider all types of compressors 

in the preliminary analysis (these comments were discussed in sections IV.C.4.b and 

IV.C.5.b). In particular, interested parties noted that the choice of compressor could 

affect the potential energy savings, but that it was inappropriate to treat compressor 

choice as a design option because not all compressor types are available at all capacities 

for all types of equipment. In response to these comments, DOE developed performance 

curves in the engineering analysis for refrigeration systems with each compressor type 

independently - —identifying the maximum efficiency level for systems with each 

compressor type. The highest refrigeration system efficiency level that could be obtained 

by any compressor type for a given capacity unit was identified. In its set of TSL 

options, DOE included a highest efficiency level for the refrigeration systems at which all 

compressor technologies can compete (“All Compressors”). See chapter 10 of the TSD 

for further details on DOE’s process for selecting potential TSLs.

After the seven potential efficiency levels for each refrigeration system class were 

selected as described above, DOE proceeded with the LCC and NIA analysis of the 

envelope components (panels and doors). DOE conducted the LCC and NIA analyses on 

the envelope components by pairing them with each of the seven refrigeration system 

efficiency levels. Each panel and door class has between five and eightnine potential
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efficiency levels, each corresponding to an engineering design option applicable to that 

class (described in section IV.C). These LCC and NPV results represent the entire range 

of the economic benefits to the consumer at various combinations of efficiency levels of 

the refrigeration systems and the envelope components. The pairing of refrigeration 

system efficiency levels with the efficiency levels of envelope component classes is 

discussed in detail in chapter 10 of the TSD.

DOE selected envelope component levels for further analysis based on the 

following criteria: maximum NPV, maximum NES with positive NPV, and Max Tech. 

DOE also considered a fourth criterion: maximum NES with positive NPV for display 

doors only, and no new standard for panels and non-display doors. DOE considered this 

level because it observed that, due to the nature of the panel and non-display door 

industry, any standard could have a large effect on small panel and door manufacturers. 

This effect is described in detail in chapter 12 of the TSD, Manufacturer Impact Analysis.

Finally, DOE chose six composite TSLs by selecting from the combinations of

the seven potential levels for the refrigeration systems and the four potential levels for the 

envelope components. The composite TSLs and criteria for each one are shown in Table 

V-2. 
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Table V-2 Criteria Description for the Composite TSLs

LXX. Refrigeration System Criteria

Component 

Criteria

All 

Compressors

Max NPV Max NES with 

NPV>0*

Max NES/Max 

Tech

Display Doors 

Only

12: All display 

doors only at 

NPV> 0

Maximum NPV 21: All 

compressors, 

max NPV

4: Maximum 

NPV for both 

refrigeration 

system and 

components

Maximum NES 

with NPV>0

3: All 

compressors, 

NPV>0

5: Max NES 

with NPV>0 for 

both 

Refrigeration 

system and 

Components

Max –Tech 6: Max-tech for 

both 

Refrigeration 

system and 

Components

* Not counted as a separate efficiency level for the refrigeration system, as it corresponds 

to the Max Tech level in the current analysis 

In Table V-2, the column headings identify the criteria for the TSL option for the 

refrigeration system and the row headings identify the criteria for the TSL option for the 

envelope components. The intersection of the row and the column define the respective 

choices for the composite TSL. The composite TSLs are numbered from 1 to 6 in order 

of least to most energy savings.

DOE describes each TSL, from highest to lowest energy savings, as follows. TSL 

6 is the max-tech level for each equipment class for all components. TSL 5 represents the

maximum efficiency level of the refrigeration system productequipment classes with a 

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positive NPV at a 7-percent discount rate, combined with the maximum efficiency level 

with a positive NPV at a 7-percent discount rate for each envelope component (panel, 

non-display door, or display door). TSL 4 corresponds to the efficiency level with the 

maximum NPV for refrigeration system classes and the efficiency level with the 

maximum NPV for envelope component classes. TSL 3 is the highest efficiency level for 

refrigeration systems at which all compressor technologies can compete, combined with 

the maximum efficiency level with a positive NPV at a 7-percent discount rate for each 

envelope component. TSL 2 is the efficiency level with the maximum NPV at a 7-

percent discount rate for refrigeration systems, combined with the efficiency level with a 

maximum NPV at a 7-percent discount rate for display doors only, and does not include a 

new energy standard for panels and non-display doors. DOE is considering TSL 2

because a standard for panels and non-display doors may be unduly burdensome to a 

large number of small business manufacturers (see sections V.B.2.d and VI.B for further 

discussion of the impact of the rule on small manufacturers). TSL 1 is the highest 

efficiency level for refrigeration systems at which all compressor technologies can 

compete, combined with the efficiency level with the maximum NPV at a 7-percent 

discount rate for each envelope component when the components are combined with the 

selected refrigeration efficiency level. For more details on the criteria for the proposed 

TSLs, see chapter 10 of the TSD.

1.2. Trial Standard Level Equations

For panels and doors, DOE expresses the TSLs in terms of a normalization 

metric. For panels, the normalization metric is the ratio of the edge area to the core area. 

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The TSLs are expressed in terms of polynomial equations that establish maximum Ufactor limits in the form of:

C

 Core Area

 Edge Area B

 Core Area

 Edge Area -U factor A

2

 +



 



  ×+  



 ×=

C

 Core Area

 Edge Area B

 Core Area

 Edge Area -U factor A

2

 +



 



  ×+  



 ×=

The form of the equation allows the efficiency requirements to be determined for 

panels of any dimension within an equipment class. Coefficients A, B, and C were 

uniquely derived for each equipment class by plotting the U-factor of each representative 

size in an equipment class versus the edge area to core area ratio of the representative size 

and modeling the relationship as a polynomial equation. The core and edge areas for both 

floor and structural panels are defined in the walk-in cooler and freezer test procedure 

final rule. 76 FR at 33632 (June 9, 2011). 

 

For display and non-display doors, respectively, the normalization metric is the 

surface area of the door. The TSLs are expressed in terms of linear equations that 

establish maximum daily energy consumption (MEC) limits in the form of:

MEC ×= Surface(D Area) + E

MEC ×= Surface(D Area) + E

 

Field Code Changed

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Coefficients D and E were uniquely derived for each equipment class by plotting 

the energy consumption at a given performance level versus the surface area of the door 

and determining the slope of the relationship, D, and the offset, E, where the offset 

represents the theoretical energy consumption of a door with no surface area (the offset is 

necessary because not all energy-consuming components of the door scale directly with 

surface area). The surface area is defined in the walk-in cooler and freezer test procedure 

final rule. 76 FR at 33632. 

For refrigeration systems, the proposed TSLs are expressed as a minimum 

efficiency level (AWEF) that the system must meet. DOE calculated the minimum 

efficiency for two capacity ranges in each class of dedicated condensing refrigeration 

systems and calculated a single minimum efficiency for each class of multiplex 

condensing systems. The capacity ranges used are those shown in Table V-1. For 

dedicated condensing systems, DOE calculated the AWEF differently for small and large 

classes based DOE’s expectation that small sized equipment may have difficulty meeting 

the same efficiency standard as large equipment (see section IV.A.3.b for details).

Specifically, DOE observed that higher-capacity equipment tended to be more efficient 

because of the availability of scroll compressors above a certain capacity. DOE expressed 

the AWEF for large capacity dedicated condensing systems as a single value 

corresponding to the AWEF of the lowest capacity system analyzed in the large capacity 

class. DOE expressed the AWEF for the small capacity dedicated condensing systems as 

a linear equation normalized to the system gross capacity, where the equation was based 

on the AWEFs for the smallest two capacities analyzed but adjusted such that the 
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equation would be continuous with the standard level for the large capacity class at the 

boundary capacity point between the classes (i.e., 9,000 Btu/h). DOE calculated a single 

minimum efficiency for each class of multiplex condensing systems because DOE found 

that equipment capacity did not have a significant effect on the efficiency of the 

equipment. See appendix 10D of the TSD for further details on how the AWEF values 

were calculated. DOE requests comment on the AWEF equations and the methodology 

for determining them. In particular, DOE asks interested parties to submit data on how 

the efficiency of typical refrigeration systems varies by capacity. Based on comments and 

additional data DOE receives on the NOPR, DOE may consider other methods of 

calculating the minimum AWEF associated with the TSLs for each equipment class. 

The following tables present the equations and AWEFs for all TSLs under 

consideration. Table V-3, Table V-4, Table V-5Table V-5, Table V-6, Table V-7, and 

Table V-8 show the standards equations for structural cooler panels, structural freezer 

panels, freezer floor panels, display doors, non-display passage doors, and non-display 

freight doors, respectively. Table V-9 shows the AWEFs for refrigeration systems and 

indicates that the equations and AWEFs for a particular class of equipment may be the 

same across more than one TSL. This occurs when the criteria for two different TSLs are

satisfied by the same efficiency level for a particular component. For example, for all

refrigeration classes the max-tech level has a positive NPV; thus, the efficiency level with 

the maximum energy savings with positive NPV (TSL 5) is the same as the efficiency 

level corresponding to max-tech (TSL 6). 
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Table V-3 Equations for All Structural Cooler Panel TSLs

TSL Equations for Maximum U-Factor (Btu/h-ft

2

-°F)

Baseline

0997.0 189.0 0421.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

10.0 19.0 042.0

 nf core

edge nf

2

 nf core

edge nf

+





×+





×−

AAAA

TSL 1

0118.0 239.0 0405.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

012.0 024.0 041.0

 nf core

edge nf

2

 nf core

edge nf

+





×+





×−

AAAA

TSL 2

0997.0 189.0 0421.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

10.0 19.0 042.0

 nf core

edge nf

2

 nf core

edge nf

+





×+





×−

AAAA

TSL 3

0118.0 239.0 0405.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

010.0 021.0 036.0

 nf core

edge nf

2

 nf core

edge nf

+





×+





×−

AAAA

TSL 4

0118.0 239.0 0405.0

 nf core

edge nf

2

 nf core

edge nf

+



×+





×−

AAAA

017.0 024.0 041.0

 nf core

edge nf

2

 nf core

edge nf

+





×+





×−

AAAA

TSL 5 

0118.0 239.0 0405.0

 nf core

edge nf

2

 nf core

edge nf

+



×+





×−

AAAA

010.0 021.0 036.0

 nf core

edge nf

2

 nf core

edge nf

+





×+





×−

AAAA

TSL 6 0.0113011

Table V-4 Equations for All Structural Freezer Panel TSLs

TSL Equations for Maximum U-Factor (Btu/h

-ft

2

-°F)

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Baseline

00880.0 168.0 0369.0

 nf core

edge nf

2

 nf core

edge nf +















×+ 















×− A

A

A

A

088.0 17.0 037.0

 nf core

edge nf

2

 nf core

edge nf +















×+ 















×− A

A

A

A

TSL 1

00692.0 143.0 0240.0

 nf core

edge nf

2

 nf core

edge nf +















×+ 















×− A

A

A

A

0083.0 017.0 029.0

 nf core

edge nf

2

 nf core

edge nf +















×+ 















×− A

A

A

A

TSL 2

00880.0 168.0 0369.0

 nf core

edge nf

2

 nf core

edge nf +















×+ 















×− A

A

A

A

088.0 17.0 037.0

 nf core

edge nf

2

 nf core

edge nf +















×+ 















×− A

A

A

A

TSL 3 0.0239024

TSL 4

00847.0 172.0 0287.0

 nf core

edge nf

2

 nf core

edge nf +















×+ 















×− A

A

A

A

0083.0 017.0 029.0

 nf core

edge nf

2

 nf core

edge nf +















×+ 















×− A

A

A

A

TSL 5 0.0239024

TSL 6 0.0113011

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Table V-5 Equations for All Freezer Floor Panel TSLs

TSL Equations for Maximum U-Factor (Btu/h

-ft

2

-°F)

Baseline

100.0 194.0 0424.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

098.0 18.0 042.0

fp core

fp edge 

2

fp core

fp edge 

+





×+





×−

AAAA

TSL 1

0108.0 0214.0 0385.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

0091.0 018.0 033.0

fp core

fp edge 

2

fp core

fp edge 

+





×+





×−

AAAA

TSL 2

100.0 194.0 0424.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

098.0 18.0 042.0

fp core

fp edge 

2

fp core

fp edge 

+





×+





×−

AAAA

TSL 3

00653.0 0134.0 0233.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

0064.0 013.0 023.0

fp core

fp edge 

2

fp core

fp edge 

+





×+





×−

AAAA

TSL 4

0108.0 0214.0 0385.0

 nf core

edge nf

2

 nf core

edge nf

+



×+





×−

AAAA

0091.0 018.0 033.0

fp core

fp edge 

2

fp core

fp edge 

+





×+





×−

AAAA

TSL 5

00653.0 0134.0 0233.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

0064.0 013.0 023.0

fp core

fp edge 

2

fp core

fp edge 

+





×+





×−

AAAA

TSL 6 0209.0 0414.0 0115.0

 nf core

edge nf

2

 nf core

edge nf

+



×+



×−

AAAA

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021.0 041.0 011.0

fp core

fp edge 

2

fp core

fp edge 

+





×+





×−

AAAA

Table V-6 Equations for All Display Door TSLs

TSL Equations for Maximum Energy 

Consumption (kWh/day)

DD.M DD.L

Baseline

190.0 +× 21.1 Add

+× 82.014.0 Add

434.0Add +× 13.1

+× 88.036.0 Add

TSL 1

0610.0 +× 586.0 Add

049.0 +× 39.0 Add

251.0Add +× 574.0

+× 38.033.0 Add

TSL 2

0586.0 +× 377.0 Add

049.0 +× 39.0 Add

251.0

Add +× 574.0

+× 38.033.0 Add

TSL 3

0586.0 +× 377.0 Add

049.0 +× 39.0 Add

177.0 +× 584.0 Add

+× 8.306.0 Add

TSL 4

0610.0 +× 586.0 Add

049.0 +× 39.0 Add

251.0

Add +× 574.0

+× 38.033.0 Add

TSL 5

0586.0 +× 377.0 Add

049.0 +× 39.0 Add

251.0Add +× 574.0

+× 38.033.0 Add

TSL 6

0095.0 +× 416.0 Add

0080.0 +× 29.0 Add

136.0 +× 402.0 Add

+× 32.011.0 Add

Field Code Changed

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Table V-7 Equations for All Passage Door TSLs

TSL Equations for Maximum Energy Consumption 

(kWh/day)

PD.M PD.L

Baseline

000395.0 +× 237.0 And

0040.0 +× 24.0 And

141.0 And +× 81.4

141.0 +× 81.4 And

TSL 1

000323.0 And +× 217.0

0032.0 +× 22.0 And

139.0 And +× 04.4

138.0 +× 04.4 And

TSL 2

000395.0 +× 237.0 And

0040.0 +× 24.0 And

141.0 And +× 81.4

141.0 +× 81.4 And

TSL 3

000323.0 +× 217.0 And

0032.0 +× 22.0 And

135.0 +× 99.3 And

135.0 +× 91.3 And

TSL 4

000323.0 +× 217.0 And

0032.0 +× 22.0 And

139.0 +× 30.4 And

138.0 +× 04.4 And

TSL 5

000323.0 +× 217.0 And

0032.0 +× 22.0 And

135.0 +× 05.4 And

135.0 +× 91.3 And

TSL 6

00124.0 +× 00822.0 And

00093.0 +× 0083.0 And

124.0 +× 12.4 And

131.0 +× 88.3 And

Table V-8 Equations for All Freight Door TSLs

TSL Equations for Maximum Energy Consumption 

(kWh/day)

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FD.M FD.L

Baseline

00778.0 +× 108.0 And

0078.0 +× 11.0 And

120.0 +× 47.5 And

+× 6.512.0 And

TSL 1

00727.0 +× 0820.0 And

0073.0 +× 082.0 And

108.0 +× 13.5 And

+× 3.511.0 And

TSL 2

00778.0 +× 108.0 And

0078.0 +× 11.0 And

120.0 +× 47.5 And

+× 6.512.0 And

TSL 3

00727.0 And +× 0820.0

0073.0 +× 082.0 And

101.0 And +× 25.5

+× 2.510.0 And

TSL 4

00727.0 +× 0820.0 And

0073.0 +× 082.0 And

117.0 +× 15.5 And

+× 4.511.0 And

TSL 5

00727.0 +× 0820.0 And

0073.0 +× 082.0 And

101.0 And +× 25.5

+× 2.510.0 And

TSL 6

00134.0 And +× 00474.0

00092.0 +× 13.0 And

0955.0 And +× 25.5

094.0 +× 2.5 And

Table V-9 AWEFs for All Refrigeration System TSLs

Equipment Class Equations for Minimum AWEF (Btu/W-h

Equipment Class Baseline TSLTSLs 1 and 3 TSLTSLs 2 and 4 TSL 3 

DC.M.I, < 9,000 30.21047.2 4 +×× − Q 26.21037.4 4 +×× − Q 5

.41063.2 4 +×× − Q 

DC.M.I, < 15≥ 9,000 3.794.52 6.6319 5.47 5.47 6.6390 

DC.M.O, < 9,000 66.21050.2 4 +×× − Q 57.31010.6 4 +×× − Q 12.01034.1 3 +×× − Q 

DC.M.I, ≥ 15O, ≥ 9,000 4.2991 7.389.06 6.7312.21 

DC.L.I, < 9,000 48.11043.1 4 +×× − Q 16.21010.1 4 +×× − Q 89.11093.1 4 +×× − Q 

DC.L.I, < 15≥ 9,000 2.3677 3.0915 3.2763 

DC.L.O, < 9,000 38.11070.1 4 +×× − Q 16.21043.2 4 +×× − Q 0

.11070.5 4 +×× − Q 

DC.L.I, < 15O, ≥

9,000

2.65 32.91 3.57 3.57 3.91 4.1235 4.126.15 

DC.M.O, < 7500 4.44 9.51 8.84 8.84 9.51 

DCMC.M.O, ≥ 7500 6.80 410.82 12.8110.74 

DCMC.L.O, < 

7500

2.50

4.8766 4.715.91

4.71 4.87

5.1053 

DC.L.O, ≥ 7500 2.87 7.39 5.38 5.38 7.39 

MC.M 6.80 12.86 12.86 12.86 12.86 

MC.L 4.68 6.29 6.29 6.29 6.29 

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B. Economic Justification and Energy Savings 

1. Economic Impacts on Commercial Customers

a. Life-Cycle Cost and Payback Period

Consumers affected by new or amended standards usually incur higher purchase 

prices and experience lower operating costs. DOE evaluates these impacts on individual 

consumers by calculating changes in LCC and the PBP associated with the TSLs. Using 

the approach described in section IV.F, DOE calculated the LCC impacts and PBPs for 

the efficiency levels considered in this NOPR. Inputs used for calculating the LCC 

include total installed costs (i.e., equipment price plus installation costs), annual energy 

savings, and average electricity costs by consumer, energy price trends, repair costs, 

maintenance costs, equipment lifetime, and consumer discount rates. DOE based the LCC 

and PBP analyses on energy consumption under conditions of actual product use. DOE 

created distributions of values for some inputs, with probabilities attached to each value, 

to account for their uncertainty and variability. DOE used probability distributions to 

characterize equipment lifetime, discount rates, sales taxes and several other inputs to the 

LCC model.

The computer model DOE uses to calculate the LCC and PBP, which incorporates 

Crystal Ball (a commercially available software program), relies on a Monte Carlo 

simulation to incorporate uncertainty and variability into the analysis. The Monte Carlo 

simulations randomly sample input values from the probability distributions of the input 

variables and calculate the LCC and PBP from these. Details of the spreadsheet model, 

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20131002_OIRA compare document dated 9-26.docx

and of all the inputs to the LCC and PBP analyses, are contained in TSD chapter 8 and its 

appendices.

DOE’s LCC and PBP analysis results for each refrigeration system are reported in 

Table V-10 through Table V-14Table IV-14 at each TSL for the representative sizes of 

walk-in refrigeration systems in each productequipment class. Each table includes the 

installed cost, total LCC, average LCC savings , the median payback period, and also the 

percentage of customers who will experience a benefit, cost, or no change under a 

proposed standard by performing a Monte Carlo analysis. DOE noted that for all classes 

of refrigeration systems, consumer LCCs were positive up through TSL 6, which 

corresponds to the maximum technologically feasible level (max-tech) refrigeration level.

The median PBP values vary between 2–6 years for the dedicated condensing unit (DC) 

classes and were less than 1 year for the multiplex classes for all TSLs through TSL 6 for 

medium temperature systems and for all TSLs throughTSL2 and TSL 4 for low 

temperature systems. The median PBP exceeded 12 year only for the low temperature 

multiplex systems for TSL 5 and TSL 6 onlyother TSLs considered. DOE also noted that 

higher benefits are experienced by users of larger capacity systems than by the smaller 

capacity systems. The LCC savings and PBP for all the sizes analyzed by DOE are shown 

in TSD chapter 8. 

 

DOE’s LCC and PBP analysis results for all envelope component 

productequipment classes at each TSL are reported in Table V-15Table V-15 through 

Table V-17Table V-17. DOE analyzed three sizes (small, medium and large) in each 
295 

20131002_OIRA compare document dated 9-26.docx

component productequipment class. Results for the components of different sizes in the 

productequipment class are averaged on the basis of their shipment weights and reported 

in these tables. LCC and PBP results for all sizes may be found in chapter 8 of the TSD. 

Table V-10 through Table V-17Table V-17 show that for all the components, LCC 

savings are significantly negative and payback periods are very high at the max-tech level 

(TSL 6).

 

Table V-10 Summary LCC and PBP Results for Medium Temperature Dedicated 

Condensing Refrigeration Systems – Outdoor Condenser

LXXI. Tr

ial 

Standard 

Level

LXXII. Life-Cycle Cost 

(20102012$)

LXXIII.Life-Cycle Cost Savings 

(20102012$)

LXXIV.Payb

ack Period 

(years)

Installed 

Cost

Discount

ed 

Operatin

g Cost

LCC Average 

Savings

% of Consumers 

that Experience

Net No Median

Impa

ct

Net 

Benef

it

Cos

t 

Baseline 5,1474,3

68

8,6637,36

3

13,81011,7

31

TSL1 6,3724,8

91 5,364791 11,73510,682

2,0751,0

48 0 0 100 2.51.3

TSL2 5,976387 5,9254,76

6

11,90110,1

53 1,954577 0 0 100 1.72.5

TSL3 5,9764,9

92 5,925622 11,90110,614 1,954117 0 0 100 1.78

TSL4 6,3725,2

86

5,3644,93

6

11,73510,2

22

2,0751,5

09 0 0 100 2.50

TSL5 7,2495,5

32 4,794591 12,04310,123 1,753608 101 0 9099 4.53.0

TSL6 7,2495,5

32 4,794591 12,04310,123 1,753608 101 0 9099 4.53.0

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Table V-11 Summary LCC and PBP Results for Medium-Temperature Dedicated 

Condensing Refrigeration Systems – Indoor Condenser

LXXV. Tr

ial 

Standard 

Level

LXXVI.Life-Cycle Cost 

(20102012$)

LXXVII. Life-Cycle 

Cost Savings (20102012$)

LXXVIII.

ayback Period 

(years)

Installed 

Cost

Discount

ed 

Operatin

g Cost

LCC

Avera

ge 

Saving

s

% of Consumers 

that Experience

Net No Median

Impa

ct

Net 

Benef

it

Cos

t

Baseline 3,7694,0

33 7,295746 11,064779

TSL1 4,538501 5,6626,99

8

10,20011,4

99 864280 1 0 99 3.12

TSL2 4,175931 6,408238 10,58311,1

69 945611 04 0 10096 2.74.4

TSL3 4,175501 6,408998 10,58311,4

99 945280 01 0 10099 3.2.7

TSL4 4,538931 5,6626,23

8

10,20011,1

69 864611 14 0 9996 3.14.4

TSL5 5,0664,9

31

5,4936,23

8

10,55911,1

69 505611 264 0 7496 6.14.4

TSL6 5,0664,9

31

5,4936,23

8

10,55911,1

69 505611 264 0 7496 6.14.4

Table V-12 Summary of LCC and PBP Results for Low-Temperature DedicatedCondensing Refrigeration Systems – Outdoor Condenser

LXXIX.Trial 

Standard 

Level

LXXX. Life-Cycle Cost (20102012$) LXXXI.Life-Cycle Cost Savings 

(20102012$)

LXXXII. P

ayback Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost

LCC Average 

Savings

% of Consumers that 

Experience Median Net No 

Impact

Net 

Cost Benefit

Baseline 4,086093 10,075471 14,161564

TSL1 5,6294,673 6,1928,564 11,82013,236 2,3401,328 15 0 9995 3.01.2

TSL2 4,9425,377 7,4446,791 12,386168 1,8332,001 05 0 10095 1.82.3

TSL3 4,942673 7,4448,564 12,38613,236 1,833328 05 0 10095 1.82

TSL4 5,629377 6,192791 11,82012,168 2,340001 15 0 9995 2.3.0

TSL5 6,6725,591 5,9816,584 12,653175 1,785994 85 0 9295 4.52.8

TSL6 6,6725,591 5,9816,584 12,653175 1,785994 85 0 9295 4.52.8

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Table V-13 Summary of LCC and PBP Results for Low-Temperature DedicatedCondensing Refrigeration Systems – Indoor Condenser

LXXXIII.

rial 

Standard 

Level

LXXXIV. Life-Cycle Cost 

(20102012$)

LXXXV. Life-Cycle 

Cost Savings (20102012$)

LXXXVI.

ayback Period 

(years)

Installed 

Cost

Discounte

d 

Operating 

Cost

LCC

Averag

e 

Saving

s 

% of Consumers 

that Experience

Net No Median

Impa

ct

Net 

Benef

it

Cos

t

Baseline 3,9094,1

61

12,46113,0

51

16,37017,2

12

TSL1 4,663688 10,28712,0

19

14,95016,7

07

1,4205

05 0 0 100 2.58

TSL2 5,663187 10,55711,0

18 16,219205 9971,117 220 0 78100 4.82.7

TSL3 5,6634,6

88

10,55712,0

19 16,219707 997505 220 0 78100 42.8

TSL4 4,6635,1

87

10,28711,0

18

14,95016,2

05

1,4201

17 0 0 100 2.57

TSL5 6,2265,2

72

9,93910,97

0 16,165242 7311,080 250 0 75100 6.03.1

TSL6 6,2265,2

72

9,93910,97

0 16,165242 7311,080 250 0 75100 6.03.1

Table V-14 Summary LCC and PBP Results for Medium- and Low-Temperature 

Multiplex Refrigeration Systems (Unit Coolers Only)

LXXXVII.

rial 

Standard 

Level

LXXXVIII.

fficiency 

Level

LXXXIX. Life-Cycle Cost 

(20102012$)

XC. Life-Cycle Cost Savings 

(20102012$)

XCI. P

ayback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost

LCC Average 

Savings

% of Consumers that 

Experience Median

Net

Cost

No 

Impact

Net 

Benefit

Cost

Medium Temperature Multiplex

Baseline 1,583 5,0606,143 6,6437,726

TSL1 EL2 1,7132,251 3,398759 5,1126,010 1,531715 0 0 100 0.36

TSL2 EL2 1,7132,231 3,398771 5,1126,002 1,531724 0 0 100 0.35

TSL3 EL2 1,7132,251 3,398759 5,1126,010 1,531715 0 0 100 0.36

TSL4 EL2 1,7132,231 3,398771 5,1126,002 1,531724 0 0 100 0.35

TSL5 EL3 1,7312,251 3,388759 5,1196,010 1,524715 0 0 100 0.46

TSL6 EL3 1,7312,251 3,388759 5,1196,010 1,524715 0 0 100 0.46

Low Temperature Multiplex

Baseline 1,583 8,81110,29

5

10,39411,8

78

TSL1 EL2 1,7982,776 6,8367,252 8,63410,02

8 1,759849 0 0 100 0.72.5

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TSL2 EL2 1,7982,231 6,8367,585 8,6349,817 1,7592,0

61 0 0 100 0.74

TSL3 EL2 1,7982,776 6,8367,252 8,63410,02

8 1,759849 0 0 100 0.72.5

TSL4 EL2 1,7982,231 6,8367,585 8,6349,817 1,7592,0

61 0 0 100 0.74

TSL5 EL3EL5 2,284776 6,5627,252 8,84510,02

8 1,548849 0 0 100 2.65

TSL6 EL3EL5 2,284776 6,5627,252 8,84510,02

8 1,548849 0 0 100 2.65

 

Table V-15 Summary LCC and PBP Results for Structural and Floor Panels 

(Weighted Across All Sizes)

XCII. T

rial 

Standard 

Level

XCIII. Life-Cycle Cost (20102012$) XCIV. Life-Cycle Cost Savings 

(20102012$)

XCV. P

ayback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost

LCC Average 

Savings

% of Consumers that 

Experience Median Net No 

Impact

Net 

Cost Benefit

Medium Temperature StandardStructural Panel

Baseline 9741,007 9397 1,067104

TSL1 9741,007 9397 1,067104 016 014 1000 086 0.03.8

TSL2 998977 73119 1,071095 110 210 0100 790 3.60.0

TSL3 9981,043 7385 1,071128 11-9 2175 0 7925 3.6.8

TSL4 9981,007 6380 1,061088 78 3534 0 6566 4.35

TSL5 9981,043 5765 1,055109 4-22 4293 0 587 4.79.0

TSL6 3,039206 1519 3,054225

-

1,9962,1

39

100 0 0 167.6146.

