Building Technologies Program 1 eere.energy.gov

Public Service of Colorado Ponnequin Wind Farm

BUILDING TECHNOLOGIES PROGRAM

Commercial Refrigeration Equipment 

(CRE) Test Procedure Notice of Proposed 

Rulemaking (NOPR) Public Meeting

Charles Llenza

January 6, 2011

CRE-2010-STD-0003@ee.doe.gov
Building Technologies Program 2 eere.energy.gov

Proposed Test Procedure Amendments

Burden of Testing & Regulatory Review

Closing Remarks, Contacts & Information

Public Meeting Topics

4

5

6

2 Rulemaking History & Timelines

3 Test Procedure Rulemaking Scope

1 Welcome, Introductions & Opening Remarks
Building Technologies Program 3 eere.energy.gov

• Meeting Agenda

• Introductions

• Role of the Facilitator

• Ground Rules 

– Listen as an ally

– Focus on the issues

– Use short, succinct statements/keep to the point

– One person speak at a time (raise hand to be recognized; state your 

name for the record)

– Hold sidebar conversations outside the room

– Set cell phones to silent/vibrate

• Housekeeping Items

Welcome, Introductions & Opening Remarks 
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• To present DOE’s proposed test procedure amendments.

• To answer questions about DOE’s proposed approach.

• To seek comment & input from participants on the DOE’s proposed 

testing.

• To discuss the Federal Register published the NOPR, 75 FR 51596, 

November 24, 2010. The NOPR:

– Gives notice of the public meeting and availability of the NOPR 

document.

– Describes the proposed amendments to the CRE test procedure.

• Please submit comments no later than January 24, 2011.

• Document and materials from today’s public meeting will be available 

online: 

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

Welcome, Introductions & Opening Remarks

Public Meeting Purpose
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Welcome, Introductions & Opening Remarks

Issue Box - In the test procedure NOPR for commercial 

refrigeration equipment, DOE welcomes comment. 

Throughout this presentation, specific issues will be raised 

for discussion on slides such as this, with identifying 

numbers corresponding to those in the test procedure 

NOPR document. In addition, DOE has added questions that 

are not in the framework document. These questions are 

identified by a letter. 

Request for Comment Format
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Welcome, Introductions & Opening Remarks

At this time DOE welcomes opening remarks on the 

NOPR document for the proposed test procedure for 

commercial refrigeration equipment. 
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Proposed Test Procedure Amendments

Burden of Testing & Regulatory Review

Closing Remarks, Contacts & Information

Public Meeting Topics

4

5

6

2 Rulemaking History & Timelines

3 Test Procedure Rulemaking Scope

1 Welcome, Introductions & Opening Remarks 
Building Technologies Program 8 eere.energy.gov

Rulemaking History & Timelines

• DOE published a final rule on January 9, 2009 (74 FR 1092);effective January 1, 2012. 

• EPACT 2005 amendment to EPCA also directed DOE to determine whether to amend the 

standards prescribed both by DOE and in EPACT 2005 and, if necessary, publish amended 

standard by January 1, 2013.

• DOE is currently conducting a separate rulemaking to address whether to amend energy 

conservation standards for commercial refrigeration equipment set by EPACT 2005 and DOE 

(EERE-2010-BT-STD-0003).

• Any amended standards established by DOE would apply to equipment manufactured 3 years or 

more after the publication of such a rule, or a maximum of 5 years.

2005 2009 2010 2012 2013 2016

DOE sets standards for 

ice-cream freezers, remote 

condensing equipment, 

and self-contained 

equipment without doors

DOE determines 

whether to amend 

standards for all 

CRE equipment 

(EPACT and 2009 

rulemaking)

EPACT 

prescribes 

standards 

for SC 

equipment

with doors

EPCA 

establishes 

energy 

conservation 

program 

1975

CRE Standard Regulatory History
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Rulemaking History & Timelines

• EPCA, as amended, directs that:

– Compliance with energy conservation standards is shown using prescribed 

test procedures. (42 U.S.C. 6311(3) and (4)) 

– Test procedures for commercial refrigerators, freezers, and 

refrigerator-freezers must be:

1) the test procedures determined to be generally accepted industry 

testing procedures; or 

2) rating procedures developed or recognized by ASHRAE or by ANSI.

(42 U.S.C. 6314(a)(6)(A)(i)) 

– The initial test procedures for self-contained refrigerators, freezers, and 

refrigerator-freezers with doors shall be the ASHRAE 117 test procedures 

that went into effect January 1, 2005. (42 U.S.C. 6314(a)(6)(A)(ii))

CRE Test Procedure Regulatory History 
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Rulemaking History & Timelines

• EPCA states that:

– If ASHRAE 117 is amended, the Secretary must, by rule, amend the DOE test 

procedure to ensure consistency with the amended ASHRAE 117 unless 

certain findings are made by clear and convincing evidence. (42 U.S.C. 