4

Low Temperature StandardStructural Panel

Baseline 1,051122 363278 1,414400

TSL1 1,051122 363278 1,414400 0122 02 1000 098 0.02.9

TSL2 1,228010 184399 1,412410 420 360 0100 640 4.60.0

TSL3 1,396373 170215 1,566588 -11266 9179 0 921 8.67.4

TSL4 1,155122 198216 1,353338 6172 177 0 8393 3.6

TSL5 1,396373 144161 1,540533 -151140 9694 0 46 10.20

TSL6 3,050208 6876 3,118284

-

1,72889

0

100 0 0 42.343.0

Low Temperature Floor Panel

Baseline 1,153202 301243 1,454445

TSL1 1,153202 301243 1,454445 066 06 1000 094 0.03.5

TSL2 1,236103 220318 1,456421 320 220 0100 780 4.10.0

TSL3 1,452348 134166 1,586515 -994 9262 0 838 8.36.0

TSL4 1,236202 198189 1,434390 2030 3928 0 6172 4.65

TSL5 1,452348 113124 1,566473 -13265 9788 0 312 9.98.0

TSL6 2,920982 7279 2,9913,06

1

-

1,55765 100 0 0 47.148.7

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3

 

Table V-16 Summary LCC and PBP Results for Display Doors (Weighted Across 

All Sizes)

XCVI. Trial 

Standard 

Level

XCVII. Life-Cycle Cost (20102012$) XCVIII.Life-Cycle Cost Savings 

(20102012$)

XCIX. Payback 

Period (years)

Installed 

Cost

Discounted 

Operating 

Cost

LCC Average 

Savings

% of Consumers that 

Experience Median Net No 

Impact

Net 

Cost Benefit

Medium Temperature Display Door

Baseline 7861,100 521530 1,307630

TSL1 1,291205 139186 1,430391 -123239 860 0 14100 7.32.1

TSL2 1,097205 177180 1,273385 48228 420 0 58100 4.82.2

TSL3 1,291205 143186 1,434391 -113239 830 0 17100 72.1

TSL4 1,097205 172180 1,269385 38228 440 0 56100 4.92.2

TSL5 1,291205 137177 1,427382 -129222 870 0 13100 7.42.2

TSL6 3,2294,182 7173 3,2994,255 -

2,001650 100 0 0 30.437.6

Low Temperature Display Door

Baseline 1,322594 1,105412 2,4263,006

TSL1 1,881756 6441,033 2,525789 -99217 750 0 25100 6.9N/A

TSL2 1,881756 665954 2,546710 -84200 730 0 27100 6.6N/A

TSL3 2,236046 491972 2,7273,019 -26512 8964 0 1136 7.96.0

TSL4 1,881756 644954 2,525710 -99200 750 0 25100 6.9N/A

TSL5 1,881756 625942 2,506698 -104198 760 0 24100 6.9N/A

TSL6 3,3094,242 359371 3,6684,613 -

1,267717 100 0 0 1518.5

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Table V-17 Summary LCC and PBP Results for Non-Display Doors (Weighted 

Across All Sizes)

C. Trial 

Standard 

Level

CI. Life-Cycle Cost (20102012$) CII. Life-Cycle Cost Savings 

(20102012$)

CIII. Payback 

Period (years)

Installed 

Cost

Discounted 

Operating 

Cost

LCC Average 

Savings

% of Consumers that 

Experience Median Net No 

Impact

Net 

Cost Benefit

Medium Temperature Passage Door

Baseline 694691 7389 767780

TSL1 694691 7389 767780 02 027 1000 073 0.04.5

TSL2 700683 7091 770774 20 340 0100 660 4.30.0

TSL3 700691 7089 770780 2 3427 0 6673 4.35

TSL4 700691 6683 766774 10 4852 0 5248 5.15

TSL5 700691 6380 764772 0 5964 0 4136 5.6.0

TSL6 1,343637 1319 1,356655 -593884 100 0 0 62.978.7

Low Temperature Passage Door

Baseline 8871,070 1,5872,205 2,4743,274

TSL1 8871,070 1,5872,205 2,4743,274 074 014 1000 086 0.04.3

TSL2 1,053880 1,4632,261 2,5163,142 160 520 0100 480 5.30.0

TSL3 1,196226 1,4172,138 2,6133,364 -8216 8266 0 1834 7.86.2

TSL4 9701,070 1,4652,020 2,4353,090 3852 3727 0 6373 3.94.7

TSL5 1,111226 1,358937 2,4693,163 -3652 7475 0 2625 6.67.0

TSL6 1,395863 1,312913 2,7073,776 -273665 92100 0 0 12.118.3

Medium Temperature Freight Door

Baseline 1,262277 111147 1,373424

TSL1 1,262277 111143 1,373420 03 025 1000 075 0.04.5

TSL2 1,271265 108144 1,380409 30 330 0100 670 4.20.0

TSL3 1,271277 108143 1,380420 3 3325 0 6775 4.25

TSL4 1,271277 100131 1,372408 1 4650 0 5450 5.04

TSL5 1,271277 96126 1,367403 0 5662 0 4438 55.45.9

TSL6 2,355511 2049 2,375560 -

1,008157 100 0 0 7081.5

Low Temperature Freight Door

Baseline 1,262670 1113,424 1,3735,094

TSL1 1,262670 1113,424 1,3735,094 0152 06 1000 094 03.8

TSL2 1,353426 893,491 1,4424,917 -600 1000 0100 0 15.90.0

TSL3 1,553914 363,305 1,5895,219 -20728 10056 0 044 185.8

TSL4 1,325543 863,237 1,4114,780 -39136 1001 0 099 14.02.9

TSL5 1,553914 292,987 1,5834,901 -21632 10069 0 031 21.26.5

TSL6 2,3553,273 202,932 2,3756,205 -

1,008337 100 0 0 70.521.7

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a.b. Life-Cycle Cost Subgroup Analysis

Using the LCC spreadsheet model, DOE estimated the impact of increased WICF 

efficiency standards at each TSL on the following consumer subgroup: small restaurants 

that purchase their own walk-in units. These restaurants are typically identified by the 

Small Business Administration as restaurants with annual receipts of $10 million or 

less.

44 The small restaurant subgroup was analyzed because in the “food service and 

drinking places” business class in the 2007 Census,

45 almost 60 percent of employment 

and sales can be attributed to small restaurants and more than 78 percent of these 

establishments are considered small businesses. Furthermore, DOE received comments 

suggesting small restaurant owners could be particularly vulnerable to potential negative 

consequences of higher efficiency standards and potentially face shorter equipment 

lifetimes. DOE’s LCC analysis shows that restaurants had among the highest financing 

costs (based on weighted average cost of capital of entities using walk-in coolers and 

freezers). Therefore, this group was expected to have the least LCC savings and longest 

PBP of any identifiable consumer group. 

 

44 Small Business Administration. “Table of Small business Size Standards.” SBA.gov. 

http://www.sba.gov/content/guide-size-standards. Accessed July 2011 45 U.S. CENSUS. 2007. U.S. Census Bureau American Fact Finder, 2002 Economic Census-Sector 44: 

Retail Trade: Subject Series–Estab & Firm Size: Single Unit and Multiunit Firms for the United States: 

2007, Washington, D.C..., Accessed July 2011. 

http://www.census.gov/econ/census07/www/data_release_schedule/whats_been_released.html#44. 

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DOE estimated the LCC and PBP for the small restaurants subgroup. 

Table V-18 and Table V-19Table V-19 show the LCC savings for refrigeration systems 

and envelope component equipment, respectively, which meet the proposed energy 

conservation standards for the small restaurant subgroup. Table V-20 and Table 

V-21Table V-21 show the corresponding PBPs (in years) for this subgroup. 

For example, DOE’s analysis shows that at TSL 4, DC.M.I 006 systemsstructural 

cooler panels for small restaurants have lower LCC savings and longer payback periods 

than other business types; however, LCC savings values are still positive for this 

subgroup across all TSLsat this TSL for refrigeration systems.panels. In addition, 

payback periods are typically increased by less than 510 percent compared with the walkin market as a whole. For a more detailed discussion on the LCC subgroup analysis and 

its results, see chapter 11 of the TSD.
303 

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Table V-18 Life-Cycle Cost Savings for WICF Refrigeration Systems (2010$)2012$) 

CIV. Equ

ipment Class CV. Business CVI. TSL1

CVII. TS

L2

CVIII. TS

L3

CIX. TS

L4

CX. TS

L5

CXI. TS

L6

DC.M.I.006 Small Business $59767.25 $709352.58 $70967.25 $597352.58 $231352.58 $231352.58

All Business Types $612 70.30 $721 370.28 $721 70.30 $612 370.28 $248 370.28 $248 370.28

DC.M.I.018 Small Business $2,1821,294

.98

$2,1451,762

.74

$2,1451,294

.98

$2,1821,762

.74

$1,840762.7

4

$1,840762.7

4

All Business Types $2,153 

1,350.45

$2,088 

1,837.93

$2,088 

1,350.45

$2,153 

1,837.93

$1,817 

837.93

$1,817 

837.93

DC.M.O.006 Small Business $831567.37 $783718.28 $783567.37 $831718.28 $486784.16 $486784.16

All Business Types $852 589.85 $802 748.02 $802 748.02 $852 589.85 $513 818.57 $513 818.57

DC.M.O.018 Small Business $3,6741,749

.53

$3,5002,761

.13

$3,5001,749

.53

$3,6742,761

.13

$3,3742,761

.13

$3,3742,761

.13

All Business Types $2,772 

1,817.33

$2,564 

874.34

$2,564 

1,817.33

$2,722 

874.34

$2,410 

874.34

$2,410 

874.34

DC.L.I.006

M.O.054

Small Business $1,26712,02

1.21

$1,04512,56

6.27

$1,04512,02

1.21

$1,26712,56

6.27

$1,04512,56

6.27

$1,04512,56

6.27

All Business Types $1,295 

12,493.74

$335 

13,068.28

$335 

12,493.74

$1,295 

13,068.28

$335 

13,068.28

$335 

13,068.28

DC.L.I.009

006

Small Business $2,586754.4

5

$2,1161,073

.48

$2,116754.4

5

$2,5861,073

.48

$2,2141,035

.60

$2,2141,035

.60

All Business Types $1,581 

788.39

$1,843 

120.12

$1,843 

788.39

$1,581 

120.12

$1,237 

081.45

$1,237 

081.45

DC.L.O.006

I.009

Small Business $2,437136.2

3

$2,1981,031

.11

$2,198136.2

3

$2,4371,031

.11

$1,628031.1

1

$1,628031.1

1

All Business Types $2,504 

142.04

$2,262 

1,112.07

$2,262 

142.04

$2,504 

1,112.07

$1,486 

077.14

$1,486 

077.14

DC.L.O.009

006

Small Business $4,7031,764

.83

$4,0671,747

.88

$4,0671,764

.83

$4,7031,747

.88

$4,3471,773

.85

$4,3471,773

.85

All Business Types $2,259 

1,833.48

$1,618 

814.48

$1,618 

833.48

$2,259 

1,814.48

$1,934 

843.63

$1,934 

843.63

MC.M.N.00

6. 

DC.L.O.009

Small Business $1,404022.9

1

$1,4042,218

.75

$1,404022.9

1

$1,4042,218

.75

$1,3952,184

.74

$1,3952,184

.74

All Business Types $1,531 

059.59

$1,531 

2,307.72

$1,531 

059.59

$1,531 

2,307.72

$1,524 

2,273.00

$1,524 

2,273.00

MCDC.L.N.

006. 

009O.054

Small Business $1,61413,61

9.19

$1,61414,06

1.17

$1,61413,61

9.19

$1,61414,06

1.17

$1,37713,23

1.20

$1,37713,23

1.20

All Business Types $1,759 

14,125.72

$1,759 

14,590.39

$1,759 

14,125.72

$1,759 

14,590.39

$1,548 

13,760.51

$1,548 

13,760.51

*Multiplex refrigeration systems are not typically used in small restaurants.

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Table V-19 Life-Cycle Cost Savings for WICF Envelope Components (Panels and 

Doors) (2010$)2012$) 

CXII. E

quip. 

Class

CXIII. Business CXIV. T

SL1*

CXV. T

SL2

CXVI. T

SL3

CXVII. T

SL4

CXVIII.T

SL5

CXIX. TS

L6

CXX. S

P.M

CXXI. Small 

Business $-$12.65 $10.05 -

$10($8.05

) $5.37 6.20

$2.54 

($16.17)

($1,998.17

2,141.42) 

All Business Types $-$15.55 $11.00 -

$11.00 

($8.98) $7.00 63

$4.00 

($22.44)

($1,996.00

2,138.75)

SP,.L 

Small Business $-$109.66 $33.62 -

($120.727

5.54) 

$55.07 

67.73

($158.069

2.45) 

($1,738.85

901.81) 

All Business Types $-$121.93 $42.00 -

($112.006

5.50) $71.61.00 

($151.001

39.77)

($1,728.00

890.34)

FP.L

Small Business $-$58.43 $27.39 -

($106.241

2.64) 

$16.44 

26.98

($138.315

2.29) 

($1,565.37

661.22) 

All Business Types $-$65.59 $32.00 -

($99.004.

45)

$20.00 

30.28

($132.006

4.89)

($1,557.00

652.86)

DD.M

Small Business ($137.64)

$225.18

$33.80 

214.71

($127.97)

$225.17

$24.96 

214.71

($143.50)

$209.52

($2,017.84

660.23) 

All Business Types ($123.00)

$238.77

$48.00 

227.69

($113.00)

$238.77

$38.00 

227.69

($129.00)

$222.46

($2,001.00

650.38)

DD.L

Small Business ($116.82)

$210.44

($101.98)

$193.37

($289.571

1.78)

($116.82)

$193.37

($121.90)

$191.01

($1,294.85

739.58)

All Business Types ($99.00)$

217.30

($84.00)$

200.08

($265.001

2.17)

($99.00)$

200.08

($104.00)

$197.59

($1,267.00

716.84)

PD.M

Small Business $-$1.80 $1.34 - $1.34 80 $0.29 11 ($0.3488)

($594.7388

6.46)

All Business Types $-$2.13 $2.00 - $2.00 13 $1.00 0.32

$($0.00 

30)

($593.0088

3.91)

PD.L

Small Business $-$64.25 $9.12 -

($90.4737

.17)

$33.75 

42.91

($43.0765

.11)

($283.3267

7.42)

All Business Types $-$73.75 $16.00 -

($82.0015

.74)

$38.00 

51.91

($36.0051

.65)

($273.0066

4.59)

FD.M

Small Business $-$2.96 $2.24 - $2.24 96 $0.64 35

($0.326.1

4)

($1,011.19

160.14)

All Business Types $-$3.46 $3.00 - $3.00 46 $1.00 0.70

$($0.00 

24)

($1,008.00

156.91)

FD.L

Small Business $-$137.63 $24.07 -

($70.64)$

13.37

$35.22 

126.39

($87.2058

.05)

($593.111,

357.39)

All Business Types $192.5715

2.18 $--

$117.4227

.62

$167.3613

6.42

$53.70($3

2.13)

$(404.09($

1,337.03)

*Note: Dashes represent components at baseline efficiency and therefore do not have a payback period.

Note: Numbers in parentheses indicate negative values.

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20131002_OIRA compare document dated 9-26.docx

Table V-20 Payback Period for WICF Refrigeration Systems (Years)

CXXII. Equip

ment CXXIII.Business CXXIV.TSL1

CXXV. T

SL2

CXXVI.T

SL3

CXXVII.

SL4

CXXVIII

SL5

CXXIX.T

SL6

DC.M.I.006 Small Business 3.263 2.95.20 2.93.63 3.25.20 6.45.20 6.45.46

All Business Types 3.340 34.88 3.40 3.34.88 6.64.88 6.64.88

DC.M.I.018 Small Business 2.031 1.2.28 1.2.31 2.028 3.52.28 3.52.28

All Business Types 2.17 1.2.14 1.2.17 2.14 3.62.14 3.62.14

DC.M.O.006 Small Business 2.820 2.3.35 2.35.52 2.80.02 5.74.46 5.74.46

All Business Types 32.11 2.43.21 2.43.21 32.11 64.30 64.30

DC.M.O.018 Small Business 2.21.02 1.32.64 1.302 2.264 3.52.64 3.52.64

All Business Types 2.30.98 1.32.54 1.30.98 2.354 3.82.54 3.82.54

DC.L.I.006M.

O.054

Small Business 2.41.02 3.1.79 3.1.02 2.41.79 3.1.79 3.1.79

All Business Types 2.50.98 71.74 70.98 2.51.74 71.74 71.74

DC.L.I.009006 Small Business 2.3.52 1.72.74 1.73.52 2.374 4.3.16 4.3.16

All Business Types 2.43.32 1.92.58 1.93.32 2.458 4.62.98 4.62.98

DC.L.O.006I.0

09

Small Business 2.419 3.02.22 3.02.19 2.422 4.23.35 4.23.35

All Business Types 2.507 3.2.78 3.2.07 2.578 4.93.16 4.93.16

DC.L.O.00900

6

Small Business 3.02.10 1.177 1.12.10 3.01.77 3.82.88 3.82.88

All Business Types 3.32.03 1.272 1.2.03 3.31.72 4.2.80 4.2.80

MC.M.N.006D

C.L.O.009

Small Business 0.376 0.32.93 0.376 0.32.93 0.43.12 0.43.12

All Business Types 0.374 0.32.84 0.374 0.32.84 0.43.02 0.43.02

MCDC.L.N.00

6.009O.054

Small Business 0.750 0.763 0.750 0.763 2.53.23 2.53.23

All Business Types 0.748 0.761 0.748 0.761 2.63.15 2.63.15

*Multiplex refrigeration systems are not typically used in small restaurants.

Table V-21 Payback Period for WICF Envelope Components (Panels and Doors) 

(Years)

CXXX. E

quipment

CXXXI.Business CXXXII.

SL1*

CXXXIII.

SL2

CXXXIV.

SL3

CXXXV.

SL4

CXXXVI.

SL5

CXXXVII

SL6

SP.M

Small Business - 3.77 3.62- 3.626.77 4.2846 4.718.92 167.0514

6.06

All Business Types - 3.81 3.60- 3.606.80 4.3049 4.708.95 167.6014

6.40

SP,L

Small Business - 2.82 4.63- 8.567.33 3.6360 10.209.8

6 42.1858

All Business Types - 2.85 4.60- 8.607.43 3.6063 10.209.9

5 42.3097

FP.L

Small Business - 3.47 4.10- 8.315.88 4.5842 9.887.92 46.9248.

28

All Business Types - 3.50 4.10- 8.305.96 4.6046 9.907.99 47.1048.

69

DD.M

Small Business 7.32 2.10 4.822.17 7.152.10 4.942.17 7.402.21 30.1637.

28

All Business Types 7.30 2.13 4.802.19 7.102.13 4.902.19 7.402.22 30.4037.

56

DD.L

Small Business 6.86 N/A 6.60N/A 7.856.20 6.86N/A 6.90N/A 15.4818.

91

All Business Types 6.90 N/A 6.60N/A 7.906.01 6.90N/A N/A6.90 15.5018.

48

PD.M

Small Business - 4.52 4.25- 4.2552 5.0448 5.536.01 62.8878.

77

All Business Types - 4.54 4.30- 4.3054 5.1051 5.606.03 62.9078.

73

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306 

20131002_OIRA compare document dated 9-26.docx

PD.L

Small Business - 4.26 5.34- 7.836.22 3.854.70 6.637.02 12.0918.

26

All Business Types - 4.27 5.30- 7.806.23 3.904.69 6.607.02 12.1018.

31

FD.M

Small Business - 4.44 4.16- 4.1644 5.384.94 5.4190 70.4581.

55

All Business Types - 4.46 4.20- 4.2046 5.0041 55.405.9

2

70.5081.

51

FD.L

Small Business - 3.76 4.19- 6.775.76 3.732.92 7.256.54 15.2621.

62

All Business Types - 3.76 15.90- 18.805.7

7

14.002.9

2

21.206.5

4 21.70.50

*Note: Dashes represent components at baseline efficiency and therefore do not have a payback period.

1.2. Economic Impacts on Manufacturers

DOE performed a manufacturer impact analysis (MIA) to estimate the impact of 

new energy conservation standards on manufacturers of walk-in cooler and freezer 

refrigeration, panels, and doors. The section below describes the expected impacts on 

manufacturers at each considered TSL. Chapter 12 of the TSD explains the analysis in 

further detail. 

a. Industry Cash-Flow Analysis Results

Table V-22 through Table V-24 depict the financial impacts on manufacturers and 

the conversion costs DOE estimates manufacturers would incur at each TSL. The 

financial impacts on manufacturers are represented by changes in industry net present 

value (INPV). 

The impact of energy efficiency standards were analyzed under two markup 

scenarios: (1) the preservation of gross margin percentage and (2) the preservation of 

operating profit. As discussed in section IV.I.2.b, DOE considered the preservation of 

gross margin percentage scenario by applying a uniform “gross margin percentage” 

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307 

20131002_OIRA compare document dated 9-26.docx

markup across all efficiency levels. As production cost increases with efficiency, this 

scenario implies that the absolute dollar markup will increase. DOE assumed the 

nonproduction cost markup—which includes SG&A expenses; research and development 

expenses; interest; and profit to be 1.32 for panels, 1.50 for solid doors, 1.62 for display 

doors, and 1.35 for refrigeration. These markups are consistent with the ones DOE 

assumed in the engineering analysis and the base case of the GRIM. Manufacturers have 

indicated that it is optimistic to assume that as their production costs increase in response 

to an efficiency standard, they would be able to maintain the same gross margin 

percentage markup. Therefore, DOE assumes that this scenario represents a high bound 

to industry profitability under an energy-conservation standard.

The preservation of earnings before interest and taxes (EBIT) scenario reflects 

manufacturer concerns about their inability to maintain their margins as manufacturing 

production costs increase to reach more-stringent efficiency levels. In this scenario, while 

manufacturers make the necessary investments required to convert their facilities to 

produce new standards-compliant equipment, operating profit does not change in 

absolute dollars and decreases as a percentage of revenue. 

Each of the modeled scenarios results in a unique set of cash flows and 

corresponding industry values at each TSL. In the following discussion, the INPV results 

refer to the difference in industry value between the base case and each standards case 

that result from the sum of discounted cash flows from the base year 20092013 through 

20452046, the end of the analysis period. To provide perspective on the short-run cash 
308 

20131002_OIRA compare document dated 9-26.docx

flow impact, DOE includes in the discussion of the results a comparison of free cash flow 

between the base case and the standards case at each TSL in the year before new 

standards take effect.

Table V-22 through Table V-24 show the MIA results for each TSL using the 

markup scenarios described above for WICF panel, door and refrigeration manufacturers, 

respectively: 

Table V-22 Manufacturer Impact Analysis Results for WICF Panels

CXXXVIII.

CXXXIX

nits

CXL. B

ase 

Case

CXLI. Trial Standard Level

1 2 3 4 5 6 

INPV 201020

12 $M 66207.3 

66182.2

to 

66195.8

18207.3

to 

29207.3

8144.1

to 

28177.0

45182.2

to 

53195.8

8144.1

to 

28177.0

-

440212.

9 to 

123441.

9

Change in 

INPV

201020

12 $M - -25.0 to 0-11.5

(48)0.0

to 

(37)0.0

(59)-

63.1 to 

(39)-

30.2

(22)-

25.0 to 

(14)-

11.5

(59)-

63.1 to 

(39)-

30.2

(507)-

420.2 to 

57234.7

% - 0-12.1 to 

0-5.6

(72)0.0

to 

(56)0.0

(89)-

30.5 to 

(58)-

14.6

(33)-

12.1 to 

(21)-5.6

(89)-

30.5 to 

(58)-

14.6

(764)-

202.7 to 

86113.2

Free Cash 

Flow (FCF) 

(20142016) 

201020

12 $M 5.718.4 510.7 (13.8)18.4 (14.-3).4 (1.4)10.7 (14.-3).4 (60.5)-54.6

Change in 

FCF

(20142016) 

201020

12 $M - 0.0 -7.7 (19.5)0.0

(20.0)-

21.8 (-7.1)7 (20.0)-21.8

(66.2)-

73.0

% - 0.0 -41.6 (343.8)0

.0

(353.1)-

118.7

(124.7)-

41.6

(353.1)-

118.7

(1,169.8

)-396.9

Conversion 

Costs

201020

12 $M - 0 21 51 0 53 58 19 21 53 58 176 195

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pages

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indents on facing pages, Tab stops: Not at

0.25" + 0.5" + 0.75"

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swap indents on facing pages, Tab stops: Not

at 0.25" + 0.5" + 0.75"

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0.25" + 0.5" + 0.75"

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indents on facing pages, Tab stops: Not at

0.25" + 0.5" + 0.75"

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swap indents on facing pages, Tab stops: Not

at 0.25" + 0.5" + 0.75"

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309 

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Table V-23 Manufacturer Impact Analysis Results for WICF Doors

CXLII.

CXLIII.U

nits

CXLIV.B

ase 

Case

CXLV. Trial Standard Level

1 2 3 4 5 6 

INPV 201020

12 $M

405454.

6 

363437.

6 to 

508470.

7

372446.

2 to 

469470.

2

347428.

2 to 

511467.

8

374437.

8 to 

467470.

6

350427.

3 to 

504466.

4

157260.

8 to 

9891145

.1

Change in 

INPV

201020

12 $M - 

(42)-

17.0 to 

10316.1

(33)-8.4

to 

6315.6

(58)-

26.4 to 

10613.2

(32)-

16.8 to 

6116.0

(56)-

27.3 to 

9811.8

(249)-

193.8 to 

583690.

5

% - (10)-3.7

to 253.5

(-1.8) to 

163.4

(14)-5.8

to 262.9

(8)-3.7

to 153.5

(14)-6.0

to 242.6

(-42.6)1

to 

144151.

9

FCF 

(20142016)

201020

12 $M

30.836.

1

30.8 

34.1

28.9 

36.1

25.6 

30.4

28.9 

34.1

25.6 

30.5 0.1 6

Change in 

FCF

(20142016) 

201020

12 $M - (0.1)-2.07

(1.9)0.0

0 (-5.3)7 (-2.1.9) (-5.2)7 (30.7)-35.6

% - (0.2)-5.7 (6.3)0.0 (17.0)-

15.8 (6.3)-5.7 (17.0)-15.7

(99.6)-

98.5

Conversion 

Costs

201020

12 $M - 0 6 6 0.0 14 15 6 14 15 79 92

Table V-24 Manufacturer Impact Analysis Results for WICF Refrigeration Systems

CXLVI.

CXLVII.

nits

CXLVIII

ase 

Case

CXLIX.Trial Standard Level

1 2 3 4 5 6 

INPV 201020

12 $M

369189.

1 

340170.

9 to 

377183.

3

352153.

6 to 

366184.

8

352170.

9 to 

366183.

3

340153.

6 to 

377184.

8

332145.

8 to 

419188.

3

332145.

8 to 

419188.

3

Change in 

INPV

201020

12 $M - 

(30)-

18.3 to 

7-5.9

(17)-

35.5 to 

(-4).4

(17)-

18.3 to 

(4)-5.9

(30)-

35.5 to 

7-4.4

(37)-

43.3 to 

49-0.8

(37)-

43.3 to 

49-0.8

% - (8)-9.7

to 2-3.1

(5)-18.8

to (1)-

2.3

(5)-9.7

to (-3.1)

(-18.8)

to -2.3

(10)-

22.9 to 

13-0.4

(10)-

22.9 to 

13-0.4

FCF 

(20142016) 

201020

12 $M

30.916.

3

39.6 

11.7 249.1 24.1 11.7 39.6 9.1 22.5 8.0 22.5 8.0

Change in 

FCF

(20142016) 

201020

12 $M - 8.7 -4.6 (6.8)-7.2 (-4.6.8) 8.-7 .2 (-8.3) (-8.3)

% - -28.3 2 (22-

44.0)

(22.0)-

28.2

28.3 -

44.0

(27-

51.0)

(27-

51.0)

Conversion 

Costs

201020

12 $M - 25 15 23 24 23 15 25 24 28 28

Walk-in Cooler and Freezer Panel MIA Results 

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At TSL 1, the standard for all panels are set to the baseline efficiency. As a result, 

there are no changes to INPV, no changes in industry free cash flow, and no conversion 

costs. 

At TSL 2, DOE models the impacts on panel INPV to be definitively negative 

under both mark-up scenarios. The change in panel INPV ranges from -$4825.0 million 

to -$3711.5 million, or a change in INPV of -7212.1 percent to -565.6 percent. At this 

level, panel industry free cash flow46

 

46 Free cash flow (FCF) is a metric commonly used in financial valuation. DOE calculates this value by 

adding back depreciation to net operating profit after tax and subtracting increases in working capital and 

capital expenditures. 

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is estimated to decrease by approximately 344 

percent to -$19.5as much as $7.7 million, or 41.6 percent compared to the base-case 

value of $5.718.4 million, in 2016, the year before the compliance date (2014). Impacts 

on panel manufacturers are significantly more negative at TSL 2 than at TSL 1.. The 

primary driver of the drop in INPV is the standard level for low-temperature side panels, 

which goes up to EL 32. At this levelEL 2, manufacturers would need to update 

production lines to accommodate 6likely use 5-inch panels. As described in chapter 12 of 

the TSD, the move to 6-inch panels is potentially expensive for the industry. thick side 

panels for low-temperature applications to meet the panel standard. At this level, DOE 

estimates conversion costs to be $5121 million for the industry. Some manufacturers will 

need new tooling, including updated foaming stations, jigs, molds, presses that can fit 6-

inch panels. Other manufacturers can manufacture 6-inch panels today but may need to 

purchase additional equipment to maintain current throughput levels since 6-inch panels 

take significantly longer to produce than 4-inch panels due to longer cure times.
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At TSL 2, the standard for all panel equipment classes are set to the 

baseline efficiency. As a result, there are no changes to INPV, no changes in industry free 

cash flow, and no conversion costs. 

At TSL 3, DOE estimates impacts on panel INPV to range from -$5963.1 million 

to -$3930.2 million, or a change in INPV of -8930.5 percent to -5814.6 percent. At this 

level, panel industry free cash flow is estimated to decrease by approximately 353 percent 

to -$14.3as much as $21.8 million, or 118.7% compared to the base-case value of 

$5.718.4 million, in the year before the compliance date. The large percentage drop in 

cash flow in the GRIM indicates that conversion costs are very high relative to the size of 

the industry and relative to annual operating profits. Conversion costs are expected to 

total $58 million. The conversion costs are driven by the move toneed for 6-inch panels 

for both low temperature floor and side panels, as described in chaptersection 12.4.8 of 

the TSD. During manufacturer interviews, some panel manufacturers stated they would 

evaluate leaving the industry rather than make the required investments to meet the 

standard.

At TSL 4, the standard for all panel equipment classes are identical to

those at TSL 1.

DOE estimates TSL 45 impacts on panel INPV to be range from -$2263.1 million 

to -$1430.2 million, or a change in INPV of -3330.5 percent to -2114.6 percent. At this 

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level, panel industry free cash flow is estimated to decrease by approximately 125as 

much as $21.8 million, or 118.7 percent to -$1.4 million, compared to the base-case value 

of $5.718.4 million, in the year before the compliance date. The impacts at TSL 4 are 

significantly less negative than the impacts at TSL 3 because the standards do not move 

manufacturers to 6-inch panels. For low temperature applications, manufacturers would 

likely need to construct walk-in envelopes with 5-inch side panels. The majority of the 

industry can produce 5-inch panels today. As a resultAt this TSL, conversion costs in 

TSL 4 are significantly lower than those in TSL 3total $58 million for the industry. These 

conversion costs are based on DOE’s analysis indicating that industry would likely adopt 

6-inch side floor panels to meet the standard. As in TSL 3, some panel manufacturers 

would likely leave the industry at this level of burden. 

TSL 6 represents the use of max-tech design options for all equipment classes. 

DOE estimates TSL 5 impacts on panel INPV to be range from -$69 million to -$39420.2

million to $234.7 million, or a change in INPV of -89202.7 percent to -58113.2 percent. 

At this level, panel industry free cash flow is estimated to decrease by approximately 

353as much as $73.0 million, or 396.9 percent to -$14.3 million, compared to the basecase value of $5.718.4 million, in the year before the compliance date. The standard 

levelsImpacts at TSL 5 are identical to those at TSL 3 for panels. During interviews, 

panelthe most negative end of the range would likely force many manufacturers indicated 

that some players would likely consider leavingout of the industry at this level. .
313 

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DOE estimates

Walk-in Cooler and Freezer Door MIA Results

For TSL 6 impacts on panel1, DOE models the change in INPV for doors to be 

range from -$44017.0 million to $12316.1 million, or a change in INPV of -5073.7

percent to 573.5 percent. At this standard level, paneldoor industry free cash flow is 

estimated to decrease by as much as 1170$2.1 million, or 5.7 percent to -$60.5 million, 

compared to the base- case value of $5.736.1 million, in the year before the compliance 

date. Impacts of this magnitude would likely force many manufacturers out of the 

industryDOE expects solid door manufacturers to pursue design options that reduce the 

loss of heat through door frames and through embedded windows. Changes to door frame 

design may require new tooling. Total conversion costs for the door industry are expected 

to reach $6 million. 

Walk-in Cooler and Freezer Door MIA Results

At TSL 1, the door manufacturer INPV will change because there is an 

increase in the standard for display doors. At TSL 2, DOE estimates the impacts on door 

INPV to range from -$8.4 million to $15.6 million, or a change in INPV of -1.8 percent 

to 3.4 percent. At this level, door industry free cash flow is estimated to decrease by a 

negligible amount in the year before the compliance year. Furthermore, there are minimal 

conversion costs. To meet the standard, display door manufacturers would need to 

replace existing lighting with LEDs and reduce anti-sweat wire energy consumption. For 

solid door manufacturers, the standard is set at the baseline. Total conversion costs are 

expected to total $0.1 million for the industry. These costs are primarily product 

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conversion costs associated incorporating heater wire controls and updating marketing 

literature.

For TSL 3, DOE estimates changesthe change in door INPV to fall in the range of 

-$42 million to $103 million, or a change in INPV of -11 percent to 25 percent. At this 

level, door industry free cash flow is estimated to not deviate significantly from the basecase value of $30.8 million in the year before the compliance date. 

For TSL 2, door INPV rangesrange from -$3326.4 million to $6313.2 million, or 

a change in INPV of -5.8 percent to 162.9 percent. At this level, door industry free cash 

flow is estimated to decrease by as much as 6.3 $5.7 million, or 15.8 percent to $28.9 

million, compared to the base-case value of $30.836.1 million, in the year before the 

compliance date. The overall impacts on door manufactures do not vary significant from 

TSL 1 to TSL 2. The additional $6 million in conversion costs are driven by changes to 

reduce heat loss through framing materials and through door windows. The conversion 

cost are almost evenly split between capital conversion and product conversion expenses. 

For TSL 3, door INPV ranges from -$58 million to $106 million, or a change in 

INPV of -14 percent to 26 percent, for TSL 3. At this level, door industry free cash flow 

is estimated to decrease by as much as 17.0 percent to $25.6 million, compared to the 

base-case value of $30.8 million, in the year before the compliance date. At this level, 

soliddisplay doors would need to incorporate lighting sensors. Solid doors for low 

temperature walk-ins would likely need to be redesigned to 6-inches of thickness. The 
315 

20131002_OIRA compare document dated 9-26.docx

redesign process and the additional production equipment to foam six-inchesand the cost

of insulationproduct redesigns drive the conversion costs up to $15 million, more than 

double. the conversion costs at TSL 1 and TSL 2. This conversion cost number assumes 

that panel manufacturesmanufacturers that also produce both panels and solid doors 

would already haveuse the same foaming equipment and presses in place to foam at 6-

inchesto produce both products since DOE models panel manufacturers also going to 6-

inch side panels for low temperature applications at TSL 3. Manufacturers that 

exclusively produce freight doors and passage doors will not be able to spread their 

investment over as many equipment classes.

For TSL 4, DOE estimates impacts on door INPV to range from -$3216.8

million to $6116.0 million, or a change in INPV of -83.7 percent to 153.5 percent, at TSL 

4. At this considered level, door industry free cash flow is estimated to decrease by as 

much as 6.3$2.1 million, or 5.7 percent to $28.9 million, compared to the base-case value 

of $30.836.1 million, in the year before the compliance date. To meet TSL 4The standard 

levels for doors at TSL 4 are nearly identical to the standard levels at TSL 2, except that 

the standard is one efficiency level lower for the low temperature freight door equipment 

class. As mentioned above, DOE expects display doorsdoor manufacturers to pursue 

design changes that do not require new manufacturing equipment. These include adding 

controlsManufacturers are expected to use LEDs in display doors and reduce anti-sweat 

wire energy consumption and adding LED lighting.for medium temperature applications.

DOE expectexpects solid door manufacturesmanufacturers to also pursue design options 

that do not require significant investments in new tooling. The design options center on 

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reducingreduce the loss of heat through the door frameframes and through embedded 

windows. While these product design changes require engineering efforts, they do not 

require expensive changes to the manufacturing line. No changes to insulation thickness 

are necessary for TSL 4. As a result,Changes to door frame design may require new 

tooling. Total conversion costs for TSL 4 are much lower than those for TSL 3are 

expected to reach $6 million for the industry. 

For TSL 5, DOE estimates impacts on door INPV to range from -$5627.3 million 

to $9811.8 million, or a change in INPV of -146.0 percent to 242.6 percent, at TSL 5. At 

this level, door industry free cash flow is estimated to decrease by as much as 17.0 

percent to $25.6$5.7 million, or 15.7 percent compared to the base-case value of 

$30.836.1 million, in the year before the compliance date. This standard level for doors 

at TSL 5 is similar but slightly less stringent thannearly identical to the standard levels at

TSL 3. Total conversion costs are expected to reach $15 million. 

For TSL 6, DOE estimates impacts on door INPV to range from -$249193.8

million to $583690.5 million, or a change in INPV of -6142.6 percent to 144151.9

percent, at TSL 6. At this level, door industry free cash flow is estimated to decrease by 

as much as 99$35.6 percent to $0.1 million, or 98.5 percent compared to the base-case 

value of $30.836.1 million, in the year before the compliance date. Conversion costs 

would total $92 million. At this level, some door manufacturers maywould likely choose 

to leave the industry rather than make the necessary investments to comply with 

standards. 
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Walk-in Cooler and Freezer Refrigeration MIA Results

At TSL 1, DOE estimates impacts on refrigeration INPV to range from -$3018.3

million to $7-$5.9 million, or a change in INPV of -89.7 percent to 2-3.1 percent. At this 

level, refrigeration industry free cash flow is estimated to increasedecrease by 

approximately 28.3 percent to 39as much as $4.6 million, or 28.2 percent compared to the 

base-case value of $30.916.3 million, in 2016, the year before the compliance date.year.

For dedicated condensing, medium temperature, indoor refrigeration systems, DOE’s 

engineering analysis indicates that manufacturers would need to incorporate multiple 

design options to achieve this standard. The design options would likely include variable 

speed evaporator fan motors and larger condensing coils. For dedicated condensing, low 

temperature, indoor refrigeration systems, manufacturers may need to further include 

improved condenser fan, improved evaporator fan blades, and electronically commutated 

motors. For dedicated condensing, medium temperature, outdoor refrigeration systems, 

design options necessary to meet TSL 1 would include variable speed evaporator fan 

motors, improved condenser fan blades, electronically commutated condenser fan motors, 

and improved evaporator fan blades. For dedicated condensing, low temperature, outdoor 

refrigeration systems, additional design options required to meet the trial standard level 

include ambient sub-cooling, variable speed condenser fans, and defrost control 

strategies. For multiplex refrigeration, manufacturers would need to evaluate design 

improvements, such as variable speed evaporator fan motors, improved fan blade designs, 

defrost control, and hot gas defrost. Integration of these design options across equipment 

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classes will require extensive engineering investments. As a result, conversion costs total 

$15 million for the industry. 

At TSL 2, DOE estimates impacts on refrigeration INPV to range from -$1735.5

million to -$4.4 million, or a change in INPV of -518.8 percent to -12.3 percent. At this 

level, refrigeration industry free cash flow is estimated to decrease by 22as much as $7.2 

million, or 44.0 percent to $24.1 million, compared to the base-case value of $30.916.3

million, in the year before the compliance date (2014). 47

 

47 Free cash flow (FCF) is a metric commonly used in financial valuation. DOE calculates this value by 

adding back depreciation to net operating profit after tax and subtracting increases in working capital and 

capital expenditures. 

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. From TSL 1 to TSL 2, 

standards for all high-volume refrigeration equipment class step down. As a result, INPV 

impacts are less negative and conversion costs decrease from TSL 1 to TSL 2increase for 

most equipment classes. For dedicated condensing, medium temperature, indoor systems, 

a manufacturer would need to consider including electronically commutated condenser 

fan motors, improved condenser fan blades, and improved evaporator fan blades. For 

dedicated condensing, medium temperature, outdoor systems, the most cost effective 

options include using ambient subcooling, variable speed condenser fan motors, and 

floating head pressure with electronic expansion valves. For dedicated condensing, low 

temperature, outdoor systems, manufacturers will need to consider incorporating 

improved evaporator fan blades, larger condenser coils, and floating head pressure with 

electronic expansion valves. The range of changes does not require significant amounts 

of new production equipment, but could require substantial development and engineering 
319 

20131002_OIRA compare document dated 9-26.docx

time. DOE estimates the WICF refrigeration industry’s conversion costs to increase to 

$24 million. 

At TSL 3, the standards and the impacts on the walk-in refrigeration industry are

identical to those at TSL 2.

At TSL 4 At TSL 3, the standards and the impacts on the walk-in refrigeration 

industry are identical to those at TSL 1.

At TSL 4, the standards and the impacts on the walk-in refrigeration industry are 

identical to those at TSL 2.

 

TSL 5, and TSL 6 represent max-tech for WICF refrigeration systems. DOE 

estimates impacts on the refrigeration INPV to range from -$3743.3 million to $49-$0.8

million, or a change in INPV of -1022.9 percent to 13-0.4 percent. At this level, 

refrigeration industry free cash flow is estimated to decrease by 27as much as $8.3 

million, or 51.0 percent to $22.5 million, compared to the base-case value of $30.916.3

million, in the year before the compliance date. TSL 5 moves all refrigeration design 

options to the max tech level. For dedicated condensing indoor refrigeration,year. DOE’s 

engineering analysis indicates that manufacturers would need to incorporate multiple 

design changes beyond those for TSL 4 and TSL 3 to achieve this standard, including 

variable drive compressors, electronically commutated motors condenser fan motors, 

improved evaporator fan blade designs, improved condenser fan blade designs, larger 

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condenser coils, variable speed condenser fans, and defrost control strategies that reduce 

power consumption. For. Additional design changes for dedicated condensing, low 

temperature, indoor and outdoor refrigeration, additional design options would need to be 

explored, including variable speed condenser fans, ambient sub-cooling, and floating 

head pressure with electronic expansion valves. would include defrost controls. For 

multiplex refrigeration, manufacturers would need to evaluate design improvements, such 

as modulating and variable speed evaporator fans, improved evaporator fan blades, 

defrost control strategies, and hot gas defrost cycles. Integration of these design options 

will require extensive engineering investments. As a result,units, the standard levels at 

TSL 5 and 6 are identical to those at TSL 1. Total conversion costs totalare expected to 

reach $28 million for the industry.

At TSL 6, the standards and impacts on the walk-in refrigeration industry are 

identical to TSL 5.

a.b. Impacts on Direct Employment

Methodology

To quantitatively assess the impacts of energy conservation standards on 

employment, DOE used the GRIM to estimate the domestic labor expenditures and 

number of employees in the base case and at each TSL from 20102013 through 

20452046. DOE used statistical data from the U.S. Census Bureau’s 2009 Economic 

Census,2011 Annual Survey of Manufacturers (ASM), the results of the engineering 

analysis, and interviews with manufacturers to determine the inputs necessary to calculate 

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industry-wide labor expenditures and domestic employment levels. Labor expenditures 

related to manufacturing of the product are a function of the labor intensity of the 

product, the sales volume, and an assumption that wages remain fixed in real terms over 

time. The total labor expenditures in each year are calculated by multiplying the MPCs 

by the labor percentage of MPCs. 

The total labor expenditures in the GRIM were then converted to domestic 

production employment levels by dividing production labor expenditures by the annual 

payment per production worker (production worker hours timesmultiplied by the labor 

rate found in the U.S. Census Bureau’s 2009 Economic Census).2011 ASM). The 

estimates of production workers in this section cover workers, including line- supervisors 

who are directly involved in fabricating and assembling a product within the OEM 

facility. Workers performing services that are closely associated with production 

operations, such as materials handling tasks using forklifts, are also included as 

production labor. DOE’s estimates only account for production workers who manufacture 

the specific products covered by this rulemaking. To further establish a lower bound to 

negative impacts on employment, DOE reviewed design options, conversion costs, and 

market share information to determine the maximum number of manufacturers that 

would leave the industry at each TSL.

The number of non-production employees was calculated by multiplying the 

number of production workers by the ratio of non-production workers to production 

workers calculated using the employment data from the U.S. Census Bureau’s 2009 
322 

20131002_OIRA compare document dated 9-26.docx

Economic Census. The total direct employment impacts calculated in the GRIM are the 

sum of the production and non-production workers. 

In evaluating the impact of energy efficiency standards on employment, DOE 

performed separate analyses on all three walk-in component manufacturer industries: 

panels, doors and refrigeration systems. 

Employment Impacts

Using the GRIM, DOE estimates in the absence of new energy conservation 

standardstandards, there would be 3,257482 domestic production workers for walk-in 

panels, 994 domestic1,187domestic production workers for walk-in doors, and 394346

domestic production workers for walk-in refrigeration systems in 2015. DOE also 

estimates that, for every one production worker, there will be 0.471 non-production 

workers, resulting in 4,791 total employees for panels, 1,462 total employees for doors, 

and 580 total employees for refrigeration systems.2017. 

Table V-25, Table V-26, and Table V-27Table V-25, Table V-26, and 

Table V-27 show the range of the impacts of potential new energy conservation standards 

on U.S. production workers in the panel, door, and refrigeration system markets, 

respectively. Additional detail on the analysis of direct employment can be found in 

chapter 12 of the TSD.

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Table V-25 Potential Changes in the Total Number of Domestic Production Workers in 

20152017 for Panels

CL. TSL CLI. 1 CLII. 2 CLIII. 3 CLIV. 4 CLV. 5 CLVI. 6

Total Number of 

Domestic Production 

Workers 2015

3,194 3,389 3,556 3,376 3,556 6,292

Potential Changes in 

Domestic Production 

Workers 2015*2017

(from a base case 

employment of 3,462)

(3257)

-435

to

(64)134 

(3257)

to

1320

(3257)

-871

to

299490 

(3257)

-435

to

119134 

(3257)

-871

to

299490 

(3257)

-1741

to

3,034243 

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers. 

Table V-26 Potential Changes in the Total Number of Domestic Production 

Workers in 20152017 for Doors

CLVII. TSL CLVIII.1 CLIX. 2 CLX. 3 CLXI. 4 CLXII. 5 CLXIII.6

Total Number of 

Domestic Production 

Workers 2015

1,269 1,204 1,367 1,181 1,332 3,215

Potential Changes in 

Domestic Production 

Workers 2015*2017

(from a base case 

employment of 1,187)

(994)

-60

to

275149 

(994)

0

to

21097 

(994)

-120

to

373196 

(994)

-60

to

187146 

(994)

-120

to

338192 

(994)

-349

to

2,221409 

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers. 

Table V-27 Potential Changes in the Total Number of Domestic Production Workers in 

20152017 for Refrigeration Systems

CLXIV.TSL CLXV. 1 CLXVI. 2 CLXVII. CLXVIII. CLXIX. 5 CLXX. 6

Total Number of 

Domestic Production 

Workers 2015

462 427 427 462 523 523

Potential Changes in 

Domestic Production 

Workers 2015*2017

(from a base case 

employment of 346)

(394)

0

to

6831

(394)

-88

to

3374

(394)

0

to

3331

(394)

-88

to

6874

(394)

-116

to

12999

(394)

-116

to

12999

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers. 

The employment impacts shown in Table V-25Table V-25 through Table 

V-27Table V-27 represent the potential production employment changes that could result 

following the compliance date of new energy conservation standards. The upper end of 

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the results in the table estimates the maximum increase in the number of production 

workers after the implementation of new energy conservation standards and it assumes 

that manufacturers would continue to produce the same scope of covered products within 

the United States. The upperlower end of the range also assumes that domestic 

production does not shift to countries with lower labor costs. The lower end ofrepresents

the range indicatesmaximum decrease to the total number of U.S. production workers in 

the industry who could lose their jobs if all existing production were moved outside ofdue 

to manufacturers leaving the United States. industry. However, in the long-run, DOE

would expect the manufacturers that do not leave the industry to add employees to cover 

lost capacity and to meet market demand.

The employment impacts shown are independent of the employment impacts from 

the broader U.S. economy, which are documented in the Employment Impact Analysis, 

chapter 13 of the TSD.

Based on the GRIM analysis, DOE estimates that there would be positive 

employment impacts among walk in manufacturers at the upper bound. This effect occurs 

in part because the analysis assumes that the labor content, as a percentage of total MPC, 

stays consistent across all efficiency levels. However, this assumption may overstate 

employment at the most stringent TSLs, where design options require more expensive 

components but manufacturing complexity and labor requirements do not necessarily 

scale in direct proportion to manufacturer production cost. DOE presents a range of 

potential employment impacts to account for these and other uncertainties.

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a.c. Impacts on Manufacturing Capacity 

Panels

Manufacturers indicated that design options that necessitate thicker panels could 

lead to longer production times for panels. In general, every additional inch of foam 

increases panel cure times by roughly 20 minutes. DOE understands from manufacturer 

interviews, however, that the industry is not currently operating at full capacity. Given 

this fact, and the number of playersmanufacturers able to produce panels above the 

baseline today, an increase in thickness at lower panel standards – that is, a standard that 

is based on 4-inch or 5-inch panels – is not likely to lead to product shortages in the 

industry – that is, standards that are based on 4-inch or 5-inch panels.. However, a 

standard that necessitates 6-inch panels for any of the panel productequipment classes 

would require manufacturesmanufacturers to add equipment to maintain throughput due

to longer curing times, or to purchase all new tooling to enable production if the 

manufacturer’s current equipment cannot accommodate 6-inch panels. These conversion 

costs are discussed further in chapter 12 of the TSD.

Doors

Display door manufacturers did not identify any design options which would lead 

to capacity constraints. However, manufacturers commented on differences between the 

two types of low-emittance coatingcoatings analyzed: hard low emittance coating (“hardcoat”), the baseline option, and soft low emittance coating (“soft-coat”), the 

corresponding design option. Hard-coat is applied to the glass pane at high temperatures 

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during the formation of the pane, and is extremely durable, while soft-coat is applied in a 

separate step after the glass pane is formed and is less durable than hard low emittance 

coating, but has better performance characteristics. Manufacturers indicated that soft-coat

is significantly more difficult to work with and may require new conveyor equipment. As 

manufacturers adjust to working with soft-coat, longer lead times may occur. 

The production of solid doors is very similar to the production of panels and faces 

the same capacity challenges as panels. As indicated in the panel discussion above, DOE 

does not anticipate capacity constraints at a standard that moves manufacturers to 5-

inches of thickness.

Refrigeration

DOE did not identify any significant capacity constraints for the design options 

being evaluated for this rulemaking. For most refrigeration manufacturers, the walk-in 

market makes up a relatively small percentage of their overall revenues. Additionally, 

most of the design options being evaluated are available as product options today. As a 

result, the industry should not experience capacity constraints directly resulting from an 

energy conservation standard.

b.d. Impacts on Small Manufacturer Sub-Group 

As discussed in section IV.I.1, using average cost assumptions to develop an 

industry cash-flow estimate may not be adequate for assessing differential impacts among 

manufacturer sub-groups. Small manufacturers, niche equipment manufacturers, and 

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manufacturers exhibiting a cost structure substantially different from the industry average 

could be affected disproportionately. DOE used the results of the industry 

characterization to group manufacturers exhibiting similar characteristics. Consequently, 

DOE analyzes small manufacturers as a sub-group. 

DOE evaluated the impact of new energy conservation standards on small 

manufacturers, specifically ones defined as “small businesses” by the SBA. The SBA 

defines a “small business” as having 750 employees or less for NAICS 333415, “AirConditioning and Warm Air Heating Equipment and Commercial and Industrial 

Refrigeration Equipment Manufacturing.” Based on this definition, DOE identified two2

refrigeration system manufacturers, forty-two42 panel manufacturers, and five5 door 

manufacturers in the WICF industry that are small businesses. DOE describes the 

differential impacts on these small businesses in today’s notice at section VI.B, Review 

Under the Regulatory Flexibility Act. 

Section VI.B concludes that larger manufacturers could have a competitive 

advantage in multiple component markets due to their size, engineering and testing 

resources, and ability to access capital. Additionally, in some market segments, larger 

manufacturers have significantly higher production volumes over which to spread costs. 

In particular, DOE’s analysis shows that this rule could drive consolidation in the walk-in 

cooler and freezer panel industry. While DOE cannot certify that today’s rule would not 

have a significant economic impact on a substantial number of small manufacturers, DOE 

has considered these potential impacts and sought to mitigate any such impacts in today’s 
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rule.choosing the TSL proposed in today’s rule. For example, DOE specifically 

considered TSL 2, which would not raise the efficiency requirement on panel 

manufacturers above the base case level in order to minimize impacts on panel 

manufacturers. . In addition to the range of TSLs considered, alternatives to the proposed 

rule that were considered include the following policy alternatives: (1) no new regulatory 

action, (2) commercial consumer rebates, and (3) commercial consumer tax credits. 

Chapter 17 of the TSD associated with this proposed rule includes a report referred to in 

Section VI.A in the preamble as the regulatory impact analysis (RIA). The energy 

savings of these regulatory alternatives are one to two orders of magnitude smaller than 

those expected from the standard levels under consideration. The range of economic 

impacts of these regulatory alternatives is an order of magnitude smaller than the range of 

impacts expected from the standard levels under consideration. For a complete 

discussion of the impacts on small businesses, see section VI.B and chapter 12 of the 

TSD.

c.e. Cumulative Regulatory Burden

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of several impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or an entire industry. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. Multiple 

regulations affecting the same manufacturer can strain profits and can lead companies to 

abandon product lines or markets with lower expected future returns than competing 

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products. For these reasons, DOE conducts an analysis of cumulative regulatory burden 

as part of its rulemakings pertaining to appliance and equipment efficiency.

For the cumulative regulatory burden analysis, DOE looks at other regulations 

that could affect walk in cooler and freezer manufacturers that will take effect 

approximately 3 years before or after the compliance date of new energy conservation 

standards for these products. In addition to the new energy conservation regulations on 

walk-ins, several other Federal regulations apply to these products and other equipment 

produced by the same manufacturers. While the cumulative regulatory burden focuses on 

the impacts on manufacturers of other Federal requirements, DOE also describes a 

number of other regulations in section VI.B because it recognizes that these regulations 

also impact the products covered by this rulemaking. 

Companies that produce a wide range of regulated products may be faced with 

more capital and product development expenditures than competitors with a narrower 

scope of products. Regulatory burdens can prompt companies to exit the market or reduce 

their product offerings, potentially reducing competition. Smaller companies in particular 

can be affected by regulatory costs since these companies have lower sales volumes over 

which they can amortize the costs of meeting new regulations. In the following 

paragraphs, DOE discusses below the regulatory burdens manufacturers could 

experience:, mainly, DOE regulations for other products or equipment produced by walkin manufacturers and other Federal requirements including the United States Clean Air 

Act, the Energy Independence and Security Act of 2007. While this analysis focuses on 
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the impacts on manufacturers of other Federal requirements, in this section DOE also 

describes a number of other regulations that could also impact the WICF 

productsequipment covered by this rulemaking: potential climate change and greenhouse 

gas legislation, State conservation standards, and food safety regulations. DOE discusses 

these and other requirements, and includes the full details of the cumulative regulatory 

burden, in chapter 12 of the NOPR TSD.

DOE Regulations for Other Products Produced by Walk–--In Cooler and Freezer 

Manufacturers

In addition to the new energy conservation standards on walk in cooler and 

freezer productsequipment, several other Federal regulations apply to other products 

produced by the same manufacturers. DOE recognizes that each regulation can 

significantly affect a manufacturer’s financial operations. Multiple regulations affecting 

the same manufacturer can strain manufacturers’ profits and possibly cause an exit from 

the market. DOE is conducting an energy conservation standard rulemaking for 

commercial refrigeration equipment but does not include the costs of this rulemaking in 

its cumulative analysis because the costs of that rulemaking are speculative at this time. 