6314(a)(6)(E)) 

– If a test procedure other than ASHRAE 117 is approved by ANSI, the 

Secretary must review the relative strengths and weaknesses of the new test 

procedure relative to the ASHRAE 117 test procedure and, based on that 

review, adopt one new test procedure for use in the standards program. 

(42 U.S.C. 6314(a)(6)(F)) 

– At least once every 7 years DOE must conduct an evaluation of each class of 

covered equipment to determine whether to, among other things, amend 

the test procedures for such equipment. (42 U.S.C. 6314(a)(1))

Authority to Amend CRE Test Procedure
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Rulemaking History & Timelines

• On December 8, 2006, DOE established 

the current test procedure for 

commercial refrigeration equipment, 

which references the Air-Conditioning 

and Refrigeration Institute (ARI) 

Standard 1200-2006.

– ARI 1200-2006 references ASHRAE 

Standard 72-2005 as the method 

of test.

• DOE adopted AHAM Standard HRF-1-

2004 for measuring refrigerated 

compartment volume. 71 FR 71370 

(Dec. 8, 2006). 

Current CRE Test Procedure
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Rulemaking History & Timelines

• The current DOE test procedure contains the following rating temperatures 

which are applicable to all commercial refrigeration equipment for which 

energy conservation standards have been set in EPACT 2005 and by DOE in 

2009:

• The current test procedures for commercial refrigeration equipment appear 

under Title 10 of the Code of Federal Regulations part 431, subpart C.

Equipment Rating Temperature

Commercial refrigerators and 

refrigerator compartments 38 °F (±2 °F)

Commercial freezers and 

freezer compartments 0 °F (±2 °F)

Commercial ice-cream 

freezers -15 °F (±2 °F)

Current CRE Test Procedure Test Temperatures
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Rulemaking History & Timelines

• The energy conservation standard rulemaking is in the preliminary analysis 

stage & these results will be presented in a separate public meeting. 

Energy Conservation 

Standards (ECS)

Test Procedure (TP)

Framework

Document

Preliminary 

Analysis NOPR Final

Rule

NOPR Final 

Rule

CRE Standard and Test Procedure Rulemakings Timelines
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Rulemaking History & Timelines

2010

ECS Framework 

Document Public 

Meeting

May 18, 2010

ECS Preliminary 

Analysis

Public Meeting

Planned - Spring 2011

ECS NOPR

Public Meeting

Planned - Winter 2012

2012 2013 2014 2015 2016

Proposed Final Rule 

Effective Date 

January 1, 2016

CRE Energy Conservation Standard Rulemaking Timeline

TP NOPR 

Public Meeting

January 6, 2011

2011
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Rulemaking History & Timelines

EPCA Provision Authority Effective Date

Energy 

Conservation 

Standard

DOE 3 years after standard final rule 

publication (January 1, 2016)

Test Procedure DOE Concurrent with amended energy 

conservation standard

Additional Comment A - DOE welcomes comment on the effective date 

of the test procedure final rule. 

Effective Dates
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Proposed Test Procedure Amendments

Burden of Testing & Regulatory Review

Closing Remarks, Contacts & Introductions

Public Meeting Topics

4

5

6

2 Rulemaking History & Timelines 

3 Test Procedure Rulemaking Scope

1 Welcome, Introductions & Opening Remarks 
Building Technologies Program 17 eere.energy.gov

Test Procedure Rulemaking Scope

• The current DOE test procedure allows for testing to show compliance with 

energy conservation standards set for: 

– self-contained commercial refrigeration equipment with doors, as established 

by EPACT 2005, and 

– remote condensing commercial refrigeration equipment, self-contained 

equipment without doors, and ice-cream freezers for which DOE set energy 

conservation standards in 2009.

• DOE intends to include in the scope of the current test procedure 

rulemaking both the equipment with standards prescribed in EPACT 2005 

and the equipment for which DOE established energy conservation 

standards in 2009.

Test Procedure Scope
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Test Procedure Rulemaking Scope

• The DOE TP NOPR does not currently include test procedures for secondary 

coolant equipment. 

Additional Comment B - DOE welcomes comment on the exclusion of 

secondary coolant systems in the DOE test procedure. 