. In its Notice of Proposed Rulemaking for commercial refrigeration equipment, DOE 

initially estimated conversion costs for the CRE industry to total $87.5 million.

Conversion costs are one-time expenses the industry will bear between the announcement 

date of the standard and the effective date of the standard.

Federal Clean Air Act

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The Clean Air Act defines the EPA's responsibilities for protecting and improving 

the nation's air quality and the stratospheric ozone layer. The most significant of these

additional regulations is the EPA -mandated phase-out of hydrochlorofluorocarbons 

(HCFCs). The Act requires that, on a quarterly basis, any person who produced, 

imported, or exported certain substances, including HCFC refrigerants, report the amount 

produced, imported and exported. Additionally—effective January 1, 2015—selling, 

manufacturing, and using any such substance is banned unless such substance (1) has 

been used, recovered, and recycled; (2) is used and entirely consumed in the production 

of other chemicals; or (3) is used as a refrigerant in appliances manufactured prior to 

January 1, 2020. Finally, production phase-outs will continue until January 1, 2030 when 

such production will be illegal. These bans could trigger design changes to natural or low 

global warming potential refrigerants and could impact the insulation used in products 

covered by this rulemaking.

Energy Independence and Security Act of 2007

The Energy Independence and Security Act (EISA) of 2007, Pub. L. 110-14, 

made numerous amendments to the Energy Policy and Conservation Act (EPCA) of 

1975, Pub. L. 94-163, (42 U.S.C. 6291–6309), which established an energy conservation 

program for major household appliances and industrial and commercial equipment. 

EPCA, as amended by EISA, contains prescriptive standards for the WICF industry to 

meet (starting in 2009) that affect the thermal enclosure, motors, and lights. (42 U.S.C. 

6313(f)(1)) Some manufacturers noted that compliance with those CongressionallyFormatted: Font color: Black

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mandated requirements has forced them to incur significant product re-design costs, 

affecting their production process and ultimately their bottom line. 

Compliant WICF units are required to contain wall, ceiling, and door insulation of 

at least R-25 for coolers and R-32 for freezers and contain floor insulation of at least R28 for freezers. (42 U.S.C. 6313(f)(1)(C)-(D)) To attain the insulation levels prescribed, 

manufacturers that had built their production operations around expanded polystyrene as 

their preferred insulation material have had to incur considerable conversion costs, 

including retooling and testing. This change in raw material has greatly impacted those 

manufacturers’ cost structure and negatively affected their profitability. On the other 

hand, for those manufactures already using polyurethane as their preferred insulation 

material, complying with the EPCA regulations did not require a significant change to 

their operations or considerably impact their cost structure. 

Potential Climate Change and Greenhouse Gas Legislation

Many manufacturers expressed concern about potential climate change 

legislation. The main concern revolves around legislation that would initiate a phasedown of hydrofluorocarbons (HFCs) and would make the new energy conservation 

standard levels considered in this rulemaking more difficult to achieve. Manufacturers are 

particularly concerned because without a clear alternative or substitute to HFCs, any 

phase-out would create a period of uncertainty as the industry identifies suitable 

alternatives and then redesigns both products and processes around the replacement. In 

general, past phase-outs have led to more expensive and less efficient refrigerant 
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replacements. Manufacturers noted that alternative refrigerants may require substantially 

larger systems to achieve the same levels of performance or increase the risk associated 

with the use of flammable substances. 

DOE notes that it does not consider proposed legislation in its cumulative 

regulatory burden analysis because the impacts of such legislation are speculative.

State Conservation Standards

Since 2004, the State of California has had established energy standards for walkin coolers and freezers. California’s Code of Regulations (Title 20, Section 1605) 

prescribe requirements for insulation levels, motor types, and use of automatic doorclosers used for WICF applications. However, based on regulations effective January 

2011, theThese requirements for walk-ins manufactured on or after January 1, 2009, are 

identical to the ones that are contained in EPCA. Therefore, California’s Title 20have 

since been amended and mirror those standards do not pose an additional regulatory 

burden above that which has already been established in EPCA.that Congress prescribed 

as part of EISA 2007. Other States, notably, Connecticut, Maryland, and Oregon, have 

recently established energy efficiency standards for walk-ins that are also identical to the 

ones contained in EPCA, so these. These standards alsowould not be preempted until any 

Federal standards that DOE may adopt take effect. See 42 U.S.C. 6316(h)(2). Once 

DOE’s standards are finalized, all other State standards that are in effect would be preempted. As a result, these State standards do not pose an additionalany regulatory burden 

above that which has already been established in EPCA. 

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Food Safety Standards

Manufacturers expressed concern regarding Federal, State, and local food safety 

regulations. A walk-in must perform to the standards set by NSF, state, country, and city 

health regulations. There is general concern among manufacturers about conflicting 

regulation scenarios as new energy conservation standards may potentially prevent or 

make it more difficult for them to comply with food safety regulations. 

2.3. National Impact Analysis

a. Amount and Significance of Energy Savings

To estimate the national energy savings attributable to the TSLs under 

consideration, DOE compared the energy consumption of the refrigeration systems under 

the base case to their anticipated energy consumption under each TSL. Because all the 

TSLs except TSL 6 combine high efficiency refrigeration systems with envelope 

components having relatively smallersmall efficiency incrementsgains over the baseline 

levels, DOE projected that the additional impact from higher efficiency levels offor 

envelope components on the capacity of those refrigeration systems that are sold for each 

system, and subsequently on the aggregate shipped capacity, would not be significant. 

Because the shipped capacity of refrigeration systems is assumed to remain constant, 

significantly impact the energy savings estimate for each TSL. Consequently, DOE 

calculated the baseline energy consumption and the energy savings for thehigher 

efficiency refrigeration systems are calculated independent of the envelope component 

efficiency level at the TSLs considered. The energy savingsDOE did, however, estimate 

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this reduction in capacity from improved envelope component efficiency on an aggregate 

basis at each TSL and accounted for the envelope components are calculated such that 

botheconomic benefit in the baseline and calculation of the higher efficiency envelope 

components are paired with the refrigeration system at the efficiency level corresponding 

to the specific TSLnational net present value for each TSL as discussed in section V.3.b. 

By contrast, the energy savings benefits for the envelope components are 

influenced directly by the efficiency of the refrigeration system. Because of this, the 

energy savings for the envelope levels are calculated such that both the baseline and the 

higher efficiency envelope components are paired with the refrigeration system at the 

efficiency level corresponding to the specific TSL.

Table V-28 through Table V-30Table V-30 present DOE’s forecasts of the 

national primary energy savings for each TSL of the refrigeration systems and selected 

envelope components, and the combination of refrigeration systems and envelope 

components. In addition Table V-30 shows the FFC energy savings for each TSL. These 

forecasts were calculated using the approach described in section IV.G. Chapter 10 of the 

NOPR TSD presents tables that also show the magnitude of the energy savings

discounted at rates of seven and three percent. 

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Table V-28 WICF Refrigeration Systems: Cumulative National Energy Savings in 

Quads (Primary Energy Savings)

Equipment 

Classes

Class

Trial Standard Levels

1,43 2,34 5,6 6

DC.M.I* 0.044024 0.028041 0.048041 0.041

DC.M.O* 1.825 2.207446 1.8792.524 2.545524

DC.L.I* 0.017009 0.015016 0.020017 0.017

DC.L.O* 0.768 1.291162 1.004256 1.371256

MC.M 0.327378 0.327376 0.328378 0.378

MC.L 0.075099 0.075 0.084 0.099 0.099

*For DC refrigeration systems, results include both capacity ranges.

Table V-29 Component Product ClassesEquipment Class: Cumulative National 

Energy Savings in Quads (Primary Energy Savings)

CLXXI.Equipment 

ClassesClass

CLXXII. Trial Standard Levels

1 2 3 4 5 6

SP.M 0.000259 0.213000 0.213324 0.174221 0.169273 0.428553

SP.L 0.000447 0.431000 0.455564 0.297380 0.352447 0.488619

FP.L 0.000048 0.033000 0.059069 0.027040 0.046055 0.057069

DD.M 0.700405 0.653394 0.722405 0.633394 0.696394 0.835620

DD.L 0.055021 0.058020 0.079029 0.055020 0.054020 0.086095

PD.M 0.000009 0.008000 0.008009 0.006007 0.006007 0.060073

PD.L 0.000113 0.085000 0.102141 0.054106 0.085128 0.101140

FD.M 0.000 0.000 0.000 0.000 0.000 0.002004

FD.L 0.000010 0.006000 0.008013 0.004007 0.007012 0.008013

Table V-30 Refrigeration Systems and Components Combined: Cumulative 

National Primary and Full-Fuel Cycle Energy Savings in Quads

CLXXIII. Ap

plication

CLXXIV. Trial Standard Levels

1 2 3 4 5 6

Medium 

Temperature 3.2772.900 3.108257 3.1772.965 3.391486 3.792617 4.246193

Low Temperature 1.438515 1.707283 1.798692 1.820816 2.017032 2.214308

Primary Energy 

Savings Total 4.715415 4.815540 4.975658 5.211302 5.808649 6.460501

Upstream Energy 

Savings 0.072 0.074 0.076 0.086 0.092 0.106

FFC Total 4.487 4.614 4.734 5.388 5.741 6.607

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Circular A-4 requires agencies to present analytical results, including separate 

schedules of the monetized benefits and costs that show the type and timing of benefits 

and costs. Circular A-4 also directs agencies to consider the variability of key elements 

underlying the estimates of benefits and costs. For this rulemaking, DOE undertook a 

sensitivity analysis using nine rather than 30 years of product shipments. The choice of a 

9-year period is a proxy for the timeline in EPCA for the review of certain energy 

conservation standards and potential revision of and compliance with such revised 

standards. We would note that the review timeframe established in EPCA generally 

does not overlap with the product lifetime, product manufacturing cycles or other factors 

specific to walk-in coolers and freezers. Thus, this information is presented for 

informational purposes only and is not indicative of any change in DOE’s analytical 

methodology. The NES of estimated primary energy savings results based on a 9-year 

analytical period are presented in Table V-31 through Table V-33. The impacts are 

counted over the lifetime of products purchased in 2017–2025.

Table V-31 WICF Refrigeration Systems: Cumulative National Primary Energy 

Savings in Quads for Units Sold in 2017-2025

*For DC refrigeration systems, results include multiple capacity ranges.

Equipment 

Class

Trial Standard Levels

1,3 2,4 5 6

DC.M.I* 0.007 0.012 0.012 0.012

DC.M.O* 0.547 0.733 0.756 0.756

DC.L.I* 0.003 0.005 0.005 0.005

DC.L.O* 0.230 0.348 0.376 0.376

MC.M 0.113 0.113 0.113 0.113

MC.L 0.030 0.025 0.030 0.030
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Table V-32 Component Equipment Class: Cumulative National Primary Energy 

Savings in Quads for Units Sold in 2017-2025 (Primary Energy Savings)

Equipment Class

Trial Standard Levels

1 2 3 4 5 6

SP.M 0.063 0.000 0.079 0.054 0.066 0.134

SP.L 0.108 0.000 0.137 0.092 0.108 0.150

FP.L 0.012 0.000 0.017 0.010 0.013 0.017

DD.M 0.123 0.119 0.123 0.119 0.119 0.188

DD.L 0.006 0.006 0.009 0.006 0.006 0.029

PD.M 0.003 0.000 0.003 0.002 0.002 0.021

PD.L 0.033 0.000 0.041 0.031 0.037 0.041

FD.M 0.000 0.000 0.000 0.000 0.000 0.001

FD.L 0.002 0.000 0.003 0.002 0.003 0.003

Table V-33 Refrigeration Systems and Components Combined: Cumulative 

National Primary and Full-Fuel Cycle Energy Savings in Quads for Units Sold in 

2017-2025 

Application

Trial Standard Levels

1 2 3 4 5 6

Medium 

Temperature 0.855 0.977 0.871 1.033 1.069 1.226

Low Temperature 0.425 0.384 0.470 0.519 0.579 0.651

Primary Energy 

Savings Total 1.280 1.361 1.341 1.552 1.648 1.877

Upstream Energy 

Savings 0.021 0.022 0.022 0.025 0.027 0.031

FFC Total 1.301 1.383 1.363 1.577 1.675 1.908

a.b. Net Present Value of Consumer Costs and Benefits

DOE estimated the cumulative NPV to the nation of the total costs and savings for 

consumers that would result from particular composite standard levels for the 

refrigeration systems and componentcomponents. In accordance with OMB guidelines on 

regulatory analysis (OMB Circular A-4, section E, September 17, 2003), DOE calculated 

NPV using both a 7-percent and a 3-percent real discount rate. The 7-percent rate is an 

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estimate of the average before-tax rate of return on private capital in the U.S. economy, 

and reflects the returns on real estate and small business capital, including corporate 

capital. DOE used this discount rate to approximate the opportunity cost of capital in the 

private sector, since recent OMB analysis has found the average rate of return on capital 

to be near this rate. In addition, DOE used the 3-percent rate to capture the potential 

effects of standards on private consumption. This rate represents the rate at which 

society discounts future consumption flows to their present value. It can be approximated 

by the real rate of return on long-term government debt (i.e., yield on Treasury notes 

minus annual rate of change in the Consumer Price Index), which has averaged about 3 

percent on a pre-tax basis for the last 30 years.

Table V-3134 through Table V-36Table V-39 show the consumer NPV results for 

each of the TSLs DOE considered for the combination of refrigeration systems and 

envelope components, using both a 7-percent and a 3-percent discount rate. In each case, 

the impacts cover the lifetime of products purchased in 2015-20442017-2046. For a 

particular TSL combination, improving component efficiency should result in reduced 

refrigeration load on the paired refrigeration system and consequently, the refrigeration 

system can be downsized, resulting in additional consumer benefits. In estimating the 

“first cost benefits,” DOE made several assumptions and has shown the results only in 

the summary table. For a discussion of these assumptions, see chapter 10 of the TSD. 

 
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Table V-34 WICF Refrigeration Systems: Net Present Value in Millions (20112012$)

at a 7-percent Discount Rate for Units Sold in 2017-2046

ProductEquipment 

Classes

Trial Standard Levels

1, 43 2,34 5,6 6

DC.M.I* 7638 5352 5852 52

DC.M.O* 4,1123,417 3,816943 3,670937 3,937

DC.L.I* 3112 2719 2819 19

DC.L.O* 2,4651,488 2,1331,995 1,980913 1,913

MC.M 843835 843 836835 835

MC.L 186161 186189 158161 161

*For DC refrigeration systems, results include both capacity ranges.

Table V-35 Envelope Component Equipment Classes: Net Present Value in Millions 

(20112012$) at a 7-percent Discount Rate for Units Sold in 2017-2046

Product 

ClassesEquipment 

Class

Trial Standard Levels

1 2 3 4 5 6

SP.M 0 375 375 270 255 -16,023

SP.L 0 710 358 535 80 -3,687

FP.L 0 58 45 42 9 -513

DD.M 160 805 229 741 150 -7,121

DD.L 19 28 2 19 16 -234

PD.M 0 9 9 5 5 -1,105

PD.L 0 93 23 78 46 -146

FD.M 0 0 0 0 0 -55

FD.L 0 7 3 6 0 -26

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Table V-33 Refrigeration Systems and Components Combined: Net Present Value 

in Millions (2011$) at a 7-percent Discount Rate

Tim Trial Standard Levels

1 2 3 4 5 6

Medium

TemperatureSP.M 289 0 121 207 11 -17,715

Combined NPVSP.L 5,191662 5,9020 5,326269 6,048520 4,97321 -19,7424,298

First cost 

benefitsFP.L 1863 180 1952 4148 7122 144-578

Sub-TotalDD.M 5,209571 5,920545 5,345571 6,088545 5,044543 -

19,59811,200

Low

TemperatureDD.L 54 51 0 51 50 -395

Combined 

NPVPD.M 2,7014 3,2430 2,7784 3,3631 2,3181 -2,4401,764

First cost 

benefitsPD.L 2106 410 4638 7188 1676 228-513

Sub-TotalFD.M 2,7030 3,2840 2,8230 3,4340 2,4850 -2,212106

Total - AllFD.L 7,91210 9,2040 8,1695 9,522 7,5292 -21,81059

Table V-34 WICF Refrigeration Systems: Net Present Value in Millions (2011$) at a 

3-percent Discount Rate

Product Classes

Trial Standard Levels

1,4 2,3 5,6

DC.M.I 203 139 171

DC.M.O 10,789 9,809 10,289

DC.L.I 82 71 79

DC.L.O 6,426 5,426 5,548

MC.M 2,155 2,155 2,145

MC.L 480 480 437

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Table V-35 Envelope Component Equipment Classes: Net Present Value in Millions 

(2011$) at a 3-percent Discount Rate

Product Classes

Trial Standard Levels

1 2 3 4 5 6

SP.M 0 1,096 1,096 824 785 -30,675

SP.L 0 1,994 1,470 1,550 751 -6,402

FP.L 0 171 189 130 95 -910

DD.M 2,164 2,307 1,257 2,164 2,144 -13,285

DD.L 120 143 143 120 114 -336

PD.M 0 30 30 20 19 -2,117

PD.L 0 275 205 239 223 -135

FD.M 0 1 1 1 1 -105

FD.L 0 24 22 21 20 -35
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Table V-36 Refrigeration Systems and Components Combined: Net Present Value 

in Millions (20112012$) at a 37-percent Discount Rate for Units Sold in 2017-2046

CLXXV. A

pplication

CLXXVI. Trial Standard Levels

1 2 3 4 5 6

Medium

Temperature

Combined NPV 15,3125,155 15,5385,38

4

14,4884,98

7

16,1575,59

2

15,5535,38

0

-

33,57825,

961

First cost benefits 356 363 3818 8034 14045 285153

Sub-Total 15,3475,161 15,5755,38

6

14,5265,00

4

16,2375,62

7

15,6925,42

5

-

33,29325,

809

Low

Temperature

Combined NPV 7,1092,555 8,5842,255 8,0072,025 9,0492,919 7,2692,193

-

1,7533,75

1

First cost benefits 449 800 9189 14096 331246 451344

Sub-Total 7,1132,604 8,6642,255 8,0972,114 9,1893,015 7,5992,438

-

1,3023,40

8

Total -– All 22,4597,765 24,2397,64

1

22,6237,11

8

25,4268,64

2

23,2927,86

4

-

34,59529,

217

Table V-37 WICF Refrigeration Systems: Net Present Value in Millions (2012$) at a 

3-percent Discount Rate for Units Sold in 2017-2046

Equipment Class

Trial Standard Levels

1,3 2,4 5 6

DC.M.I* 107 159 159 159

DC.M.O* 9,161 11,047 11,147 11,147

DC.L.I* 36 61 60 60

DC.L.O* 3,951 5,483 5,455 5,455

MC.M 2,143 2,157 2,143 2,143

MC.L 450 483 450 450

*For DC refrigeration systems, results include both capacity ranges.

Table V-38 Envelope Component Equipment Classes: Net Present Value in Millions 

(2012$) at a 3-percent Discount Rate for Units Sold in 2017-2046

Equipment Class

Trial Standard Levels

1 2 3 4 5 6

SP.M 990 0 779 770 484 -32,834

SP.L 2,151 0 1,468 1,694 797 -7,144

FP.L 219 0 216 167 134 -985

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DD.M 1,667 1,602 1,667 1,602 1,597 -20,987

DD.L 135 128 41 128 126 -640

PD.M 21 0 21 13 12 -3,329

PD.L 364 0 270 319 189 -803

FD.M 1 0 1 1 1 -200

FD.L 36 0 31 32 23 -92

Table V-39 Refrigeration Systems and Components Combined: Net Present Value 

in Millions (2012$) at a 3-percent Discount Rate for Units Sold in 2017-2046

Application

Trial Standard Levels

1 2 3 4 5 6

Medium

Temperature

Combined NPV 14,091 14,965 13,880 15,748 15,543 -43,901

First cost benefits 12 5 34 66 87 294

Sub-Total 14,102 14,970 13,914 15,814 15,630 -43,607

Low

Temperature

Combined NPV 7,191 6,155 6,464 8,297 7,234 -3,700

First cost benefits 94 0 172 185 473 663

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

Total - All 21,387 21,125 20,550 24,296 23,337 -46,644

The NPV results based on the aforementioned 9-year analytical period are 

presented in Table V-40 through Table V-45. The impacts are counted over the lifetime 

of products purchased in 2017–2025. As mentioned previously, this information is 

presented for informational purposes only and is not indicative of any change in DOE’s 

analytical methodology or decision criteria.
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Table V-40 WICF Refrigeration Systems: Net Present Value in Millions (2012$) at a 

7-percent Discount Rate for Units Sold in 2017-2025

Equipment 

Classes

Trial Standard Levels

1,3 2, 4 5 6

DC.M.I* 21 30 30 30

DC.M.O* 1,864 2,175 2,178 2,178

DC.L.I* 7 11 11 11

DC.L.O* 810 1,095 1,060 1,060

MC.M 451 455 451 451

MC.L 89 102 89 89

*For DC refrigeration systems, results include both capacity ranges.

Table V-41 Envelope Component Equipment Classes: Net Present Value in Millions 

(2012$) at a 7-percent Discount Rate for Units Sold in 2017-2025

Equipment Class

Trial Standard Levels

1 2 3 4 5 6

SP.M 128 0 35 89 -17 -9,275

SP.L 306 0 92 238 -27 -2,293

FP.L 29 0 21 21 6 -307

DD.M 326 312 326 312 311 -5,473

DD.L 29 28 3 28 27 -186

PD.M 3 0 3 1 1 -870

PD.L 62 0 30 53 13 -244

FD.M 0 0 0 0 0 -53

FD.L 5 0 2 4 0 -30

Table V-42 Refrigeration Systems and Components Combined: Net Present Value 

in Millions (2012$) at a 7-percent Discount Rate for Units Sold in 2017-2025

Application

Trial Standard Levels

1 2 3 4 5 6

Medium

Temperature

Combined NPV 2,883 3,061 2,791 3,156 3,153 -12,843

First cost benefits 3 1 9 17 23 77

Sub-Total 2,886 3,062 2,800 3,174 3,176 -12,766

Low

Temperature

Combined NPV 1,322 1,125 1,045 1,479 1,416 -1,829

First cost benefits 23 0 42 33 124 174

Sub-Total 1,345 1,125 1,087 1,512 1,540 -1,655

Total - All 4,230 4,188 3,887 4,686 4,716 -14,421
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Table V-43 WICF Refrigeration Systems: Net Present Value in Millions (2012$) at a 

3-percent Discount Rate for Units Sold in 2017-2025

Equipment Class

Trial Standard Levels

1,3 2,4 5 6

DC.M.I* 42 63 63 63

DC.M.O* 3,564 4,330 4,377 4,377

DC.L.I* 14 24 24 24

DC.L.O* 1,535 2,143 2,145 2,145

MC.M 828 832 828 828

MC.L 177 187 177 177

*For DC refrigeration systems, results include both capacity ranges.

Table V-44 Envelope Component Equipment Classes: Net Present Value in Millions 

(2012$) at a 3-percent Discount Rate for Units Sold in 2017-2025

Equipment Class

Trial Standard Levels

1 2 3 4 5 6

SP.M 296 0 197 224 101 -12,538

SP.L 651 0 385 503 167 -2,879

FP.L 64 0 61 48 34 -392

DD.M 675 650 675 650 648 -7,204

DD.L 52 50 21 50 49 -203

PD.M 9 0 9 6 5 -1,161

PD.L 147 0 118 129 87 -261

FD.M 0 0 0 0 0 -71

FD.L 11 0 8 10 6 -35

Table V-45 Refrigeration Systems and Components Combined: Net Present Value 

in Millions (2012$) at a 3-percent Discount Rate for Units Sold in 2017-2025

Application

Trial Standard Levels

1 2 3 4 5 6

Medium

Temperature

Combined NPV 5,414 5,875 5,315 6,106 6,022 -15,707

First cost benefits 4 2 12 24 32 107

Sub-Total 5,418 5,877 5,328 6,130 6,054 -15,600

Low

Temperature

Combined NPV 2,624 2,403 2,319 3,092 2,688 -1,425

First cost benefits 34 0 62 67 172 240

Sub-Total 2,658 2,403 2,382 3,159 2,859 -1,185

Total - All 8,076 8,281 7,709 9,289 8,913 -16,785
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a.c. Employment Impacts 

Besides the direct impacts on manufacturing employment discussed in section 

V.B.2.b, DOE develops general estimates of the indirect employment impacts of 

proposed standards on the economy. As discussed above, DOE expects energy 

conservation standards for walk-ins to reduce energy bills for commercial consumers, and 

the resulting net savings to be redirected to other forms of economic activity. DOE also 

realizes that these shifts in spending and economic activity by WICF owners could affect 

the demand for labor. Thus, indirect employment impacts may result from expenditures 

shifting between goods (the substitution effect) and changes in income and overall 

expenditure levels (the income effect) that occur due to the imposition of standards. 

These impacts may affect a variety of businesses not directly involved in the decision to 

make, operate, or pay the utility bills for walk-ins. To estimate these indirect economic 

effects, DOE used an input/output model of the U.S. economy using U.S. Department of 

Commerce, Bureau of Economic Analysis (BEA) and Bureau of Labor Statistics (BLS) 

data (as described in section IV.J; see chapter 1413 of the TSD for more details).

In this input/output model, the dollars saved on utility bills from more efficient 

walk-in equipment are centered in economic sectors that create more jobs than are lost in 

the electric utility industry when spending is shifted from electricity to other products and 

services. Thus, the proposed walk-in energy conservation standards are likely to slightly 

increase the net demand for labor in the economy. However, the net increase in jobs 

might be offset by other, unanticipated effects on employment. Neither the BLS data nor 

the input/output model used by DOE indicates the quality of jobs lost or gained. As 

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shown in Table V-3746, DOE estimates that net indirect employment impacts from a 

proposed WICF standard are small relative to the national economy. 

Table V-46 CumulativeNet Change in Jobs from Indirect Employment Effects 

Under WICF TSLs 

CLXXVII.

ear

CLXXVIII. T

rial Standard 

Level

CLXXIX. Net National Change in Jobs (Thousands)

Envelope 

Components

Refrigeration 

Systems Total

20202017

1 0.242 74.780.5 0.7

2 0.541 53.250.7 0.8

3 0.602 49.230.5 0.7

4 0.462 74.780.7 0.9

5 0.462 81.220.8 1.0

6 0.463 81.220.8 1.1

20452021

1 20.230.8 81.502.5 3.4

2 9.110.3 117.653.4 3.7

3 22.381.0 77.642.5 3.5

4 16.990.8 117.653.4 4.2

5 16.990.9 127.633.6 4.4

6 16.991.4 127.633.6 5.0

1.4. Impact on Utility or Performance of Equipment 

In performing the engineering analysis, DOE generally considers design options 

that would not lessen the utility or performance of the individual classes of equipment. 

See 42 U.S.C. 6295(o)(2)(B)(i)(IV). As presented in the screening analysis (chapter 4 of 

the TSD), DOE eliminates design options that reduce the utility of the equipment from 

consideration. For this notice, DOE tentatively concludes that none of the efficiency 

levels proposed for walk-in cooler and freezer equipment would be likely to reduce the 

utility or performance of the equipment. 

2.5. Impact of Any Lessening of Competition 

DOE has also considered any lessening of competition that is likely to result from 

amended standards. The Attorney General determines the impact, if any, of any lessening 

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of competition likely to result from a proposed standard, and transmits such 

determination to the Secretary, together with an analysis of the nature and extent of such 

impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (ii))

To assist the Attorney General in making such determination, DOE will provide 

DOJ with copies of this NOPR and the TSD for review. DOE will consider DOJ’s 

comments on the proposed rule in preparing the final rule, and DOE will publish and 

respond to DOJ’s comments in that document. 

 DOE also notes that during MIA interviews, domestic manufacturers indicated 

that foreign manufacturers do not generally enter the walk-in market and have not done 

so for the past several years; however, some walk-in equipment may be manufactured in 

Mexico or Canada. Manufacturers also stated that consolidation has occurred among 

walk-in manufacturers in recent years, due largely to the competitive nature of the 

industry and the recently enacted standards established by Congress. DOE believes that 

these trends will continue in this market regardless of the proposed standard levels 

chosen, but could accelerate if higher standard levels are set. 

DOE does not believe that the proposed standards would result in domestic firms 

moving their production facilities outside the United States. The vast majority of walk-ins 

sold in the United States are manufactured in the United States, in large part because 

walk-in equipment is generally bulky and therefore, making it difficult and expensive to 

ship internationally. Manufacturers generally indicated during interviews that they would 
350 

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modify their existing facilities to comply with the amended energy conservation 

standards that DOE develops. 

3.6. Need of the Nation to Conserve Energy

An improvement in the energy efficiency of the products subject to today’s 

NOPRrule is likely to improve the security of the nation’s energy system by reducing 

overall demand for energy. Reduced electricity demand may also improve the reliability 

of the electricity system. As a measure of this reduced demand, Table V-38 presents the 

estimated reductionReductions in national electric generating capacity in 2043estimated

for the TSLs that DOEeach considered in this rulemakingTSL are reported in chapter 14 

of the TSD. 

Table V-38 Reduction in Electric Generating Capacity in 2043 by TSL

Trial Standard Level Capacity Reduction (GWh)

1 3.3

2 3.3

3 3.4

4 3.6

5 3.9

6 4.3

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Energy savings from newamended standards for WICFsWICF equipment classes covered in 

today’s NOPR could also produce environmental benefits in the form of reduced emissions of air 

pollutants and greenhouse gases associated with electricity production. Table V-3947 provides 

DOE’s estimate of cumulative CO2, NOX, and Hg emissions reductions projected to result from 

the TSLs considered in this rule.rulemaking. The table includes both power sector emissions and 

upstream emissions. The upstream emissions were calculated using the multipliers discussed in 

section IV.G. DOE reports annual CO2, NOX, and Hg emissions reductions for each TSL in the 

environmental assessment in chapter 15 of the NOPR TSD.

Table V-39 Summary of Emissions Reduction Estimated for WICF TSLs 

(cumulative for 2015 through 2044)

Trial Standard 

Level

Cumulative Reduction in Emissions 

(2015 through 2044)

CO2

MMt

NOX

kt

Hg

T

1 109.1 73.4 1.8

2 109.1 73.4 1.8

3 112.8 75.9 1.9

4 120.4 81.0 2.0

5 128.6 86.5 2.1

6 143.5 96.6 2.4

IV.L,IV.J, DOE did not report sulfur dioxide (SO2) 

emissions reductions from power plants because there is uncertainty about the effect of 

energy conservation standards on the overall level of SO2 emissions in the United States 

due to SO2 emissions caps. DOE also did not include NOX emissions reduction from 

power plants in States subject to CAIR, because an energy conservation standard would 

not affect the overall level of NOX emissions in those States due to the emissions caps 

mandated by CAIR.48CSAPR.

 

48 DOE notes that EPA issued the Cross-State Air Pollution Rule (CSPAR) on July 6, 2011, which was 

published in the Federal Register in early August 2011. See 76 FR 48208 (Aug. 8, 2011). The CSPAR 

replaces the CAIR ruled. DOE will consider any changes to its analysis resulting from promulgation of the 

CSPAR. 

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Table V-47 Cumulative Emissions Reduction for WICF TSLs for Equipment 

Purchased in 2017-2046 

TSL

1 2 3 4 5 6

Power Sector and Site Emissions*

 CO2 (million metric tons) 234.32 240.95 246.75 281.35 299.79 345.05

 NOX (thousand tons) 178.96 183.22 188.62 214.60 228.76 263.66

 Hg (tons) 0.52 0.53 0.54 0.62 0.66 0.76

 N2O (thousand tons) 5.22 5.33 5.51 6.26 6.67 7.70

 CH4 (thousand tons) 29.18 29.98 30.74 35.03 37.33 42.98

 SO2 (thousand tons) 313.03 322.01 329.61 375.89 400.52 460.93

Upstream Emissions

 CO2 (million metric tons) 13.87 14.27 14.61 16.66 17.75 20.43

 NOX (thousand tons) 190.90 196.36 201.02 229.24 244.26 281.10

 Hg (tons) 0.01 0.01 0.01 0.01 0.01 0.01

 N2O (thousand tons) 0.14 0.14 0.15 0.17 0.18 0.21

 CH4 (thousand tons) 1,159.66 1,192.72 1,221.16 1,392.52 1,483.77 1,707.59

 SO2 (thousand tons) 2.97 3.06 3.13 3.57 3.80 4.38

Total Emissions

 CO2 (million metric tons) 248.19 255.22 261.36 298.01 317.54 365.48

 NOX (thousand tons) 369.85 379.58 389.64 443.84 473.02 544.76

 Hg (tons) 0.52 0.54 0.55 0.63 0.67 0.77

 N2O (thousand tons) 5.36 5.48 5.65 6.43 6.85 7.90

 CH4 (thousand tons) 1,188.84 1,222.70 1,251.90 1,427.56 1,521.10 1,750.57

 SO2 (thousand tons) 316.00 325.06 332.74 379.46 404.32 465.31

As part of the analysis for this NOPR, DOE estimated monetary benefits likely to 

result from the reduced emissions of CO2 and NOX that DOE estimated for each of the 

TSLs considered. As discussed in section IV.M.1, DOE used values for the SCC 

developed by an interagency process. The interagency group selected four sets of SCC 

values for CO2 emissions reductions resulting from that process (expresseduse in 

2007$)regulatory analyses. Three sets are $4.7/ton (based on the average value from a 

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distribution that uses a 5-percentSCC from three integrated assessment models, at

discount rate), $21.4/ton (the average value from a distribution that uses a 3-percent 

discount rate), $35.1/ton (the average value from a distribution that uses arates of 2.5-

percent, 3 percent, and 5 percent discount rate), and $64.9/ton (. The fourth set, which 

represents the 95th-percentile value from a distribution that usesSCC estimate across all 

three models at a 3-percent discount rate). These values correspond, is included to the 

value of emission reductionsrepresent higher-than-expected impacts from temperature 

change further out in 2010; thethe tails of the SCC distribution. The four values for CO2

emissions reductions in 2015, expressed in 2012$, are $12.9/ton, $40.8/ton, $62.2/ton, 

and $117.0/ton. The values for later years are higher due to increasing damages as the 

magnitude of climate change increases. For each TSL, DOE calculated

Table V-48 presents the global present valuesvalue of CO2 emissions reductions, 

using the same discount rate as was used in the studies upon which the dollar-per-ton 

values are based. at each TSL. DOE calculated domestic values as a range from 7 

percent to 23 percent of the global values., and these results are presented in chapter 16 of 

the NOPR TSD.

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Table V-48 Cumulative Emissions Reduction for WICF TSLs (2017 through 2073) 

TSL

SCC Case*

5% 

discount 

rate, 

average*

3% 

discount 

rate, 

average*

2.5% 

discount 

rate, 

average*

3% 

discount 

rate, 95th

percentile*

Million 2012$

Primary Energy Emissions

1 1,477.1 7,031.6 11,276.4 21,608.4

2 1,532.4 7,269.9 11,648.3 22,334.5

3 1,552.5 7,396.3 11,863.3 22,730.2

4 1,777.9 8,455.6 13,556.7 25,982.3

5 1,892.8 9,004.8 14,438.5 27,670.6

6 2,173.0 10,348.6 16,597.3 31,802.7

Upstream Emissions

1 86.8 415.1 665.9 1,277.0

2 90.0 429.1 687.8 1,319.6

3 91.2 436.7 700.6 1,343.3

4 104.4 499.1 800.6 1,535.4

5 111.2 531.6 852.7 1,635.2

6 127.7 610.9 980.2 1,879.4

Total Emissions

1 1,563.8 7,446.7 11,942.3 22,885.4

2 1,622.4 7,698.9 12,336.1 23,654.1

3 1,643.7 7,832.9 12,563.9 24,073.6

4 1,882.4 8,954.8 14,357.3 27,517.7

5 2,003.9 9,536.4 15,291.2 29,305.8

6 2,300.7 10,959.5 17,577.5 33,682.1

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

$117.0 per metric ton (2012$).

DOE is well aware that scientific and economic knowledge about the contribution 

of CO2 and other GHG emissions to changes in the future global climate and the potential 

resulting damages to the world economy continues to evolve rapidly. Thus, any value 

placed in this NOPR on reducing CO2 emissions is subject to change. DOE, together with 

other Federal agencies, will continue to review various methodologies for estimating the 

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monetary value of reductions in CO2 and other GHG emissions. This ongoing review will 

consider the comments on this subject that are part of the public record for this NOPR 

and other rulemakings, as well as other methodological assumptions and issues. 

However, consistent with DOE’s legal obligations, and taking into account the 

uncertainty involved with this particular issue, DOE has included in this NOPR the most 

recent values and analyses resulting from the ongoing interagency review process.

DOE also estimated a range for the cumulative monetary value of the economic 

benefits associated with NOX and Hg emissions reductions anticipated to result from 

amended ballast standards. Estimated monetary benefits for CO2, NOX and Hg emission 

reductions are detailed in chapter 16 of the NOPR TSDTable V-49 presents the present 

value of cumulative NOX emissions reductions for each TSL calculated using the average 

dollar-per-ton values at 7-percent and 3-percent discount rates. Formatted: Font color: Auto
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Table V-49 Cumulative Present Value of NOX Emissions Reduction for WICF TSLs 

(2017 through 2073) 

TSL 3% discount rate 7% discount rate

Million 2012$

Power Sector Emissions

1 219.7 96.3

2 227.7 101.0

3 231.0 100.9

4 264.4 116.2

5 281.5 123.6

6 323.3 141.4

Upstream Emissions

1 240.1 105.4

2 249.4 110.5

3 252.3 110.5

4 289.1 127.2

5 307.7 135.3

6 353.1 154.8

Total Emissions

1 459.8 201.6

2 477.1 211.4

3 483.3 211.4

4 553.5 243.5

5 589.2 258.9

6 676.5 296.3

Note: Present value of NOX emissions calculated with at $2,639 per ton.

The NPV of the monetized benefits associated with emissions reductions can 

be viewed as a complement to the NPV of the consumer savings calculated for each TSL 

considered in this NOPR. Table V-40 shows an example of the calculation of the 

combined NPV including benefits from emissions reductions for the case of TSL 4 for 

walk-ins. The CO2 values used in the table correspond to the four scenarios for the 

valuation of CO2 emission reductions presented in section IV.M.1.

Table V-50 presents the NPV values that result from adding the estimates of the 

potential economic benefits resulting from reduced CO2 and NOX emissions in each of 

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four valuation scenarios to the NPV of consumer savings calculated for each TSL 

considered in this rulemaking, at both a 7-percent and a 3-percent discount rate. The CO2

values used in the columns of each table correspond to the four scenarios for the 

valuation of CO2 emission reductions discussed above.
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Table V-50 Adding WICF TSLs: Net Present Value of Consumer Savings 

toCombined with Net Present Value of Monetized Benefits from CO2 and NOX

Emissions Reductions at TSL 4 for WICF

CategoryTSL

Presen

t Value

million 

2010$

Consumer NPV at 3% Discount Rate added with:

Benefits

Operating Cost Savings 14,092 7%

35,372 3%

CO2 Reduction 

Monetized Value (at 

$4.7/Metric Ton)*SCC 

Value of $12.9/metric 

ton CO2

* and Low 

Value for NOX

**

470SCC Value of 

$40.8/metric ton CO2

*

and Medium Value for 

NOX

**

5%SCC Value of $62.2/metric ton CO2

* and 

Medium Value for NOX

**

SCC Value of $117.0/metric 

CO2

* and High Value for NO

billion 2012$

1 23.03 29.29 33.79 45.11

2 22.83 29.30 33.94 45.65

3 22.28 28.87 33.60 45.50

CO2 Reduction 

Monetized Value (at 

$21.4/Metric Ton)*4

2,31226.28 3%33.80 39.21 52.82

5 25.45 33.46 39.22 53.72

6 -44.22

CO2 Reduction 

Monetized Value (at 

$35.1/Metric Ton)*-

35.01

3,880-28.39 2.5%-11.73

TSL

CO2 Reduction Monetized Value (at $64.9/Metric Ton)*Consumer NPV at 7% Discount Rate added 

with:

7,058 3

NOX Reduction 

Monetized Value (at 

$2,543/Ton)*SCC 

Value of $12.9/metric 

ton CO2

* and Low 

Value for NOX

**

45SCC Value of 

$40.8/metric ton CO2

*

and Medium Value for 

NOX

**

7%SCC Value of $62.2/metric ton CO2

* and 

Medium Value for NOX

**

SCC Value of $117.0/metric 

CO2

* and High Value for NO

103billion 2012$ 3

1 9.36 15.41 19.91 31.02

2 9.30 15.55 20.19 31.68

Total Monetary Benefits 

**3 8.80 15.16,570 7%19.89 31.58

4 10.57 17.84 23.24 36,981.60 3

Costs

Total Incremental Installed Costs 4,691 7%

5 9,140.91 3%17.66 23.41 37.64

Net Benefits/Costs

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Including CO2 and 

NOX**6 -26.86 -17.96 -11,879.34 7%5.01

27,841 3%

* These values represent global values (in 2007$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.7, $21.4, and $35.1 per ton are the averages of SCC distributions calculated 

using 5 percent, 3 percent, and 2.5 percent discount rates, respectively. The value of $64.9 per ton 

represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. See section 

IV.M.1 for details. For NOx an average value ($2,543) of the low ($451) and high ($4,635) values was 

used.

** Total Monetary Benefits for both the 3 percent and 7 percent cases utilize the central estimate of social 

cost of NOx and CO2 emissions calculated at a 3-percent discount rate (averaged across three IAMs), which 

is equal to $21.4/ton in 2010 (in 2007$).

Note: Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 

per ton of NOX emissions. High Value corresponds to $4,809 per ton of NOX emissions.

* These label values represent the global SCC in 2015, in 2012$. The present values have been calculated 

with scenario-consistent discount rates.

Although adding the value of consumer savings to the values of emission 

reductions provides a valuable perspective, the following should be considered: (1) the 

national consumer savings are domestic U.S. consumer monetary savings found in 

market transactions, while the values of emissions reductions are based on estimates of 

marginal social costs, which, in the case of CO2, are based on a global value; and (2) the 

assessments of consumer savings and emission-related benefits are performed with 

different computer models, leading to different timeframes for analysis. For walk-ins, the 

present value of national consumer savings is measured for the period in which units 

shipped (2015–20442017–2046) continue to operate. However, the time frames of the 

benefits associated with the emission reductions differ. For example, the value of CO2 

emissions reductions reflects the present value of all future climate-related impacts due to 

emitting a ton of CO2 in that year, out to 2300.

Chapter 15 of the NOPR TSD presents calculations of the combined NPV,

including benefits from emissions reductions for each TSL. 

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4.7. Other Factors

Consistent with EPCA, DOE examined whether other factors might be relevant in 

determining whether the proposed standards are economically justified. See generally 42 

U.S.C. 6295(o)(2)(B)(i)(VII). DOE identified none other than those discussed above.

DOE prepared a regulatory impact analysis (RIA) for this rulemaking, which is 

contained in the TSD. The RIA is subject to review by the Office of Information and 

Regulatory Affairs (OIRA) in the OMB. The RIA consists of (1) a statement of the 

problem addressed by this regulation and the mandate for Government action, (2) a 

description and analysis of policy alternatives to this regulation, (3) a 

qualitativequantitative review of the potential impacts of the alternatives, and (4) the 

national economic impacts of the proposed standard.

The RIA assesses the effects of feasible policy alternatives to walk-in equipment 

standards and provides a comparison of the impacts of the alternatives. DOE evaluated 

the alternatives in terms of their ability to achieve significant energy savings at 

reasonable cost, and compared them to the effectiveness of the proposed rule. DOE 

analyzed these alternatives qualitatively with reference to the particular market dynamics 

of the WICF industry.

DOE identified the following major policy alternatives for achieving increased 

WICF efficiency:

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• No new regulatory action

• Commercial consumer tax credits

• Commercial consumer rebates

• Voluntary energy efficiency targets

• Bulk government purchases

• Early replacement

DOE qualitatively evaluated each alternative’s ability to achieve significant 

energy savings at reasonable cost and compared it to the effectiveness of the proposed 

rule. DOE assumed that each alternative policy would induce commercial consumers to 

voluntarily purchase at least some higher efficient at any of the trial standard levels 

(TSLs). In contrast to a standard at one of the TSLs, the adoption rate of the alternative 

non-regulatory policy cases may not be 100 percent, which would result in lower energy 

savings than a standard. The following paragraphs discuss each policy alternative. (See 

chapter 17 of the TSD, Regulatory Impact Analysis, for further details.) 

No new regulatory action. The case in which no regulatory action is taken for 

WICF equipment constitutes the base case (or no action) scenario. By definition, no new 

regulatory action yields zero energy savings and a net present value of zero dollars. 

Commercial consumer tax credits. Consumer tax credits are considered a viable 

non-regulatory market transformation program. From a consumer perspective, the most 

important difference between rebate and tax credit programs is that a rebate can be 

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obtained quickly, whereas receipt of tax credits is delayed until income taxes are filed or 

a tax refund is provided by the Internal Revenue Service (IRS). From a societal 

perspective, tax credits (like rebates) do not change the installed cost of the equipment, 

but rather transfer a portion of the cost from the consumer to taxpayers as a whole. DOE, 

therefore, assumed that equipment costs in the consumer tax credits scenario were 

identical to the NIA base case.

Commercial consumer rebates:. Consumer rebates cover a portion of the 

difference in incremental product price between products meeting baseline 

efficacyefficiency levels and those meeting higher efficacyefficiency levels, resulting in a 

higher percentage of consumers purchasing more efficaciousefficient models and 

decreased aggregated energy use compared to the base case. Although a rebate program 

would reduce the total installed cost to the consumer, it is financed by tax revenues. 

Therefore, from a societal perspective, the installed cost at any efficiency level does not 

change with the rebate program; rather, part of the cost is transferred from the consumer 

to taxpayers as a whole. Consequently, DOE assumed that equipment costs in the rebates 

scenario were identical to the NIA base case. 

Voluntary energy efficiency targets:. While it is possible that voluntary programs 

for equipment would be effective, DOE lacks a quantitative basis to determine how 

effective such a program might be. As noted previously, broader economic and social 

considerations are in play than simple economic return to the equipment purchaser. DOE 

Comment [A30]: Edits made per OIRA.
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lacks the data necessary to quantitatively project the degree to which such voluntary 

programs for more expensive, higher efficiency equipment would modify the market.

Bulk Government purchases and early replacement incentive programs:. DOE 

also considered, but did not analyze, the potential of bulk Government purchases and 

early replacement incentive programs as alternatives to the proposed standards. Bulk 

purchases would have very limited impact on improving the overall market efficiency of

WICF equipment because they are a negligible part of the total. In the case of 

replacement incentives, several policy options exist to promote early replacement, 

including a direct national program of consumer incentives, incentives paid to utilities to 

promote an early replacement program, market promotions through equipment 

manufacturers, and replacement of government-owned equipment. In considering early 

replacements, DOE estimates that the energy savings realized through a one-time early 

replacement of existing stock equipment does not result in energy savings commensurate 

to the cost to administer the program. Consequently, DOE did not analyze this option in 

detail.

B.C. Proposed Standard 

DOE notes that the “When considering proposed standards it develops , the new 

or amended energy conservation standard that DOE adopts for any type (or class) of 

walk-in this rulemaking mustcoolers and freezers shall be designed to achieve the 

maximum improvement in energy efficiency that the Secretary of Energy determines is 

technologically feasible and economically justified. (42 U.S.C. 6313(f)(4)(A)) In 

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determining whether a standard is economically justified, the Secretary determinesmust 

determine whether the benefits of the standard exceed its burdens to the greatest extent 

practicable, in light ofconsidering the seven statutory factors discussed previously. (See 

generally (42 U.S.C. 6295(o)(2)(B)(i). DOE also will not adopt ) and 6316(a)) The new 

or amended standard unless it resultsmust also “result in significant conservation of 

energy. See generally .” (42 U.S.C. 6295(o)(3)(B). ) and 6316(a))

DOE considered the impacts of standards at each TSL, beginning with the 

maximum technologically feasible level, to determine whether that level met the 

evaluation criteria. If the max tech level was not justified, DOE then considered the next 

most efficient level and undertook the same evaluation until it reached the highest 

efficiency level that is both technologically feasible and economically justified and saves 

a significant amount of energy.

DOE discusses the benefits and/or burdens of each TSL in the remainder of this 

section. DOE bases its discussion of each TSL on quantitative analytical results such as 

national energy savings, net present value (discounted at 73 and 37 percent), emissions 

reductions, industry net present value, life-cycle cost, and consumers’ installed price 

increases. Beyond the quantitative results, DOE also considers other burdens and benefits 

that affect economic justification, including how technological feasibility, manufacturer 

costs, and impacts on competition may affect the economic results presented.
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DOE has included a table below that presents a summary of the results of DOE’s 

quantitative analysis for each TSL. In addition to the quantitative results presented in the 

tables, DOE also considers other burdens and benefits that affect economic justification. 

Section V.B presents the estimated impacts of each TSL on commercial customers and 

manufacturers, and subgroups thereof, as well as the Nation.
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Table V-51 Summary of Results for WICF Refrigeration Systems and Envelope 

Components , TSLs 1-6

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National Full-Fuel Cycle Energy Savings (quads) *

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4

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1

NPV of Consumer Benefits (20102012$ billion)

3% discount rate

2

2

.

5

2

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4

2

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Industry Impacts

Change in Industry NPV (20102012$ million)

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CLXXX. Category

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396

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412024121142211452434825954296

LCC Savings (2010$) ***2012$) **

Refrigeration Systems

DC.M.I***

864280945611945280864611505611505611

DC.M.O***

2,0751,048

1,9545771,954117

2,0751,509

1,7536081,753608

DC.L.I***

1,4205059971,117

997505

1,4201177311,0807311,080

DC.L.O***

2,3401,3281,8332,001

1,8333282,3400011,7859941,785994

MC.M.N

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CLXXX. Category

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545455

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1,759849

1,7592,061

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1,5488491,548849

Envelope Components

SP.M

016110

11-9

78

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CLXXX. Category

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†

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CLXXX. Category

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3.5.1N/A.36.0.65.98.07.148.7

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CLXXX. Category

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.926.5521.7

Distribution of Consumer LCC Impacts

All Medium and Low Temperature Refrigeration Systems

Net Cost (%) 0 0 0 0

8181

No Impact (%)000000

Net Benefit (%)

10

0 

10010

0 

100

92999299

All Medium and Low Temperature Panels

Net Cost (%)

011250

397631285693

100

No Impact (%)

10000100

0 000

Net Benefit (%)

089760

61246972

457

0

All Medium and Low Temperature Display Doors

Net Cost (%)

850440834460860100

No Impact (%)000000

Net Benefit (%)

1510056100

1796

5410014100

0

All Medium and Low Temperature Passage Doors

Net Cost (%)

023390

4839

45

6367

100

No Impact (%)

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0

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CLXXX. Category

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4

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All Medium and Low Temperature Freight Doors

Net Cost (%)

0

1

6

6

2

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2

3

9

6

9

2

8

7

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5

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Generation Capacity Reduction GW) ††

3

.

3

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Employment Impacts

Indirect Domestic Jobs (thousands) ††

1

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*** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions.

***** For LCCs, DOE did not consider variability of input parameters and used fixed input values. For the 

panels the unit of analysis is 100 ft2, for other items it is a single unit of a refrigeration system or a door.

***For DC refrigeration systems, results include both capacity ranges.

† For PBPs, DOE did not consider variability of input parameters and used fixed input values.

@ CO2eq is the quantity of CO2 that would have the same global warming potential (GWP) †† Changes in 2045.

DOE also notes that the economics literature provides a wide-ranging discussion 

of how consumers trade off upfront costs and energy savings in the absence of 

government intervention. Much of this literature attempts to explain why consumers 

appear to undervalue energy efficiency improvements. This undervaluation suggests that 

regulation that promotes energy efficiency can produce significant net private gains (as 

well as producing social gains by, for example, reducing pollution). There is evidence 

that consumers undervalue future energy savings as a result of (1) a lack of information, 

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+ 6", Left + 6.5", Left + 7", Left + 7.5",

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(2) a lack of sufficient salience of the long-term or aggregate benefits, (3) a lack of 

sufficient savings to warrant delaying or altering purchases (e.g., an inefficient ventilation 

fan in a new building or the delayed replacement of a water pump),accelerating or 

altering investments in energy saving equipment. (4) excessive focus on the short term, in 

the form of inconsistent weighting of future energy cost savings relative to available 

returns on other investments; (5) computational or other difficulties associated with the 

evaluation of relevant tradeoffs; and (6) a divergence in incentives (e.g., renter versus 

building owner; builder versus home buyer). Other literature indicates that with less than 

perfect foresight and a high degree of uncertainty about the future, it may be rational for 

consumers mayto trade off these types of investments at a higher than expected rate 

between current consumption and uncertain future energy cost savings. Some studies 

suggest that this seeming undervaluation may be explained in certain circumstances by 

differences between tested and actual energy savings, or by uncertainty and irreversibility 

of energy investments. There may also be “hidden” welfare losses to customers if newer 

energy efficient equipment is an imperfect substitute for the less efficient equipment it 

replaces. In the abstract, it may be difficult to say how a welfare gain from correcting 

potential under-investment in energy conservation compares in magnitude to the potential 

welfare losses associated with no longer purchasing equipment or switching to an 

imperfect substitute, both of which still exist in this framework.

While DOE is not prepared at present to provide a fullerfully quantifiable 

framework for estimating the benefits and costs of changes in consumer purchase 

decisions due to an energy conservation standard, DOE has posted a paper that discusses 

Comment [A31]: Edits made per OIRA.

Comment [A32]: Revisions made per OIRA.

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the issue of consumer welfare impacts of appliance energy efficiency standards, and 

potential enhancements to the methodology by which these impacts are defined and 

estimated in the regulatory process.49 DOE is committed to developing a framework that 

can support empirical quantitative tools for improved assessment of the consumer welfare 

impacts of appliance standards. DOE welcomes comments on how to more fully assess 

the potential impact of energy conservation standards on consumer choice and how to 

quantify this impact in its regulatory analysis in future rulemakings. In particular, DOE 

requests comment on whether there are features or attributes of the more energy efficient 

walk-in coolers and walk-in freezers that manufacturers would produce to meet the 

standards in this proposed rule that might affect the welfare, positively or negatively, of 

consumers who purchase WICFs.

First, DOE considered TSL 6, the max tech level for WICF refrigeration systems 

and the covered envelope components combined together. TSL 6 would save an 

estimated 6.4661 quads of primary energy through 20442073, an amount DOE considers 

significant. For the Nation as a whole, DOE projects that TSL 6 would have a negative 

NPV for consumers, i.e., result in increased costs of $21.829.2 billion, using a discount 

rate of 7 percent. The emissions reductions at TSL 6 are 143365.5 MMt of CO2, up to 

96.6545 kt of NOx, 465 kt of SO2, and up to 2.40.8 tons of Hg. These reductions have a 

value of upare valued from $2.41 to $8.433.68 billion for CO2 and $54. For NOx the 

emissions reductions are valued at $296 million for NOx at a discount rate of 7 percent. 

 

49 Alan Sanstad, Notes on the Economics of Household Energy Consumption and Technology Choice. 

Lawrence Berkeley National Laboratory. 2010.

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

Comment [A33]: Revisions made per OIRA.

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20131002_OIRA compare document dated 9-26.docx

DOE also estimates that at TSL 6, total electric generating capacity in 2044 will decrease 

compared to the base case by 4.3 GW.

 

At TSL 6, DOE projects that consumers of WICF envelope components will 

experience an increase in LCC, ranging from $273665 (low temperature passage door) to 

$2,001650 (medium temperature display door) compared to the baseline. For 

refrigeration systems, however, DOE estimates that consumers would experience a 

decrease in LCC ranging from $505611 to $1,785994. 

At TSL 6, manufacturers expect diminished profitability due to large increases in 

product costs, capital investments in equipment and tooling, and expenditures related to 

engineering and testing. The projected change in INPV ranges from a decrease of 

$792657 million to an increase of $690924 million based on DOE’s manufacturer markup scenarios. The upper bound of $690924 million is considered an optimistic scenario 

by manufacturers because it assumes manufacturers can fully pass on substantial 

increases in product costs. DOE recognizes the risk of large negative impacts on industry 

if manufacturers’ expectations concerning reduced profit margins are realized. TSL 6 

could reduce the walk-in refrigeration, panel, and door INPV by up to 9477 percent, if the 

most negative impacts reach the high end of the rangeare realized. 

 

After carefully considering the analysis and weighing the benefits and burdens of 

TSL 6, DOE finds that the benefits to the Nation of TSL 6 (i.e., energy savings and 

emissions reductions (including environmental and monetary benefits)) are small 
379 

20131002_OIRA compare document dated 9-26.docx

compared to the burdens (i.e., a decrease of $21.829.2 billion in NPV and a decrease of 

9477 percent in INPV). Because the burdens of TSL 6 far outweigh the benefits, TSL 6 is 

not economically justified. Therefore, DOE is not proposing to adopt TSL 6.

 

DOE then considered TSL 5, which combines refrigeration systems and envelope 

components at the highest efficiency level for each that would generate positive NPV to 

the Nation. TSL 5 would likely save an estimated 5.8174 quads of energy through 

20442073, an amount DOE considers significant. For the Nation as a whole, DOE 

projects that TSL 5 would result in a net increase of $7.59 billion in NPV, using a 

discount rate of 7 percent. The estimated emissions reductions at TSL 5 are 128.6317.5

MMt of CO2, up to 86.5473 kt of NOx, 404 kt of SO2, and up to 2.140.7 tons of Hg. These 

reductions have a value of upare valued from $2.00 to $7.5429.31 billion for CO2 and 

$48. For NOx the emissions reductions are valued at $259 million for NOx, at a discount 

rate of 7 percent. Total electric generating capacity in 2042 is estimated to decrease 

compared to the base case by 3.9 GW under TSL 5. 

At TSL 5, DOE projects that the customers of WICF equipment will experience a 

decreasean increase in LCC for most equipment classes of the envelope components 

compared to the baseline except for the medium temperature structural panels, and low 

temperature passage and freight doors and either unchanged or decreased LCC for

display doors and medium temperature passage and freight doors. For the refrigeration 

systems which are at the highest efficiency levels for TSL 5, DOE estimates that the 

consumers would experience a decrease in LCC ranging from $505611 to $1,785994. 
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At TSL 5, the projected change in INPV ranges from a decrease of $152134

million to an increasea decrease of $10919 million. At TSL 5, DOE recognizes the risk of 

negative impacts if manufacturers’ expectations concerning reduced profit margins are 

realized. If the highnegative end of the range of impacts is reached as DOE expects, TSL 

5 could result in a net loss of 1816 percent in INPV to the walk-in refrigeration, 

panel,cooler and door manufacturers. At this level, panel manufacturers would 

experience particularly severe impacts. The projected INPV impacts for panel 

manufacturers range from a decline of 89 percent to decline of 58 percent. freezer 

industry. Additionally, DOE is concerned about TSL 5 causing disproportionate burdens 

on small business panel manufacturers are projected to see a sharp drop, as explained in 

free cash flow at this level. the Regulatory Flexibility analysis in section VI.B.4. 

After carefully considering the analysis and weighing the benefits and burdens of 

TSL 5, DOE finds that the benefits to the Nation at TSL 5 (i.e., energy savings and 

emissions reductions (including environmental and monetary benefits)) are too low 

compared to the burdens (i.e., a decrease of 8916 percent in INPV for the walk-in cooler 

and freezer industry with disproportionate impacts on the panel industry). Because the 

burdens of TSL 5 outweigh the benefits, TSL 5 is not economically justified. Therefore, 

DOE is not proposing TSL 5. 

 

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Next, DOE considered TSL 4, which combines the refrigeration systems at the 

maximum NPV level with the envelope components also at the maximum NPV level. 

TSL 4 would likely save an estimated 5.2139 quads of energy through 20442073, an 

amount DOE considers significant. For the Nation as a whole, DOE projects that TSL 54

would result in a net increase of $9.58.6 billion in NPV, using a discount rate of 7 

percent. The estimated emissions reductions at TSL 4 are 120.4298 MMt of CO2, up to 

81.0444 kt of NOx, 379.5 kt of SO2, and up to 2.0.6 tons of Hg. These reductions have a 

value of upare valued from $1.88 to $7.0627.52 billion for CO2 and $45. For NOx the 

emissions savings are valued at $243 million for NOx at a discount rate of 7 percent. 

Total electric generating capacity in 2042 is estimated to decrease compared to the base 

case by 3.6 GW under TSL 4.

At TSL 4, DOE projects that consumers of WICF equipment will experience 

positive a decrease of LCC savings for all the refrigeration equipment classes and all but 

two of the envelope equipment classes.. At TSL 4, the projected change in INPV ranges 

from a decrease of $8377 million to an increase of $550.01 million. At TSL 4, DOE 

recognizes the risk of negative impacts if manufacturers’ expectations concerning 

reduced profit margins are realized. If the highnegative end of the range of impacts is 

reached as DOE expects, TSL 4 could result in a net loss of 109 percent inof INPV to 

walk-in manufacturers. Panel manufacturers experience much less severe impacts at TSL 

4 as compared to TSL 5. The projected change in INPV for panel manufacturers ranges 

from a drop of 33 percent to a drop of 21 percent.

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After carefully considering the analysis and weighing the benefits and burdens of 

TSL 4, DOE tentatively believes that setting levels for both the refrigeration system and 

envelope components asat TSL 4 does, represents the maximum improvement in energy 

efficiency that isDOE’s analysis projects to be technologically feasible and economically 

justified. TSL 4 is technologically feasible because the technologies required to achieve 

these levels are already in existence. TSL 4 is economically justified because the benefits 

to the Nation (i.e., increased energy savings of 5.2139 quads, emissions reductions 

including environmental and monetary benefits of, for example, 120.4298 MMt of carbon 

dioxide emissions reduction with an associated value of up to $7.0627.52 billion at a 

discount rate of 73 percent, and an increase of $9.58.6 billion in NPV) outweigh the costs 

(i.e., a decrease of 109 percent in INPV). There is also the added benefit in terms of a 

reduction in total electrical generating capacity in 2044 by 3.6 GW compared to the base 

case under the TSL 4 scenario.

Therefore, DOE has tentatively decided to propose the adoption of energy 

conservation standards at TSL 4 for WICF refrigeration systems and the considered 

envelope components. DOE specifically seeks comment on the magnitude of the 

estimated decline in INPV at TSL 4 compared to the baseline and whether or not this 

impact could risk industry consolidation. DOE also specifically requests comment on 

whether DOE should adopt TSL 5, and, in particular, whether, compared to TSL 4, TSL 

5’s higher incremental energy savings outweigh its lower NPV benefits (by $2.0 billion) 

and its incrementally higher manufacturer impacts (INPV reduction is potentially 8 

percent greater). DOE may re-examine this level depending on the nature of the 

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information it receives during the comment period and make adjustments to its final 

levels in response to that information.

CLXXXVII.VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 

FR 51735 (Oct. 4, 1993), requires each agency to identify the problem that it intends to 

address, including, where applicable, the failures of private markets or public institutions 

that warrant new agency action, as well as to assess the significance of that problem. The 

problems that today’s standards address are as follows: 

(1) There is a lack of consumer information and/or information processing capability about 

energy efficiency opportunities in the walk-in cooler and freezer market.

(2) There is asymmetric information (one party to a transaction has more and better 

information than the other) and/or high transactions costs (costs of gathering information 

and effecting exchanges of goods and services).

(3) There are external benefits resulting from improved energy efficiency of walk-in coolers 

and freezers that are not captured by the users of such equipment. These benefits include 

externalities related to environmental protection and energy security that are not reflected 

in energy prices, such as reduced emissions of greenhouse gases.

 

 In addition, DOE has determined that today’s regulatory action is an

“economically significant regulatory action” under section 3(f)(1) of Executive Order 

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Comment [A34]: Edits made per OIRA. 

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12866. Accordingly, section 6(a)(3) of the Executive Order requires that DOE prepare a 

regulatory impact analysis (RIA) on today’s rule and that the Office of Information and 

Regulatory Affairs (OIRA) in the Office of Management and Budget (OMB) review this 

rule. DOE presented to OIRA for review the draftproposed rule and other documents 

prepared for this rulemaking, including the RIA, and has included these documents in the 

rulemaking record. The assessments prepared pursuant to Executive Order 12866 can be 

found in the technical support document for this rulemaking. They are available for 

public review in the Resource Room of DOE’s Building Technologies Program, 950 

L’Enfant Plaza, SW., Suite 600, Washington, DC 20024, (202) 586-2945, between 9:00 

a.m. and 4:00 p.m., Monday through Friday, except Federal holidays.

DOE has also reviewed this proposed regulation pursuant to Executive Order 

13563, issued on January 18, 2011 (76 FR 3281, Jan. 21, 2011). EO 13563 is 

supplemental to and explicitly reaffirms the principles, structures, and definitions 

governing regulatory review established in Executive Order 12866. To the extent 

permitted by law, agencies are required by Executive Order 13563 to: (1) propose or 

adopt a regulation only upon a reasoned determination that its benefits justify its costs 

(recognizing that some benefits and costs are difficult to quantify); (2) tailor regulations 

to impose the least burden on society, consistent with obtaining regulatory objectives, 

taking into account, among other things, and to the extent practicable, the costs of 

cumulative regulations; (3) select, in choosing among alternative regulatory approaches, 

those approaches that maximize net benefits (including potential economic, 

environmental, public health and safety, and other advantages; distributive impacts; and 
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equity); (4) to the extent feasible, specify performance objectives, rather than specifying 

the behavior or manner of compliance that regulated entities must adopt; and (5) identify 

and assess available alternatives to direct regulation, including providing economic 

incentives to encourage the desired behavior, such as user fees or marketable permits, or 

providing information upon which choices can be made by the public. 

DOE emphasizes as well that Executive Order 13563 requires agencies to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, the Office of Information and Regulatory Affairs 

has emphasized that such techniques may include identifying changing future compliance 

costs that might result from technological innovation or anticipated behavioral changes. 

For the reasons stated in the preamble, DOE believes that today’s NOPR is consistent 

with these principles, including the requirement that, to the extent permitted by law, 

benefits justify costs and that net benefits are maximized. 

DOE emphasizes that Executive Order 13563 calls for “periodic review of 

existing significant regulations,” with close reference to empirical evidence. Moreover, 

with respect to energy conservation standards, EPCA mandates that DOE review its 

regulations not later than 6 years after issuance of any final rule establishing or amending 

an energy efficiency standard. As part of the retrospective review, DOE will review its 

data on walk-in prices and costs and, as part of that review, will consider tracking 

additional data on walk-in prices and costs for the equipment classes identified in the rule 

as a means of comparing actual walk-in prices and costs to prices and costs forecasted as 

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Tab stops: 0.39", Left + 0.78", Left + 1.17",

Left + 1.56", Left + 1.94", Left + 2.33", Left

+ 2.72", Left + 3.11", Left + 3.5", Left + 

3.89", Left + 4.28", Left + 4.67", Left
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a result of the standards imposed by today’s and any future rule. Such a review will likely 

be a part of the periodic review of energy efficiency standards for walk-in called for 

under Executive Order 13563. DOE’s plan for conducting periodic review, which will be 

updated regularly, should be consulted for further information. See:

http://energy.gov/gc/report-appliance-regulation-violation/ex-partecommunications/restrospective-regulatory-review

For the reasons stated in the preamble, DOE believes that today’s proposed rule is 

consistent with these principles, including that, to the extent permitted by law, agencies 

adopt a regulation only upon a reasoned determination that its benefits justify its costs 

and select, in choosing among alternative regulatory approaches, those approaches that 

maximize net benefits.

B. Review Under the Regulatory Flexibility Act

 The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an 

initial regulatory flexibility analysis (IRFA) for any rule that by law must be proposed for 

public comment, unless the agency certifies that the rule, if promulgated, will not have a 

significant economic impact on a substantial number of small entities. As required by 

Executive Order 13272, “Proper Consideration of Small Entities in Agency Rulemaking,” 

67 FR 53461 (August. 16, 2002), DOE published procedures and policies on February 

19, 2003 to ensure that the potential impacts of its rules on small entities are properly 

considered during the rulemaking process. 68 FR 7990. DOE has made its procedures 

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and policies available on the Office of the General Counsel’s website 

(www.gc.doe.govhttp://energy.gov/gc/office-general-counsel ).

For manufacturers of walk-in coolers and freezers, the Small Business 

Administration (SBA) has set a size threshold, which defines those entities classified as 

“small businesses” for the purposes of the statute. DOE used the SBA’s small business 

size standards to determine whether any small entities would be subject to the 

requirements of the rule. 65 FR 30836, 30848 (May 15, 2000), as amended at 65 FR 

53533, 53544 (Sept. 5, 2000) and codified at 13 CFR part 121.The size standards are 

listed by North American Industry Classification System (NAICS) code and industry 

description and are available at 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf . 

Walk-in cooler and freezer manufacturing is classified under NAICS 333415, “AirConditioning and Warm Air Heating Equipment and Commercial and Industrial 

Refrigeration Equipment Manufacturing.” The SBA sets a threshold of 750 employees or 

fewer for an entity to be considered as a small business for this category.

DOE reviewed the energy conservation standards considered in today’s notice of 

proposed rulemaking under the provisions of the Regulatory Flexibility Act and the 

procedures and policies published on February 19, 2003. To better assess the potential 

impacts of this rulemaking on small entities, DOE conducted a more focused inquiry of 

the companies that could be small business manufacturers of equipment covered by this 

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rulemaking. DOE used all available public information to identify potential small 

manufacturers. DOE’s research involved industry trade association membership 

directories (including AHRI and NAFEM), the NSF Section 7 certification database, 

individual company websites, and marketing research tools (e.g., Hoovers reports) to 

create a list of companies that manufacture or sell walk-in cooler or freezer panels, doors, 

and refrigeration systems covered by this rulemaking. DOE also asked stakeholders and 

industry representatives if they were aware of any other small manufacturers during 

manufacturer interviews and at previous DOE public meetings. DOE reviewed all 

publicly available data and contacted select companies on its list, as necessary, to 

determine whether they met the SBA’s definition of a small business manufacturer of 

WICF equipment. DOE screened out companies that did not offer equipment covered by 

this rulemaking, did not meet the definition of a ‘‘small business,’’ or are foreign-owned 

and operated. DOE looked at each type of covered equipment (i.e., panels, doors, and 

refrigeration systems) separately for purposes of determining whether certification was 

appropriate or an initial regulatory flexibility analysis was needed.

DOE identified 52 panel manufacturers in the WICF industry. Based on publicly 

available information, 42 of the identified panel manufacturers are believed to be small 

businesses. The Department notes that there may be more than the 52 panel 

manufacturers identified as part of its review. As part of the MIA interviews, the 

Department interviewed nine panel manufacturers, including three small business 

operations. During MIA interviews, multiple manufacturers claimed that there are 

“hundreds of two-man garage-based operations” that produce WICF panels in small 
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quantities. They asserted that these small manufacturers do not typically comply with 

EISA 2007 standards and do not obtain UL or NSF certifications for their equipment. 

DOE was not able to identify these small businesses and did not consider them in its 

analysis. Based on the large number of small panel manufacturers and the potential scope 

of the impact, DOE could not certify that the proposed standards would not have a 

significant impact on a significant number of small businesses with respect to the panel 

industry.

DOE identified 59 walk-in door manufacturers, 55 of which produce solid doors. 

The remaining four produce display doors. However, 52 of the 55 solid door 

manufacturers produce panels as their primary business and are considered in the 

category of panel manufacturers above. The remaining three solid door manufacturers are 

all considered to be small businesses. Two of the display door manufacturers are 

considered small businesses. Therefore, of the seven manufacturers that exclusively 

produce WICF doors, DOE determined that five are small businesses. As part of the MIA 

interviews, the Department interviewed six door manufacturers, including four small 

business operations. Based on the large proportion of small door manufacturers in the 

door market, DOE could not certify that the proposed standards would not have a 

significant impact on a significant number of small businesses with respect to the door 

industry.

DOE identified nine refrigeration system manufacturers in the WICF industry. 

Based on publicly available information, two of the manufacturers are small businesses. 

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One small business focuses on large warehouse refrigeration systems, which are outside 

the scope of this rulemaking. However, at its smallest capacity, this company’s units are 

sold to the walk-in market. The other small business specializes in building evaporators 

and unit coolers for a range of refrigeration applications, including the walk-in market. 

As part of the MIA interviews, the Department interviewed five refrigeration 

manufacturers, including the two small business operations. Both small businesses 

expressed concern that the rulemaking would negatively impact their businesses and one 

small business indicated it would exit the walk-in industry as a result of any standard that 

would directly impact walk-in refrigeration system energy efficiency. However, due to 

the small number of small businesses that manufacture WICF refrigeration systems and 

the fact that only one of them focuses on WICF refrigeration as a key market segment

and constitutes a very small share of the overall walk-in market, DOE certifies that the 

proposed standards would not have a significant impact on a significant number of small 

businesses with respect to the refrigeration equipment industry.

As a result of this analysis, DOE determined that it could not certify that the 

proposed rule, if promulgated, would not have a significant effect on a substantial 

number of small entities that manufacture WICF panels and doors. Therefore, DOE has 

prepared an IRFA (sections VI.B.1 through VI.B.6 below) for this rulemaking. The IRFA 

describes potential impacts on small businesses associated with walk-in cooler and 

freezer energy conservation standards.

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DOE will transmit a copy of this IRFA to the Chief Counsel for Advocacy of the 

Small Business Administration for review.

1. 

1. Reasons for the Proposed Rule

Title III of the Energy Policy and Conservation Act of 1975, as amended, (EPCA 

or the Act) sets forth a variety of provisions designed to improve energy efficiency. Part 

B of Title III (42 U.S.C. 6291–6309) provides for the Energy Conservation Program for 

Consumer Products Other Than Automobiles. The National Energy Conservation Policy 

Act (NECPA), Public Law 95–619, amended EPCA to add Part C of Title III, which 

established an energy conservation program for certain industrial equipment. (42 U.S.C.

6311– 6317) (For purposes of codification in Title 42 of the U.S. Code, these parts were 

subsequently redesignated as Parts A and A–1, respectively, for editorial reasons.) 

Section 312 of the Energy Independence and Security Act of 2007 (EISA 2007) further 

amended EPCA by adding certain equipment to this energy conservation program, 

including walk-in coolers and walk-in freezers (collectively ‘‘walk-in equipment’’ or 

‘‘walk-ins’’), which are the subject of this rulemaking. (42 U.S.C. 6311(1), (20), 6313(f) 

and 6314(a)(9)) The proposed rule would establish energy conservation standards for 

walk-in coolers and walk-in freezers.

2. 2. Objectives of, and Legal Basis for, the Proposed Rule

EPCA provides that DOE must publish performance-based standards for walk-in

coolers and walk-in freezers that achieve the maximum improvement in energy that is 

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technologically feasible and economically justified. (42 U.S.C. 6313(f)(4)(A)) However, 

in general, DOE may not adopt any standard that would not result in the significant

conservation of energy. (42 U.S.C. 6295(o)(3)) (Regarding provisions contained only in 

the consumer products section of the U.S. Code, DOE is proposing to apply those 

provisions to walk-in coolers and walk-in freezers in the same manner.) Moreover, DOE 

may not prescribe a standard: (1) for certain products, including walk-in coolers and 

freezers, if no test procedure has been established for the product; or (2) if DOE 

determines by rule that the proposed standard is not technologically feasible or 

economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed 

standard is economically justified, DOE must determine whether the benefits of the 

standard exceed its burdens after receiving comments on the proposed standard. (42 

U.S.C. 6295(o)(2)(B)(i)) To determine whether economic justification exists, DOE 

reviews comments received and conducts analysis to determine whether DOE must make 

this determination, and by considering, to the greatest extent practicable, the seven 

factors set forth in 42 U.S.C.6295(o)(2)(B) (see section II of this preamble). 

EPCA also states that the Secretary may not prescribe a standard if interested 

persons have established by a preponderance of the evidence that the standard is likely to 

result in the unavailability in the United States of any covered product type (or class) of 

performance characteristics (including reliability), features, sizes, capacities, and volumes 

that are substantially the same as those generally available in the United States. (42 

U.S.C. 6295(o)(4)) Further information concerning the background of this rulemaking is 

provided in chapter 1 of the TSD.
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3. Description and Estimated Number of Small Entities Regulated

DOE used all available public information and information from confidential 

interviews to identify potential small manufacturers. DOE’s research involved industry 

trade association membership directories (including AHRI and NAFEM), the NSF 

Section 7 certification database, individual company websites, and marketing research 

tools (e.g., Dun and Bradstreet reports) to create a list of every companycompanies that 

manufacturesmanufacture or sellssell walk-in cooler or freezer panels, doors, and 

refrigeration systems covered by this rulemaking. DOE also asked stakeholders and 

industry representatives if they were aware of any other small manufacturers during 

manufacturer interviews and at previous DOE public meetings. DOE reviewed allthe

publicly available data and contacted select companies on its list, as necessary, to 

determine whether they met the SBA’s definition of a small business manufacturer of 

WICF equipment. DOE screened out companies that did not offer products covered by 

this rulemaking, did not meet the definition of a ‘‘small business,’’ or are foreign owned 

and operated. Based on this analysis, DOE estimates that there are 42 small 

manufacturers of WICF panels, 5 small manufacturers of WICF doors that do not also 

manufacture panels, and 3 small manufacturers of WICF refrigeration. See chapter 12 of 

the TSD for further discussion about the methodology used in DOE’s manufacturer 

impact analysis and its analysis of small business impacts.

Based on this information, DOE identified 52 panel manufacturers and found 42 

of the identified panel manufacturers to be small businesses. As part of the MIA 
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interviews, the Department interviewed nine panel manufacturers, including three small 

business operations. During MIA interviews, multiple manufacturers claimed that there 

are “hundreds of two-man garage-based operations” that produce WICF panels in small 

quantities. They asserted that these small manufacturers do not typically comply with 

EISA 2007 standards and do not obtain UL or NSF certifications for their equipment. 

DOE was not able to identify these small businesses and did not consider them in its 

analysis. Based on the purported number of small panel manufacturers and the potential 

scope of the impact (as described in section VI.B.4 below), DOE could not certify that 

the proposed standards would not have a significant impact on a substantial number of 

small businesses with respect to the panel industry.

DOE identified 59 walk-in door manufacturers. Fifty-five of those produce solid 

doors and four produce display doors. Of the fifty-five solid door manufacturers, fiftytwo produce panels as their primary business and are considered in the category of panel 

manufacturers above. The remaining three solid door manufacturers are all considered to 

be small businesses. Of the four display door manufacturers, two are considered small 

businesses. Therefore, of the seven manufacturers that exclusively produce WICF doors 

(three producing solid doors and four producing display doors), DOE determined that 

five are small businesses. As part of the MIA interviews, the Department interviewed six 

door manufacturers, including four small business operations. Based on the large 

proportion of small door manufacturers in the door market and the potential scope of the 

impact (as described in section VI.B.4 below), DOE could not certify that the proposed 
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standards would not have a significant impact on a large number of small businesses with 

respect to the door industry.

DOE identified nine refrigeration system manufacturers in the WICF industry. 

Based on publicly available information, two of the manufacturers are small businesses. 

One small business focuses on large warehouse refrigeration systems, which are outside 

the scope of this rulemaking. However, at its smallest capacity, this company’s units can 

be sold to the walk-in market. The other small business specializes in building 

evaporators and unit coolers for a range of refrigeration applications, including the walkin market. As part of the MIA interviews, the Department interviewed five refrigeration 

manufacturers, including the two small business operations. Both small businesses 

expressed concern that the rulemaking would negatively impact their businesses and one 

small business indicated it would exit the walk-in industry as a result of any standard that 

would directly impact walk-in refrigeration system energy efficiency. However, due to 

the small number of small businesses that manufacture WICF refrigeration systems and 

the fact that only one of two focuses on WICF refrigeration as a key market segment and 

constitutes a very small share of the overall walk-in market, DOE certifies that the 

proposed standards would not have a significant impact on a substantial number of small 

businesses with respect to the refrigeration equipment industry.

4. Description and Estimate of Compliance Requirements

The potential impacts on manufacturers, including small businesses, come from 

impacts associated with walk-in cooler and freezer equipment design and manufacture. 

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The margins or market share of small businesses in the WICF industry could be 

negatively impacted in the long term by the standard levels under consideration in this 

NOPR. 

The level of R&DGiven the significant role of small businesses in the 

walk-in panel and walk-in door industries, DOE provides a detailed analysis of the 

impacts of the proposed standard on these industries below.

Panels

In the walk-in industry, panel manufacturers typically use the same production 

lines to manufacture all three equipment classes (SP.M, SP.L, and FP.L). The equipment 

class with the most stringent standard drives conversion costs. The design options 

considered include reducing heat loss through the panel frame (typically by using high 

density polyurethane framing materials or by moving to a frameless design), increasing 

the thickness of panels, and incorporating vacuum-insulated technology. 

Small manufacturers tend to be at a disadvantage when adapting to a new 

standard requiring fixed cost investments. Small manufacturers may have greater 

difficulty obtaining credit or may obtain less favorable terms than larger competitors 

when capital expenditures are necessary to meet the standard. Additionally, product 

testing required to meet costs stemming from the energy conservation standards increases 

with the stringency of the standards. Product redesign costsstandard tend to be fixed and 

do not scale with sales volume. Thus, small panel and door manufacturersAs a result, 
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these product conversion costs would be at a relative disadvantage at higher TSLs 

because R&D effortsthe same in absolute terms for small and large panel manufacturers. 

The small businesses would have to recoup these over smaller sales volumes, leading to 

higher per unit costs and potentially putting them at a pricing disadvantage. The projected 

conversion cost impacts on panel manufacturers are shown in Table VI-1 and Table VI-2

below.

Table VI-1 Impacts of Conversion Costs on a Small Panel Manufacturer

Capital Conversion 

Cost as a Percentage of 

Annual Capital 

Expenditures

Product Conversion 

Cost as a Percentage of 

Annual R&D Expense

Total Conversion 

Cost as a 

Percentage of 

Annual Revenue

Total Conversion Cost 

as a Percentage of 

Annual Operating 

Income

TSL 1 565% 122% 9% 242%

TSL 2 0% 0% 0% 0%

TSL 3 1695% 230% 26% 669%

TSL 4 565% 122% 9% 242%

TSL 5 1695% 230% 26% 669%

TSL 6 5461% 995% 87% 2262%

Table VI-2 Impacts of Conversion Costs on a Large Panel Manufacturer

Capital Conversion 

Cost as a Percentage of 

Annual Capital 

Expenditures

Product Conversion 

Cost as a Percentage of 

Annual R&D Expense

Total Conversion 

Cost as a 

Percentage of 

Annual Revenue

Total Conversion Cost 

as a Percentage of 

Annual Operating 

Income

TSL 1 22% 5% 0% 9%

TSL 2 0% 0% 0% 0%

TSL 3 66% 9% 1% 26%

TSL 4 22% 5% 0% 9%

TSL 5 66% 9% 1% 26%

TSL 6 213% 39% 3% 88%

At the proposed standard (TSL 4), the engineering analysis suggests that 

manufacturers would shift to high density rails for all products to achieve the minimum 

U-factors. The capital conversion costs would be on the same scale as those for larger 
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companies, but these expenses565% of the typical annual capital expenditures for a small 

manufacturer while only 22% of the typical annual capital expenditures for a large 

manufacturer. The product conversion costs would be recouped over smaller sales 

volumes. Additionally, higher efficiency designs tend to require more materials, such as 

sheet metal and foaming agents. Small manufacturers 122% of the typical small 

manufacturer’s annual R&D budget and only 5% of the typical large manufacturer’s 

annual R&D budget.

In addition to these conversion cost impacts, small manufacturers typically have a 

significant price disadvantage for raw materials and basic components due to their small 

purchasing quantities when compared to large manufacturers. , such as foaming agents. 

Any standard that requires small manufacturers to use more insulation or more expensive 

components will exacerbate the pricing gap. Finally, as the standard level increases, 

additional production tooling will be needed in the door and panel industries. However, 

small manufacturers may have greater difficulty obtaining credit or may obtain less 

favorable terms than larger competitors when financial capital expenditures are necessary 

to meet the standard and growth their business. DOE anticipates that small manufacturers 

are likely to experience more difficulty funding the changes necessary to meet the 

proposed energy conservation standards than largeradd a different foam formulation for 

high density rails will accentuate the difference in material costs for large manufacturers 

versus small manufacturers. 

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Based on the large number of small panel manufacturers and the potential scope 

of the impact (as described in section VI.B.2 below), DOE could not certify that the 

proposed standards would not have a significant impact on a substantial number of small 

businesses with respect to the panel industry.

Doors However, as discussed under subsection 6 (Significant alternatives to the rule), 

DOE expects that the differential impact on small WICF equipment manufacturers 

(versus large businesses) would be smaller in moving to proposed TSL 4 than it would be 

in moving from proposed TSL 4 to higher TSLs. The rationale for DOE’s expectation is 

best discussed in a comparative context and is therefore elaborated upon in subsection 66 

(Significant alternatives to the rule). 

For the walk-in door industry, DOE identified seven small manufacturers that 

produce doors as their primary product, as described in section VI.B.4. Three companies 

produce solid doors and four companies produce display doors. 

In the solid door market, all three manufacturers of customized passage doors and 

freight doors are small. The potential impacts on these three manufacturers are illustrated 

in Table VI-3. 

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Table VI-3 Impacts of Conversion Costs on a Small Solid Door Manufacturer

Capital Conversion 

Cost as a Percentage of 

Annual Capital 

Expenditures

Product Conversion 

Cost as a Percentage of 

Annual R&D Expense

Total Conversion 

Cost as a 

Percentage of 

Annual Revenue

Total Conversion Cost 

as a Percentage of 

Annual Operating 

Income

TSL 1 52% 47% 2% 25%

TSL 2 0% 0% 0% 0%

TSL 3 626% 47% 5% 63%

TSL 4 157% 47% 2% 25%

TSL 5 626% 47% 5% 63%

TSL 6 4086% 142% 27% 369%

At the proposed standard (TSL 4), the engineering analysis suggests that 

manufacturers would shift to high density frames to achieve the minimum energy 

consumption for all solid doors. Additionally, for low-temperature passage doors,

manufacturers would need to incorporate enhanced windows to reduce heat transmission; 

manufacturers of low-temperature freight doors would need to add controls to minimize 

anti-sweat heater energy usage. The capital conversion costs would be 157% of the 

typical annual capital expenditures for a small manufacturer and the product conversion 

costs would be 47% of the typical manufacturer’s annual R&D budget. 

 

In the display door market, two of the four manufacturers are small. If conversion 

costs for display door manufacturers were large, the small manufacturers could be at a 

disadvantage due to the fixed investments necessary for capital conversion and product 

conversion costs. However, as illustrated in Table VI-4, conversion costs for display door 

manufacturers are negligible for most TSLs. This is because the considered design 

options primarily consist of component swaps and component additions. To make these 

design changes, no costly equipment or tooling is necessary. As a result, the conversion 
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costs do not cause small businesses to be at a significant disadvantage relative to larger 

businesses when adapting to the proposed standard.

Table VI-4 Impacts of Conversion Costs on a Small Display Door Manufacturer

Capital Conversion 

Cost as a Percentage of 

Annual Capital 

Expenditures

Product Conversion 

Cost as a Percentage of 

Annual R&D Expense

Total Conversion 

Cost as a 

Percentage of 

Annual Revenue

Total Conversion Cost 

as a Percentage of 

Annual Operating 

Income

TSL 1 0% 2% 0% 0%

TSL 2 0% 2% 0% 0%

TSL 3 0% 2% 0% 0%

TSL 4 0% 2% 0% 0%

TSL 5 0% 2% 0% 0%

TSL 6 501% 19% 3% 20%

Table VI-5 Impacts of Conversion Costs on a Large Display Door Manufacturer

Capital Conversion 

Cost as a Percentage of 

Annual Capital 

Expenditures

Product Conversion 

Cost as a Percentage of 

Annual R&D Expense

Total Conversion 

Cost as a 

Percentage of 

Annual Revenue

Total Conversion Cost 

as a Percentage of 

Annual Operating 

Income

TSL 1 0% 0% 0% 0%

TSL 2 0% 0% 0% 0%

TSL 3 0% 0% 0% 0%

TSL 4 0% 0% 0% 0%

TSL 5 0% 0% 0% 0%

TSL 6 88% 3% 0% 4%

At the proposed standard (TSL 4), the engineering analysis suggests that 

manufacturers would need to purchase more efficient components, such as LED lights,

and incorporate anti-sweat heater controllers. There are no anticipated capital conversion 

costs, and product conversion costs appear to be manageable for both small and large 

businesses door manufacturers. 

Based on the number of small door manufacturers and the potential scope of the 

impact on solid door manufacturers, DOE could not certify that the proposed standards 
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would not have a significant impact on a significant number of small businesses with 

respect to the walk-in door industry.

5. Duplication, Overlap, and Conflict with Other Rules and Regulations

DOE is not aware of any rules or regulations that duplicate, overlap, or conflict 

with the rule being considered today. 

6. Significant Alternatives to the Proposed Rule

The primary alternatives to the proposed rule considered by DOE are the other 

TSLs besides the one being considered today, proposed TSL 4. DOE explicitly 

considered the role of small businesses in its selection of TSL 4 rather than TSL 5. 

Though TSL 5 results in greater energy savings for the country, the standard would place 

excessive burdens on manufacturers, including small manufacturers, of walk-in 

refrigeration, panels, and doors. In particular, DOE considered the drastic reduction in 

INPV and increase in conversion costs and potential negative impacts on small 

businesses that occurred between TSL 4 and TSL 5 for the solid door and panel 

industryindustries, which hashave a significant number of small businesses. As another 

alternative to the proposed standard, DOE also considered lower TSLs; in particular, TSL 

21, which does not set standards for panels and non-display doors. Chapter 12 of the TSD 

contains additional information about the impact of this rulemaking on manufacturers.

In addition to the other TSLs considered, alternatives to the proposed rule include 

the following policy alternatives: (1) no new regulatory action, (2) commercial consumer

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rebates, and (3) commercial consumer tax credits. Chapter 17 of the TSD associated with 

this proposed rule includes a report referred to in Section VI.A in the preamble as the 

regulatory impact analysis (RIA). The energy savings of these regulatory alternatives are 

one to two orders of magnitude smaller than those expected from the standard levels 

under consideration. The range of economic impacts of these regulatory alternatives is an 

order of magnitude smaller than the range of impacts expected from the standard levels 

under consideration. 

C. Review Under the Paperwork Reduction Act

There is currently no information collection requirement related to the test 

procedure for walk-in coolers and walk-in freezers. In the event that DOE proposes an 

energy conservation standard with which manufacturers must demonstrate compliance, or 

otherwise proposes to require the collection of information derived from the testing of 

walk-in coolers and walk-in freezers according to this test procedure, DOE will seek 

OMB approval of such information collection requirement.

Manufacturers of covered equipmentwalk-in coolers and freezers must certify to 

DOE that their equipment compliesproducts comply with any applicable energy 

conservation standard developed by DOE.standards. In certifying compliance, 

manufacturers must test their equipmentproducts according to the applicable DOE test 

procedureprocedures for walk-in coolers and freezers, including any amendments 

adopted for thatthose test procedure. 
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procedures. DOE has established regulations for the certification and 

recordkeeping requirements for certainall covered consumer products and commercial 

equipment, including walk-in coolers and freezers. 76 FR 12422 (March 7, 2011). The 

collection-of-information requirement for the certification and recordkeeping wasis

subject to review and approval by OMB under the Paperwork Reduction Act (PRA). This 

requirement washas been approved by OMB under OMB Control Numbercontrol number

1910-1400. The publicPublic reporting burden for the certification wasis estimated to 

average 20 hours per response, including the time for reviewing instructions, searching 

existing data sources, gathering and maintaining the data needed, and completing and 

reviewing the collection of information.

 As previously stated, in the event DOE proposes an energy conservation standard 

for walk-in coolers and walk-in freezers with which manufacturers must demonstrate 

compliance, DOE will seek OMB approval of the associated information collection 

requirement. DOE will seek approval either through a proposed amendment to the 

information collection requirement approved under OMB control number 1910-1400 or 

as a separate proposed information collection requirement. 

 

Notwithstanding any other provision of the law, no person is required to respond 

to, nor shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the PRA, unless that collection of information 

displays a currently valid OMB Control Number.

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D. Review Under the National Environmental Policy Act of 1969 

DOE has prepared a draft environmental assessment (EA) of the impacts of the 

proposed rule pursuant to the National Environmental Policy Act of 1969 (42 U.S.C. 

4321 et seq.), the regulations of the Council on Environmental Quality (40 CFR parts 

1500–1508), and DOE’s regulations for compliance with the National Environmental 

Policy Act of 1969 (10 CFR part 1021). This assessment includes an examination of the 

potential effects of emission reductions likely to result from the rule in the context of 

global climate change, as well as other types of environmental impacts. The draft EA has 

been incorporated into the NOPR TSD as chapter 15. Before issuing a final rule for walkin coolers and freezers, DOE will consider public comments and, as appropriate, 

determine whether to issue a finding of no significant impact (FONSI) as part of a final 

EA or to prepare an environmental impact statement (EIS) for this rulemaking.

E. Review Under Executive Order 13132

Executive Order 13132, “Federalism” 64 FR 43255 (Aug. 10, 1999)), imposes 

certain requirements on Federal agencies formulating and implementing policies or 

regulations that preempt State law or that have Federalism implications. The Executive 

Order requires agencies to examine the constitutional and statutory authority supporting 

any action that would limit the policymaking discretion of the States and to carefully 

assess the necessity for such actions. The Executive Order also requires agencies to have 

an accountable process to ensure meaningful and timely input by State and local officials 

in the development of regulatory policies that have Federalism implications. On March 

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14, 2000, DOE published a statement of policy describing the intergovernmental 

consultation process it will follow in the development of such regulations. 65 FR 13735. 

EPCA governs and prescribes Federal preemption of State regulations as to energy 

conservation for the products that are the subject of today’s proposed rule. See 42 U.S.C. 

6316(h)(1)(A)(2), 42 U.S.C. 6316(h)(2)(B), and 42 U.S.C. 6316(h)(3). No further action 

is required by Executive Order 13132.

F. Review Under Executive Order 12988

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, “Civil Justice Reform,” imposes on 

Federal agencies the general duty to adhere to the following requirements: (1) eliminate 

drafting errors and ambiguity; (2) write regulations to minimize litigation; and (3) 

provide a clear legal standard for affected conduct rather than a general standard and 

promote simplification and burden reduction. 61 FR 4729 (Feb. 7, 1996). Section 3(b) of 

Executive Order 12988 specifically requires that Executive agencies make every 

reasonable effort to ensure that the regulation: (1) clearly specifies the preemptive effect, 

if any; (2) clearly specifies any effect on existing Federal law or regulation; (3) provides 

a clear legal standard for affected conduct while promoting simplification and burden 

reduction; (4) specifies the retroactive effect, if any; (5) adequately defines key terms; 

and (6) addresses other important issues affecting clarity and general draftsmanship under 

any guidelines issued by the Attorney General. Section 3(c) of Executive Order 12988 

requires Executive agencies to review regulations in light of applicable standards in 

section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to 

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meet one or more of them. DOE has completed the required review and determined that, 

to the extent permitted by law, this proposed rule meets the relevant standards of 

Executive Order 12988.

G. Review Under the Unfunded Mandates Reform Act of 1995

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each 

Federal agency to assess the effects of Federal regulatory actions on State, local, and 

Tribal governments and the private sector. Pub. L. 104-4, sec. 201 (codified at 2 U.S.C. 

1531). For a proposed regulatory action likely to result in a rule that may cause the 

expenditure by State, local, and Tribal governments, in the aggregate, or by the private 

sector of $100 million or more in any one year (adjusted annually for inflation), section 

202 of UMRA requires a Federal agency to publish a written statement that estimates the 

resulting costs, benefits, and other effects on the national economy. (2 U.S.C. 1532(a), 

(b)) The UMRA also requires a Federal agency to develop an effective process to permit 

timely input by elected officers of State, local, and Tribal governments on a proposed 

“significant intergovernmental mandate,” and requires an agency plan for giving notice 

and opportunity for timely input to potentially affected small governments before 

establishing any requirements that might significantly or uniquely affect small 

governments. On March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR 12820. DOE’s policy statement is 

also available at www.gc.doe.govhttp://energy.gov/gc/office-general-counsel. 

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Although today’s proposed rule does not contain a Federal intergovernmental 

mandate, it may require expenditures of $100 million or more on the private sector. 

Specifically, the proposed rule will likely result in a final rule that could require 

expenditures of $100 million or more. Such expenditures may include: (1) investment in 

research and development and in capital expenditures by walk-in cooler and freezer 

manufacturers in the years between the final rule and the compliance date for the new 

standards, and (2) incremental additional expenditures by customers to purchase higherefficiency walk-in coolers and freezers, starting at the compliance date for the applicable 

standard. 

Section 202 of UMRA authorizes a Federal agency to respond to the content 

requirements of UMRA in any other statement or analysis that accompanies the proposed 

rule. 2 U.S.C. 1532(c). The content requirements of section 202(b) of UMRA relevant to 

a private sector mandate substantially overlap the economic analysis requirements that 

apply under section 325(o) of EPCA and Executive Order 12866. The 

SUPPLEMENTARY INFORMATION section of the NOPR and the “Regulatory Impact 

Analysis” section of the TSD for this proposed rule respond to those requirements. 

Under section 205 of UMRA, the Department is obligated to identify and consider 

a reasonable number of regulatory alternatives before promulgating a rule for which a 

written statement under section 202 is required. 2 U.S.C. 1535(a). DOE is required to 

select from those alternatives the most cost-effective and least burdensome alternative 

that achieves the objectives of the proposed rule unless DOE publishes an explanation for 

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doing otherwise, or the selection of such an alternative is inconsistent with law. As 

required by 42 U.S.C. 6313(f)(4)(A), today’s proposed rule would establish energy 

conservation standards for walk-in coolers and walk-in freezers that are designed to 

achieve the maximum improvement in energy efficiency that DOE has determined to be 

both technologically feasible and economically justified. A full discussion of the 

alternatives considered by DOE is presented in the “Regulatory Impact Analysis” section 

of the TSD for today’s proposed rule.

H. Review Under the Treasury and General Government Appropriations Act, 1999

 Section 654 of the Treasury and General Government Appropriations Act, 1999 

(Pub. L. 105-277) requires Federal agencies to issue a Family Policymaking Assessment 

for any rule that may affect family well-being. This rule would not have any impact on 

the autonomy or integrity of the family as an institution. Accordingly, DOE has 

concluded that it is not necessary to prepare a Family Policymaking Assessment.

I. Review Under Executive Order 126

 DOE has determined, under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights” 53 FR 8859 (Mar. 18, 

1988), that this regulation would not result in any takings that might require 

compensation under the Fifth Amendment to the U.S. Constitution.

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J. Review Under the Treasury and General Government Appropriations Act, 2001

 Section 515 of the Treasury and General Government Appropriations Act, 2001 

(44 U.S.C. 3516, note) provides for Federal agencies to review most disseminations of 

information to the public under guidelines established by each agency pursuant to general 

guidelines issued by OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 

2002), and DOE’s guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has 

reviewed today’s NOPR under the OMB and DOE guidelines and has concluded that it is 

consistent with applicable policies in those guidelines.

K. Review Under Executive Order 13211

Executive Order 13211, “Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use” 66 FR 28355 (May 22, 2001),) requires 

Federal agencies to prepare and submit to OIRA at OMB, a Statement of Energy Effects 

for any proposed significant energy action. A “significant energy action” is defined as 

any action by an agency that promulgates or is expected to lead to promulgation of a final 

rule, and that: (1) is a significant regulatory action under Executive Order 12866, or any 

successor order; and (2) is likely to have a significant adverse effect on the supply, 

distribution, or use of energy; or (3) is designated by the Administrator of OIRA as a 

significant energy action. For any proposed significant energy action, the agency must 

give a detailed statement of any adverse effects on energy supply, distribution, or use 

should the proposal be implemented, and of reasonable alternatives to the action and their 

expected benefits on energy supply, distribution, and use. 

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DOE has tentatively concluded that today’s regulatory action, which sets forth 

energy conservation standards for walk-in coolers and freezers, is not a significant energy 

action because the proposed standards are not likely to have a significant adverse effect 

on the supply, distribution, or use of energy, nor has it been designated as such by the 

Administrator at OIRA. Accordingly, DOE has not prepared a Statement of Energy 

Effects on the proposed rule.

L. Review Under the Information Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in consultation with the Office of Science and 

Technology Policy (OSTP), issued its Final Information Quality Bulletin for Peer Review 

(the Bulletin). 70 FR 2664 (Jan. 14, 2005). The Bulletin establishes that certain scientific 

information shall be peer reviewed by qualified specialists before it is disseminated by 

the Federal Government, including influential scientific information related to agency 

regulatory actions. The purpose of the bulletin is to enhance the quality and credibility of 

the Government’s scientific information. Under the Bulletin, the energy conservation 

standards rulemaking analyses are “influential scientific information,” which the Bulletin 

defines as scientific information the agency reasonably can determine will have, or does 

have, a clear and substantial impact on important public policies or private sector 

decisions. 70 FR 2667. 

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews 

of the energy conservation standards development process and analyses and has prepared 

a Peer Review Report pertaining to the energy conservation standards rulemaking 

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analyses. Generation of this report involved a rigorous, formal, and documented 

evaluation using objective criteria and qualified and independent reviewers to make a 

judgment as to the technical/scientific/business merit, the actual or anticipated results, 

and the productivity and management effectiveness of programs or projects. The “Energy 

Conservation Standards Rulemaking Peer Review Report” dated February 2007 has been 

disseminated and is available at the following website: 

www1.eere.energy.gov/buildings/appliance_standards/peer_review.html. 

CLXXXVIII.VII. Public Participation

A. Attendance at the Public Meeting

The time, date, and location of the public meeting are listed in the DATES and 

ADDRESSES sections at the beginning of this notice. If you plan to attend the public 

meeting, please notify Ms. Brenda Edwards at (202) 586-2945 or 

Brenda.Edwards@ee.doe.gov. As explained in the ADDRESSES section, foreign 

nationals visiting DOE Headquarters are subject to advance security screening 

procedures.

In addition, you can attend the public meeting via webinar. Please note that foreign 

nationals visiting DOE Headquarters are subject to advance security screening 

procedures. Any foreign national wishing to participate in the meeting should advise 

DOE as soon as possible by contacting Ms. Edwards to initiate the necessary procedures. 

Please also note that those wishing to bring laptops into the Forrestal Building will be 

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required to obtain a property pass. Visitors should avoid bringing laptops, or allow an 

extra 45 minutes. Persons can attend the public meeting via webinar. 

Webinar registration information, participant instructions, and information about 

the capabilities available to webinar participants will be published on DOE’s website at: 

[INSERT LINK]. Participants are responsible for ensuring their systems are compatible 

with the webinar software.

B. Procedure for Submitting Prepared General Statements For Distribution

Any person who has plans to present a prepared general statement may request 

that copies of his or her statement be made available at the public meeting. Such persons 

may submit requests, along with an advance electronic copy of their statement in PDF 

(preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to the 

appropriate address shown in the ADDRESSES section at the beginning of this notice. 

The request and advance copy of statements must be received at least one week before 

the public meeting and may be emailed, hand-delivered, or sent by mail. DOE prefers to 

receive requests and advance copies via email. Please include a telephone number to 

enable DOE staff to make follow-up contact, if needed.

C. Conduct of the Public Meeting

DOE will designate a DOE official to preside at the public meeting and may also 

use a professional facilitator to aid discussion. The meeting will not be a judicial or 

evidentiary-type public hearing, but DOE will conduct it in accordance with section 336 

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of EPCA (42 U.S.C. 6306). A court reporter will be present to record the proceedings and 

prepare a transcript. DOE reserves the right to schedule the order of presentations and to 

establish the procedures governing the conduct of the public meeting. After the public 

meeting, interested parties may submit further comments on the proceedings as well as on 

any aspect of the rulemaking until the end of the comment period.

The public meeting will be conducted in an informal, conference style. DOE will 

present summaries of comments received before the public meeting, allow time for 

prepared general statements by participants, and encourage all interested parties to share 

their views on issues affecting this rulemaking. Each participant will be allowed to make 

a general statement (within time limits determined by DOE), before the discussion of 

specific topics. DOE will allow, as time permits, other participants to comment briefly on 

any general statements. 

At the end of all prepared statements on a topic, DOE will permit participants to 

clarify their statements briefly and comment on statements made by others. Participants 

should be prepared to answer questions by DOE and by other participants concerning 

these issues. DOE representatives may also ask questions of participants concerning other 

matters relevant to this rulemaking. The official conducting the public meeting will 

accept additional comments or questions from those attending, as time permits. The 

presiding official will announce any further procedural rules or modification of the above 

procedures that may be needed for the proper conduct of the public meeting.
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A transcript of the public meeting will be included in the docket, which can be 

viewed as described in the Docket section at the beginning of this notice. In addition, any 

person may buy a copy of the transcript from the transcribing reporter. 

D. Submission of Comments

DOE will accept comments, data, and information regarding this proposed rule 

before or after the public meeting, but no later than the date provided in the DATES 

section at the beginning of this proposed rule. Interested parties may submit comments, 

data, and other information using any of the methods described in the ADDRESSES 

section at the beginning of this notice. 

Submitting comments via regulations.gov... The regulations.gov webpage will 

require you to provide your name and contact information. Your contact information will 

be viewable to DOE Building Technologies staff only. Your contact information will not 

be publicly viewable except for your first and last names, organization name (if any), and 

submitter representative name (if any). If your comment is not processed properly 

because of technical difficulties, DOE will use this information to contact you. If DOE 

cannot read your comment due to technical difficulties and cannot contact you for 

clarification, DOE may not be able to consider your comment.

However, your contact information will be publicly viewable if you include it in 

the comment itself or in any documents attached to your comment. Any information that 

you do not want to be publicly viewable should not be included in your comment, nor in 

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any document attached to your comment. Otherwise, persons viewing comments will see 

only first and last names, organization names, correspondence containing comments, and 

any documents submitted with the comments. 

Do not submit to regulations.gov information for which disclosure is restricted by 

statute, such as trade secrets and commercial or financial information (hereinafter 

referred to as Confidential Business Information (CBI)). Comments submitted through 

regulations.gov cannot be claimed as CBI. Comments received through the website will 

waive any CBI claims for the information submitted. For information on submitting CBI, 

see the Confidential Business Information section.

DOE processes submissions made through regulations.gov before posting.

Normally, comments will be posted within a few days of being submitted. However, if 

large volumes of comments are being processed simultaneously, your comment may not 

be viewable for up to several weeks. Please keep the comment tracking number that 

regulations.gov provides after you have successfully uploaded your comment. 

Submitting comments via email, hand delivery/courier, or mail... Comments and 

documents submitted via email, hand delivery, or mail also will be posted to 

regulations.gov. If you do not want your personal contact information to be publicly 

viewable, do not include it in your comment or any accompanying documents. Instead, 

provide your contact information in a cover letter. Include your first and last names, 
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email address, telephone number, and optional mailing address. The cover letter will not 

be publicly viewable as long as it does not include any comments

Include contact information each time you submit comments, data, documents, 

and other information to DOE. If you submit via mail or hand delivery or courier, please 

provide all items on a CD, if feasible. It is not necessary to submit printed copies. No 

facsimiles (faxes) will be accepted.

 

 Comments, data, and other information submitted to DOE electronically should 

be provided in PDF (preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) 

file format. Provide documents that are not secured, that are written in English, and that 

are free of any defects or viruses. Documents should not contain special characters or any 

form of encryption and, if possible, they should carry the electronic signature of the 

author. 

Campaign form letters. Please submit campaign form letters by the originating 

organization in batches of between 50 to 500 form letters per PDF or as one form letter 

with a list of supporters’ names compiled into one or more PDFs. This reduces comment 

processing and posting time. 

Confidential Business Information. According to 10 CFR 1004.11, any person 

submitting information that he or she believes to be confidential and exempt by law from 

public disclosure should submit via email, postal mail, or hand delivery or courier two 
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well-marked copies: one copy of the document marked confidential including all the 

information believed to be confidential, and one copy of the document marked nonconfidential with the information believed to be confidential deleted. Submit these 

documents via email or on a CD, if feasible. DOE will make its own determination about 

the confidential status of the information and treat it according to its determination.

Factors of interest to DOE when evaluating requests to treat submitted 

information as confidential include: (1) a description of the items; (2) whether and why 

such items are customarily treated as confidential within the industry; (3) whether the 

information is generally known by or available from other sources; (4) whether the 

information has previously been made available to others without obligation concerning 

its confidentiality; (5) an explanation of the competitive injury to the submitting person 

that would result from public disclosure; (6) when such information might lose its 

confidential character due to the passage of time; and (7) why disclosure of the 

information would be contrary to the public interest.

It is DOE’s policy that all comments may be included in the public docket, 

without change and as received, including any personal information provided in the 

comments (except information deemed to be exempt from public disclosure). 
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E. Issues on Which DOE Seeks Comment

Although DOE welcomes comments on any aspect of this proposal, DOE is 

particularly interested in receiving comments and views of interested parties concerning 

the following issues: 

1. Component Level Standards

In this NOPR, DOE proposes to set separate standards for the panels, display 

doors, non-display doors, and refrigeration system of a walk-in, but is not proposing to 

establish an overall performance standard for the envelope or for the walk-in as a whole. 

DOE requests that interested parties submit comments about this approach. See section 

III.A for further details.

2. Market Performance Data 

As part of the market assessment, DOE collects information that provides an 

overall picture of the market for the walk-in coolers and freezers. DOE’s analysis of 

market data uses catalogue and performance data to determine the number of products on 

the market at varying efficiency levels. However, WICF equipment has not previously 

been rated for efficiency by manufacturers, nor has an efficiency metric been established 

for the equipment. DOE requests that interested parties submit market performance data 

to help inform DOE’s analysis. See section IV.A for further details.

3. Definitions 

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In this NOPR, DOE proposes to amend the existing definition of display door and 

to add definitions of passage door and freight door, as follows.

DOE proposes to amend the existing definition of display door to include all 

doors that are composed of 50 percent or more glass or another transparent material. This 

amendment is intended to classify passage doors that are mostly composed of glass as 

display doors because the utility and construction of glass passage doors more closely 

resemble that of a display door. DOE proposes the following amended definition of 

display door: “Display door means a door that – (1) is designed for product movement, 

display, or both, rather than the passage of personsdisplay; or (2) has 50 percent or more 

of its surface area composed of glass or another transparent material.” The amended 

definition would affect both the test procedure (by potentially subjecting a broader range 

of equipment to testing) and the energy conservation standards. DOE requests comment 

on the proposed definition of display door. 

DOE is also proposing a definition for passage doors in order to differentiate 

passage doors from freight doors. Passage doors are mostly intended for the passage of 

people and small machines such as hand carts. DOE proposes the following definition of 

passage door: “Passage door means a door that is used as a means of access for people 

and is less than 34 feet 9 inches wide and 78 feet tall.” DOE requests comment on the 

proposed definition of passage door. 
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 Freight doors tend to be larger than passage doors and are typically used to allow 

machines, such as forklifts, into walk-ins. DOE is proposing a definition of “freight door” 

to distinguish it from a passage door. DOE proposes the following definition of freight 

door: “Freight door means a door that is not a passage door and is equal to or larger than 

34 feet 9 inches wide and 78 feet tall.” DOE requests comment on the proposed definition 

of freight door. 

See section IV.A.1 for further information on the definitions.

4. Equipment Included in the Rulemaking

DOE proposes not to include certain types of equipment in the rulemaking 

analysis. DOE identified three types of panels used in the walk-in industry: display 

panels, floor panels, and non-floor panels. Based on its research, DOE determined that 

display panels, typically found in beer caves (walk-ins used for the display and storage of 

beer or other alcoholic beverages often found in a supermarket) make up a small 

percentage of all panels currently present in the market. Therefore, because of the 

extremely limited energy savings potential currently projected to result from amending 

the requirements that these panels must meet, DOE is not proposing standards for walk-in 

display panels in this NOPR. Also, DOE is declining to set a performance-based standard 

for walk-in cooler floor panels. All other types of panels, freezer floor and non-floor, will 

be subject to a performance standard. DOE requests comment on this approach and 

requests market data to better understand the market share of display panels and walk-in 

cooler floor panels. 
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DOE also proposes not to include blast freezer refrigeration systems, which are 

designed to quickly freeze food and then store it at a holding temperature, in this 

rulemaking analysis. DOE received comments regarding the performance difference and 

the higher energy consumption of blast freezers as compared to storage freezers. DOE 

questions whether blast freezer refrigeration systems would be less efficient than storage 

freezers and seeks information regarding whether blast freezers would face difficulty in 

complying with DOE’s proposed standards. Furthermore, if blast freezers cannot comply 

with those proposed standards, DOE requests test procedure data confirming the same. 

See section IV.A.2 for details.

5. Type of Refrigerant Analyzed

DOE based its analysis on refrigeration equipment using R404A, a 

hydrofluorocarbon (HFC) refrigerant, as it is widely used in the walk-ins industry. DOE 

received comments supporting the use of HFC refrigerants, but also suggested 

considering refrigerants with lower global warming potential (GWP) due to the shift in 

the marketplace toward these products. DOE acknowledges that there are governmentwide efforts to reduce emissions of HFCs, and such actions are being pursued both 

through international diplomacy as well as domestic actions. DOE, in concert with other 

relevant agencies, will continue to work with industry and other stakeholders to identify 

safer and more sustainable alternatives to HFCs while evaluating energy efficiency 

standards for this equipment. DOE requests comment on the extent of usecurrent use or 

future availability of lower GWP refrigerants and asks manufacturers and chemical 
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producers to submit data related to the ability of equipment (existing or redesigned) using 

theseHFC alternative refrigerants to meet the proposed standard. See section IV.A.2.b for 

further details. DOE also requests data and evidence to support estimates of the cost of 

any incremental technology or equipment redesign that may be needed in order to 

compensate for any energy efficiency losses associated with the use of alternative 

refrigerants to meet the standards proposed in this notice. 

6. Refrigeration Classes

DOE has proposed separate classes for dedicated condensing refrigeration 

systems and unit coolers connected to multiplex condensing systems. However, DOE 

does not propose to create separate classes for dedicated packaged systems (where the 

unit cooler and condensing unit are integrated into a single piece of equipment) and 

dedicated split systems (where the unit cooler and condensing unit are separate pieces of 

equipment connected by refrigerant piping). Due to the small market share of packaged 

systems, DOE proposes to base the standard for dedicated condensing systems on an 

analysis of split systems. DOE requests comment on its proposal not to consider 

dedicated packaged systems and dedicated split systems as separate classes, and 

specifically asks whether this proposal would unfairly disadvantage any manufacturers. 

In addition, DOE proposes one standard level for high-capacity equipment and 

another for low-capacity equipment within the dedicated condensing category (because 

the compressor is covered only for DC systems). High- and low-capacity equipment 

would thus also be considered different equipment classes., with the classes divided at a 
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threshold of 9,000 Btu/h. DOE requests comment on this proposal, particularly the 

capacity threshold between high- and low-capacity equipment. 

See section IV.A.3.b for details about the refrigeration system equipment classes.

7. Cycle Efficiency 

DOE considered design options manufacturers could use to improve cycle 

efficiency; for example, economizer cooling. In the screening analysis, DOE screened out 

economizer cooling based on utility to the consumer, one of the four screening criteria. 

Specifically, economizer cooling is not effective in areas of the country where the 

temperature does not drop below a walk-in’s temperature. DOE did not identify any other 

options to improve cycle efficiency beyond what was already considered. However, DOE 

realizes that there may be other methods and designs manufacturers could use to improve 

cycle efficiency and requests specific recommendations on such methods and designs, as 

well as how they could be incorporated into the analysis of standard levels. See section 

IV.B.2.b for details.

8. Envelope Representative Sizes

DOE used three different panel sizes to represent the variation in panels within 

each productequipment class. DOE determined the sizes based on market research and 

calculated the impact of size on the test metric, U-factor. DOE requests comment on the 

representative sizes used in the analysis and whether other sizes should be considered. 
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Similar to panels, DOE used three different sizes to represent the differences in 

doors within each class for walk-in display and non-display doors. The sizes of the doors 

were determined by market research, and can be found in section IV.C.1.a for display and 

non-display doors. DOE requests comment on the representative equipment sizes 

analyzed in the proposed analysis. See section IV.C.1.a for further details.

9. Performance Data for Envelope Components 

DOE’s engineering model separately analyzes panels, display doors, and nondisplay doors. The models estimate the performance of the baseline equipment and levels 

of performance above the baseline associated with specific design options that are added 

cumulatively to the baseline equipment. Results for performance of all components can 

be found in appendix 5A of the TSD. DOE requests comment on the performance data 

and requests any data manufacturers can provide about the performance of panels, 

display doors, or non-display doors and their design options. See section IV.A for further

details.

10. Refrigeration Metric

The refrigeration energy model calculates the annual energy consumption and the 

Annual Walk-in Energy Factor (AWEF) of walk-in coolers and freezers at various 

performance levels using a design option approach. AWEF is the ratio of the total heat, 

not included in the heat generated by the operation of the refrigeration system, removed, 

in Btu, from a walk-in box during a one-year period of usage to the total energy input of 

refrigeration systems, in watt-hours, during the same period. DOE proposes using AWEF 
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as the metric to set standards for the refrigeration system and requests comment on this 

proposal. See section IV.C.2.a for further details.

11. Manufacturing Markups 

DOE calculated the manufacturer’s selling price of the walk-in cooler and freezer 

equipment by multiplying the manufacturer’s production cost by a markup and adding the 

equipment’s shipping cost. The markup affects the manufacturer’s selling price, which is 

a critical input to the downstream economic analyses. DOE calculated an average markup 

for panels to be 32 percent, for display doors to be 50 percent, for non-display doors to be 

62 percent, and for refrigeration to be 35 percent. DOE requests comment on the 

proposed markups. See section IV.C.3.d for further details.

12. Envelope Component Shipping Prices

DOE has found through its research that most panel, display door, and nondisplay door manufacturers use less than truck load freight to ship their respective 

components. DOE also found that typically none of the manufacturers mark up the 

shipments for profit, and instead include the cost of shipping as part of the price quote. 

DOE has conducted its analysis accordingly and requests comment on the shipping prices 

found in chapter 5 of the NOPR TSD. See section IV.C.3.e for further details.

13. Panel and Door Baseline Assumptions 

In the NOPR analysis, DOE used wood framing members as the baseline framing 

material in panels. DOE’s analysis assumes the typical wood frame completely borders 
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the insulation and is 1.5 inches wide. DOE requests comment on its baseline 

specifications for walk-in panels, specifically the assumptions about framing material and 

framing dimensions. 

DOE assumed that the baseline non-display doors are constructed in a similar 

manner to baseline panels. Baseline non-display doors consist of wood framing materials 

1.5 inches wide that completely border foamed-in-place polyurethane insulation. For nondisplay doors, DOE also proposes to include a 2.25 ft2 window that conforms to the 

standards set by EPCA on all non-display passage doors regardless of the passage door’s 

size. DOE analyzed two different size windows for non-display freight doors. DOE 

assumed that a small freight door has a 2.25 ft2 window and that both medium and large 

freight doors have 4 ft2 windows. DOE requests comment on the baseline specifications 

for non-display doors, specifically on the size of the windows included in the baseline 

door. 

DOE made several assumptions about baseline display doors in its analysis. First 

it assumed that baseline display cooler doors are composed of two panes of glass with 

argon gas fill and hard coat low-e coating. Second, DOE assumed that the baseline cooler 

display door requires 2.9 W/ft2 of anti-sweat heater wire and does not have a heater wire 

controller. Baseline display freezer doors in DOE’s analysis are composed of three panes 

of glass, argon gas, and soft coat low-e coating. Third, DOE assumed that baseline 

freezer doors use 15.23 W/ft2 of anti-sweat heater wire power and require an anti-sweat 

heater wire controller. Finally, DOE assumed that each baseline door is associated with 
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one fluorescent light with an electronic ballast, and that a door shorter than 6.5 feet has a 

5-foot fluorescent bulb and a door equal to or taller than 6.5 feet has a 6-foot fluorescent 

bulb. DOE requests comment on the baseline assumptions for display cooler and freezer 

doors. In particular, DOE requests data illustrating the energy or power consumption of 

anti-sweat heaters found on cooler and freezer display doors. 

See section IV.C.4.a for further details on the baseline assumptions. 

14. Condensing Unit and Unit Cooler Components

In its analysis of baseline equipment, DOE included all necessary components of 

the refrigeration system that came from the manufacturer. However, DOE has tentatively 

decided against including components in its engineering analysis that are not specifically 

part of the unit cooler or condensing unit; for example, refrigerant piping connecting a 

unit cooler to a multiplex condensing system. DOE assumes that these are not included in 

the manufacturer’s selling price of the equipment, and would be supplied by the 

contractor upon installation. DOE requests comment on this assumption. See section 

IV.C.4.b for further details.

15. Refrigeration Temperature Difference Assumption

In determining appropriate temperature set points, DOE considered information 

from various sources in formulating its assumptions: comments, research, and 

confidential and non-confidential discussions with manufacturers and other parties. DOE 

notes that the ambient temperature specified in the test procedure is 90 or 95 degrees for 
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indoor and outdoor condensing units, respectively. Given that the system must maintain a 

reasonable temperature difference (TD) between the SCT and the ambient temperature, 

the SCT during the test procedure would be higher than the 90-–95 degree assumption 

recommended. Even though the set point during actual use may be lower, equipment is 

rated—and evaluated for meeting the standard—at the test procedure rating points. DOE 

requests comment on this assumption, particularly whether the TDs for baseline and 

higher efficiency equipment are appropriate. See section IV.C.4.b for further details.

16. Panel Design Options

In the proposed engineering analysis for walk-in panels, DOE included design 

options that increase the baseline insulation thickness, change the baseline insulation 

material from foam-in-place polyurethane to a hybrid of polyurethane and VIP, change 

the baseline framing material from wood to high-density polyurethane, and eliminate a 

non-floor-panel’s framing material. DOE proposes that floor panels must retain some 

type of framing material, and that high-density polyurethane framing materials found in a 

panel have the same dimensions as the wood framing materials. DOE requests comment 

on the design options for panels, particularlyincluding the specifications for high-density 

polyurethane framing materials., manufacturer conversion costs for increasing the 

baseline panel thickness, and any estimated changes in repair, maintenance, or 

installation costs. DOE also requests comment on the technological feasibility of the 

panel options analyzed and whether the design options selected would cause any 

lessening of the utility or the performance of the walk-ins. See section IV.C.5.a for 

further details.
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17. Display and Non-Display Door Design Options

The design options that DOE proposes for display doors include improved glass 

packs, anti-sweat heater controls for cooler doors, LED lighting, and lighting sensors. 

DOE does not propose anti-sweat heater controls for freezer display doors because 

baseline freezer doors are required to have a controller due to the amount of power 

consumed by the anti-sweat heater wire. DOE requests comment on the proposed design 

options, specifically any heat transfer data for the improved glass packs detailed in 

chapter 5 of the TSD. 

The design options that DOE proposes for non-display doors include increased 

insulation thickness, changing the insulation material from baseline to a hybrid of 

polyurethane and VIP, changing the baseline framing material from wood to high-density 

polyurethane, improving the window’s glass pack, and adding an anti-sweat heater wire 

controller to the door. DOE requests comment on the proposed design options for nondisplay doors, and specifically requests comment on the cost of the window 

improvements detailed in chapter 5 of the TSD.manufacturer conversion investments 

required to update product designs and manufacturing lines in order to product compliant 

products; information regarding any changes in repair, maintenance, or installation costs 

of the window improvements detailed in chapter 5 of the TSD. DOE also requests 

comment on the technological feasibility of the panel options analyzed and whether the 

design options selected would cause any lessening of the utility or the performance of the 

walk-ins. 
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See section IV.C.5.a and chapter 5 of the TSD for further details on the display 

and non-display door design options.

18. Refrigeration System Design Options

DOE is proposing to include the use of improved condenser coils as a design 

option, wherein the condenser coil increases by a certain percentage from its original 

size. After performing analytical calculations, DOE tentatively believes that increasing 

the coil size of the condenser would not require an increase in the coil size of the 

evaporator. However, DOE requests comment on this assumption, particularly from 

manufacturers that currently utilize larger condenser coils. 

DOE is proposing to use high-efficiency condenser fan motors as a design option, 

and it is critical to accurately estimate the input power due to the energy savings 

associated with this option. DOE calculated the input power from the efficiency ratings 

provided. However, DOE received comments that this approach may not provide an 

accurate method to measure input power and requests feedback on how it should 

determine input power. 

DOE also considered a design option which modulates or adjusts the speed of the 

evaporator fans when the compressor is off. DOE is aware of the potential effects of 

evaporator fan control on food safety but has tentatively concluded that the controls it 

analyzed are limited (to 50 percent fan cycling or 50 percent fan speed when the 
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compressor is off) such that food temperatures could be adequately maintained in either 

control case. DOE requests comment from interested parties as to whether food 

temperatures would be adequately maintained in the specific control cases it has 

analyzed, and, if not, what would be an appropriate control strategy. DOE particularly 

requests any data interested parties can provide to show the relationship between fan 

controls and food temperatures. DOE also seeks information on whether other

components may be necessary to ensure food temperatures would be adequately 

maintained, such as extra thermostats located in certain areas of the walk-in. 

DOE has adjusted its analysis of the floating head pressure design option after 

taking commenters’ recommendations into account. DOE included components and 

analytical changes with respect to fan power, temperature differences, and SCT in 

response to stakeholder comments. DOE requests comment on its revised assumptions 

and implementation of this option, particularly regarding the cost to implement various 

floating head pressure control schemes and the energy savings that would be achieved. 

DOE requests comment on the technological feasibility of the panel options analyzed and 

whether the design options selected would cause any lessening of the utility or the 

performance of the walk-ins. DOE also requests information on any changes in repair, 

maintenance, or installation costs associated with the technologies needed to meet the 

proposed standards.

See section IV.C.5.b and chapter 5 of the TSD for further details on the 

refrigeration system design options. 
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19. Relative Equipment Sizing

In the Energy Use Analysis, DOE calculates the expected energy consumption of 

the covered equipment, as installed. To do so, DOE makes certain assumptions about the 

relative sizing of refrigeration systems with envelopes, which determines how often the 

compressor runs during a day, which in turn affects the energy use of the equipment. For 

the NOPR analysis, DOE assumed that the runtime of the refrigeration system is 13.3 

hours per day for coolers and 15 hours per day for freezers at full design point capacity

and requests comment on this assumption. See section IV.E.1 for further details.

20. Equipment Price Trends

DOE assumes in its price forecasts for this NOPR that the real prices of walk-in 

cooler and freezer equipment decrease slightly over time. DOE performed price trends 

sensitivity calculations to examine the dependence of the analysis results on different 

analytical assumptions. DOE invites comment on methods to improve its equipment price 

forecasting, as well as any data supporting alternate methods. For more details, see 

section IV.F.1. 

21. Refrigerant Charge Maintenance Costs

DOE received comments on maintenance costs associated with refrigerant 

leakage and refrigerant charge and assumed a certain maintenance cost for the 

refrigeration system. DOE requests that interested parties submit data on refrigerant 

charge maintenance costs. See section IV.F.6 for further details.
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22. Compliance Date of Standards

DOE’s proposed standards will apply to products that are manufactured beginning 

on the date 3 years after the final rule is published unless DOE determines, by rule, that a 

3-year period is inadequate, in which case DOE may extend the compliance date for that 

standard by an additional two2 years. (42 U.S.C. 6314(f)(4)(B)) Because DOE anticipates 

publishing the final rule in 2012, DOE calculated the LCC and PBP proposes to provide 3 

years for walk-in coolers and freezers under the assumption that compliant equipment 

would be purchased in the year when compliance with the newthis standard is required—

2015—because it has not received any information indicating that 3 years is inadequate. 

DOE, but seeks comments and informationcomment on the adequacy of the 3-

yearwhether it should consider a longer compliance date and whether additional time is 

needed. If additional time is needed, DOE seeks information, including data, in support 

of that viewas authorized, and, if so, by how much. See section IV.F.9 for details.

23.23. Base-Case Efficiency Distributions

To accurately estimate the share of consumers who would likely be impacted by a 

standard at a particular efficiency level, DOE’s LCC analysis considers the projected 

distribution of product efficiencies that consumers purchase under the base case (i.e., the 

case without new energy efficiency standards) DOE examined the range of standard and 

optional equipment features offered by refrigeration manufacturers and estimated that for 

refrigeration systems, 75 percent of the equipment sold under the base case would be at 

DOE’s assumed baseline level—that is, the equipment would comply with the existing 
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standards in EPCA, but have no additional features that improve efficiency. The 

remaining 25 percent of equipment would have features that would increase its efficiency 

to a level commensurate with the first design option in each equipment class. For 

envelope components, all base case shipments are assumed to have only a single EPCAcompliant efficiency level except for cooler display doors. For cooler display doors, 

shipments in the base case would be a mix of 80 percent EPCA-compliant equipment and 

20 percent higher efficiency equipment. For both refrigeration systems and envelope 

components, DOE assumed that the base-case energy efficiency distribution would 

remain constant throughout the forecast period. DOE requests comment on its 

assumptions about base-case efficiency distributions. See sections IV.F.10 and IV.G.2 for 

details.

24. Trial Standard Level Equations

In this NOPR, DOE proposes standard levels for different classes of refrigeration 

systems. DOE expressed the AWEF for large capacity dedicated condensing systems as a 

single value and expressed the AWEF for the small capacity dedicated condensing 

systems as a linear equation normalized to the system gross capacity. DOE calculated a 

single minimum AWEF for each class of multiplex condensing systems. The 

methodology DOE used to develop the AWEF values and equations is detailed in 

appendix 10D of the TSD. DOE requests comment on the AWEF equations and the 

methodology for determining them. In particular, DOE asks interested parties to submit 

data on how the efficiency of typical refrigeration systems varies by capacity. Based on 

comments and additional data DOE receives on the NOPR, DOE may consider other 
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methods of calculating the minimum AWEF associated with the TSLs for each 

equipment class. See section V.A.2 for details.

25. Proposed Standard 

 In this NOPR, DOE proposes TSL 4 as the energy conservation standard for 

equipment covered under this rulemaking. DOE proposes this standard because it 

tentatively believes that it represents the maximum improvement in energy efficiency that 

is technologically feasible and economically justified, and that the benefits outweigh the 

burdens. For a full description of the benefits and burdens of TSL 4, see section V.C. 

We seek comment, information and data on whether other combinations of 

standards for refrigeration units, panels, or doors can improve energy efficiency that is 

technologically feasible and economically justified, taking into consideration effects on 

the manufacturers and the end users of walk-in coolers and freezers. 

 

26. Product Attributes

DOE requests comment on whether there are features or attributes of the more 

energy efficient walk-in coolers and freezers that manufacturers would produce to meet 

the standards in this proposed rule that might lessen the utility or performance of these 

products in current uses (i.e., restaurants, food service providers, grocery stores and 

convenience stores). An example of such an effect might be that grocers or restaurant 

operators would change where, how, how much and for how long food items would be 

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stored or whether thicker panels would detrimentally reduce the refrigerated area of a 

walk-in making higher efficiency panels less desirable. DOE requests comment 

specifically on how any such effects should be weighed in the choice of standards for 

these walk-in coolers and freezers for the final rule.

27. Impact of Amended Standards on Future Shipments

DOE welcomes stakeholder input and estimates on the effect of amended 

standards on future walk-in cooler and freezer shipments. We are seeking information on 

what factors drive the demand for walk-in coolers and freezers and whether those factors 

are likely to remain unchanged in the relevant analytic time period of 30 years. For 

example, a commenter submitted that 70 percent of all restaurants and 90 percent of all 

small restaurants fail due to insufficient up-front capital. In light of this information, are 

there better ways and data to project future shipments of walk-in coolers and freezers 

than the current method which is based on the number of buildings projected to house 

walk-in coolers and freezers? DOE also welcomes input and data on the demand 

elasticity estimates used in the analysis.

28. Learning Impacts on Price forecast for Future Shipments

Currently, DOE projects future prices by subtracting the cost reductions 

associated with learning effects from the cost associated with the amended standards. 

DOE analyzes learning effects using PPI, a quality adjusted index of wholesale prices, as 

a proxy for price of commercial refrigerators. DOE is seeking input, and price data that 
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could be used in place of PPI. Also DOE is seeking input on the magnitude of the price 

data and the cause of those price changes. 

29. Analytic Timeline

For this rulemaking, DOE analyzed the effects of this proposal assuming that the 

walk-in coolers and freezers would be available to purchase starting 2017 until 2047 and 

includes the useful life of the last unit sold, extending the analysis to 2073. DOE also 

undertook a sensitivity analysis using nine rather than 30 years of product shipments. The 

choice of a 30-year period is consistent with the DOE analysis for other products and 

commercial equipment. The choice of a 9-year period is a proxy for the timeline in 

EPCA for the review of certain energy conservation standards and potential revision of 

and compliance with such revised standards. We are seeking input, information and data 

on whether there are ways to refine the analytic timeline further. 

In particular, given that walk-in coolers and freezers are largely used by the food 

service industry, convenience stores and small grocers, we are seeking information on 

whether the turnover rates in the food service industry, convenience stores and small 

grocers affects the useful life of walk-in coolers and freezers.

30. Markets for Used Walk-In Coolers and Freezers

DOE is seeking information on whether there is a significant market for used 

walk-in coolers and freezers. Given the high turnover rate of food service industry (e.g., 

a commenter noted 70 to 90 percent failure rates for restaurants), we are seeking to 
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understand whether it is reasonable to assume that the useful life of the refrigeration 

system would be 12 years and other components 15 years due to active used equipment 

markets. 

31. Small Businesses

During the Framework and preliminary analysis public meetings, DOE received 

many comments regarding the potential impacts of amended energy conservation 

standards on small business manufacturers of walk-in coolers and freezers. DOE notes 

that the small businesses could be disproportionately affected by this standard because of 

the cost of testing, potential increase in materials and potential difficulty in obtaining 

financing. DOE seeks comment and, in particular, data, in its efforts to quantify the 

impacts of this rulemaking on small business manufacturers. 

32. Rebound Effect

DOE assumed a rebound factor of one, or no effect, because walk-ins must cool 

their contents at all times and it is not possible for consumers to operate them more 

frequently. A rebound effect occurs when users operate higher efficiency equipment 

more frequently and/or for longer durations, thus offsetting estimated energy savings. 

DOE seeks comment on this assumption and whether other factors should be considered 

in the rebound effect, such as a decision to buy a larger system due to increased lifetime 

costs savings, or money saved in electricity bills with more efficient walk-in coolers and 

freezers being used for other electricity consuming activities.

33. Update to Social Cost of Carbon Values
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DOE solicits comment on the application of the new SCC values used to 

determine the social benefits of CO2 emissions reductions over the rulemaking analysis 

period. The rulemaking analysis period covers from 2017 to 2046 plus an additional 15 

years to account for the lifetime of the equipment purchased between 2017 and 2046. In 

particular, the agency solicits comment on the agency’s derivation of SCC values after 

2050 where the agency applied the average annual growth rate of the SCC estimates in 

2040−2050 associated with each of the four sets of values.

34. Cumulative Regulatory Burdens

The agency seeks input on the cumulative regulatory burden that may be imposed 

on industry either from recently implemented rulemakings for this product class or other 

rulemakings that affect the same industry. 

CLXXXIX.VIII. Approval of the Office of the Secretary

The Secretary of Energy has approved publication of today’s proposed rule.

 

List of Subjects in 10 CFR Part 430431

Administrative practice and procedure, Confidential business information, Energy 

conservation, Commercial equipment, Imports, Intergovernmental relations, Reporting 

and recordkeeping requirements, and Small businesses. 

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Issued in Washington, DC, on 

________________________________

Henry Kelly

Acting Assistant Secretary of Energy

Energy Efficiency and Renewable Energy

________________________________

DAVID T. DANIELSON

ASSISTANT SECRETARY

ENERGY EFFICIENCY AND RENEWABLE ENERGY

For the reasons set forth in the preamble, DOE proposes to amend part 431 of 

chapter II of title 10, of the Code of Federal Regulations, to read as set forth 

below: 

PART 431 – ENERGY EFFICIENCY PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL EQUIPMENT

1. The authority citation for Partpart 431 continues to read as follows:

Authority: 42 U.S.C. 6291-6317. 

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2. Section 431.302 is amended by amendingrevising the definition for 

“Display Door” and adding, in alphabetical order, definitions for “Freight Door” 

and “Passage Door” to read as follows:

§431.302 Definitions concerning walk-in coolers and freezers. 

* * * * * 

Display door means a door that has 50:

 (1) Is designed for product display; or 

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

another transparent material.

3. Section 431.302 is amended by adding, in alphabetical order, new definitions 

for “Freight Door” and “Passage Door” to read as follows:

§431.302 Definitions concerning walk-in coolers and freezers.

* * * * * 

Freight door means a door that is not a passagedisplay door and is equal to 

or larger than 34 feet 9 inches wide and 78 feet tall.

* * * * *

Passage door means a door that is used as a means of access for people 

and is not a freight or display door.

.

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* * * * *

3. In §431.304, revise paragraph (a) to read as follows:

§431.304 Uniform test method for the measurement of energy consumption 

of walk-in coolers and walk-in freezers.

(a) Scope. This section provides test procedures for measuring, pursuant to 

EPCA, the energy consumption of walk-in coolers and walk-in freezers.

* * * * *

4. In §431.306, revise paragraph (a)(3), and add paragraphs (c), (d), (e), and (f) to 

read as follows:

§431.306 Energy conservation standards and their effective dates. 

* * *

(a) * * *

(3) Contain wall, ceiling, and door insulation of at least R-25 for coolers and R-32 

for freezers, except that this paragraph shall not apply to:

(i) Glazed portions of doors not to structural members and 

(ii) A walk-in cooler or walk-in freezer component if the component 

manufacturer has demonstrated to the satisfaction of the Secretary in a manner 

consistent with applicable requirements that the component reduces energy 

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consumption at least as much as if such insulation requirements of subparagraph

(a)(3) were to apply.

(b) * * * * *

(c) Walk-in cooler and freezer panels. 

Equipment CategoryClass 

Descriptor

Temperature Class Equations for Maximum U-Factor 

(Btu/h-ft2-°F))*

Structural50

Medium

Panel, Medium 

Temperature** SP.M

0405.0

core nf

edge nf 239.0

2

core nf

edge nf 0118.0 ×− ×+ +

































A

A

A

A

041.0

core nf

edge nf 024.0

2

core nf

edge nf 012.0 ×− ×+ +

































A

A

A

A

LowStructural Panel, Low 

Temperature SP.L

0287.0

core nf

edge nf 172.0

2

core nf

edge nf 00847.0 ×− ×+ +

































A

A

A

A

029.0

core nf

edge nf 017.0

2

core nf

edge nf 0083.0 ×− ×+ +

































A

A

A

A

Floor Panel, Low Temperature

Low

FP.L

0385.0

core nf

edge nf 0214.0

2

core nf

edge nf 0108.0 ×− ×+ +

































A

A

A

A

033.0

fp core 

fp edge 018.0

2

fp core 

fp edge 0091.0 ×− ×+ +

































A

A

A

A

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

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

** A structural panel is a panel that is not used to construct a walk-in’s floor. This includes, but is not limited to, ceiling 

panels and wall panels.

(d) Walk-in cooler and freezer display doors.

Equipment CategoryClass 

Descriptor

Temperature

Class

Equations for 

Maximum Energy 

Consumption 

(kWh/day))*

 

50 A structural panel is a panel that is not used to construct a walk-in’s floor. This includes, but is 

not limited to, ceiling panels and wall panels.

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Display Door, Medium 

Temperature

Medium

DD.M

0610.0 +× 586.0 dd A

049.0 +× 39.0 Add

LowDisplay Door, Low 

Temperature DD.L

251.0 +× 574.0 dd A

+× 38.033.0 Add

*Add represents the surface area of the display door.

(e) Walk-in cooler and freezer non-display doors.

Equipment CategoryClass 

Descriptor

Temperature

Class

Equations for 

Maximum Energy 

Consumption 

(kWh/day))*

Passage Door, Medium 

Temperature 

Medium

PD.M

000323.0 +× 217.0 nd A

0032.0 +× 22.0 And

LowPassage Door, Low 

Temperature PD.L

139.0 +× 30.4 nd A

+× 0.414.0 And

Freight Door, Medium 

Temperature

Medium

FD.M

00727.0 +× 0820.0 nd A

0073.0 +× 082.0 And

LowFreight Door, Low 

Temperature FD.L

117.0 +× 15.5 nd A

+× 4.511.0 And

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

(f) Walk-in cooler and freezer refrigeration systems.

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Equipment classClass Descriptor CodeClass

Capacity 

Range 

(Btu/h)

Equations for Minimum 

AWEF

(Btu/W-h))*

Dedicated Condensing, Medium 

Temperature, Indoor 

SystemsSystem, < 9,000 Btu/h 

Capacity

DC.M.I, < 9,000

< 15,000

53.41063.2 4 +×× − Q

6.63

Dedicated 

Condensing, 

Medium 

Temperature, Indoor 

System, ≥ 9,000 

Btu/h Capacity

≥ 15DC.M.I, ≥ 9,000 6.907.38

Dedicated Condensing, Medium 

Temperature, Outdoor 

SystemsSystem, < 9,000 Btu/h 

Capacity

DC.M.O, < 9,000

< 15,000

12.01034.1 3 +×× − Q

9.51

Dedicated 

Condensing, 

Medium 

Temperature, 

Outdoor System, ≥ 

9,000 Btu/h Capacity

≥ 15DC.M.O, ≥ 9,000 12.8121

Dedicated Condensing, Low 

Temperature, Indoor 

SystemsSystem, < 9,000 Btu/h 

Capacity

DC.L.I, < 9,000 < 7500

89.11093.1 4 +×× − Q

3.09

Dedicated Condensing, Low 

Temperature, Indoor System, ≥

9,000 Btu/h Capacity

DC.L.I, ≥

9,000

≥ 7500

3.9163

Dedicated Condensing, Low 

Temperature, Outdoor 

SystemsSystem, < 9,000 Btu/h 

Capacity

DC.L.O, < 9,000 < 7500

02.11070.5 4 +×× − Q

4.71

Dedicated Condensing, Low 

Temperature, Outdoor System, ≥

9,000 Btu/h Capacity

DC.L.O, ≥ 9,000 ≥ 75006.15

7.39

Multiplex Condensing, Medium 

Temperature MC.M 10.74

12.86

Multiplex Condensing, Low 

Temperature MC.L 5.53

6.29

*Q represents the system gross

capacity as calculated by the 

procedures set forth in AHRI 1250.

* * * * *

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