Secondary Coolant 

Coverage Current Rule Proposed

Energy Conservation 

Standard 

Not covered within the 

scope of commercial 

refrigeration equipment

DOE does not plan to cover 

secondary coolant systems in the 

current ECS rulemaking

Test Procedure Excluded from ARI 1200-

2006 Excluded from AHRI 1200-2010

Secondary Coolant Equipment
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Test Procedure Rulemaking Scope

• At the May 18, 2010 CRE Framework document public meeting, several 

interested parties suggested that DOE should incorporate provisions to capture 

the effects of technologies that reduce energy consumption at variable 

refrigeration load or variable time periods.

Transient Technologies

Operate as a function of 

variable ambient conditions

Operate at 

variable times

• Higher efficiency expansion valves

• Condenser fan motor controllers

• Anti-sweat heater controls

• Lighting occupancy sensors and 

controls

• Night curtains

Part Load Technologies Energy Conservation Features

Testing of Transient Technologies
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Test Procedure Rulemaking Scope

• AHRI Standard 1200 and ASHRAE Standard 72 call for a steady-state test that 

captures some part load effects and is significantly less burdensome than a test 

that would capture all such effects. A test procedure for part load technologies 

would likely require separate tests at multiple ambient conditions. 

• DOE’s proposed test procedure would capture variation in refrigeration load 

experienced during night curtain use for open cases and door opening events 

for display cases with doors. In addition, the 75 °F and 55% relative humidity 

standard rating condition is typically part load, rather than maximum design 

load.

• DOE believes that part load testing is not justified because of the increased 

burden. As a result, DOE proposes to continue to require testing at one 

standard rating condition, relying on the transient effects inherent in the 

proposed test procedure to capture part load performance. 

Part Load Technologies – No Additional Testing Proposed
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Test Procedure Rulemaking Scope

• DOE is considering certain technology options for the energy conservation 

standards: 

– Lighting occupancy sensors and schedules controls. 

– Night curtains.

Item 3 - DOE requests comment on the burden to manufacturers 

associated with testing energy efficiency technologies other than 

those explicitly accounted for in this test procedure revision, 

namely night curtains and lighting occupancy sensors and 

scheduled controls. 

Testing of Energy Conservation Features
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Test Procedure Rulemaking Scope

• DOE understands that some commercial refrigeration equipment is designed to 

operate at more extreme ambient conditions.

– NSF (National Sanitation Foundation) Type II equipment is tested at 80 °F for 

food safety reasons.

• Commercial refrigeration equipment will operate differently whether tested at 

the ASHRAE Standard 72 75 °F / 55% RH standard rating condition or at more 

extreme conditions.

• DOE believes commercial refrigeration equipment designed to operate at more 

extreme ambient conditions can be tested at the standard rating conditions 

prescribed by DOE without any significant additional burden on manufacturers. 

Rating at Higher Ambient Temperatures

Item 2 - DOE requests comment on the burden to manufacturers associated with 

testing NSF Type II equipment at the standard test condition. Specifically, DOE 

requests comment and data on the ability of NSF Type II equipment to show 

compliance with DOE energy conservation standards when tested at the DOE 

standard rating condition. 
Building Technologies Program 23 eere.energy.gov

Test Procedure Rulemaking Scope

• EPCA directs DOE to incorporate a measure of standby and off mode energy 

use into the test procedures for consumer products. 

(42 U.S.C. 6295(gg)(3)(A))

• EPCA does not require DOE to incorporate a measure of such energy use into 

the test procedures for commercial and industrial equipment. 

• In addition, commercial refrigeration equipment generally operates constantly 

to maintain product at a desired temperature.

• Therefore, DOE does not consider a measure of standby and off mode energy 

use for commercial refrigeration equipment in the test procedure NOPR. 

Standby and Off Mode
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Proposed Test Procedure Amendments

Burden of Testing & Regulatory Review

Closing Remarks, Contacts & Information

Public Meeting Topics

4

5

6

2 Rulemaking History & Timelines 

3 Test Procedure Rulemaking Scope

1 Welcome, Introductions & Opening Remarks 
Building Technologies Program 25 eere.energy.gov

• DOE proposes amendments to its test procedure to: 

Proposed Test Procedure Amendments

1) Update referenced industry test procedures to the most current versions:

– AHRI Standard 1200-2010.

– AHAM Standard HRF-1-2008.

2) Incorporate provisions to address certain energy conservation features 

that are currently not accounted for in the DOE test procedure:

– Night curtains.

– Lighting occupancy sensors and scheduled controls.

3) Allow commercial refrigeration equipment that cannot be tested at the 

38 °F (±2 °F) rating temperature to be tested at its lowest application 

product temperature.
Building Technologies Program 26 eere.energy.gov

Proposed Test Procedure Amendments

• Since the publication of the 2006 test procedure 

Final Rule, AHRI and AHAM have updated their test 

procedures. The most recent versions are AHRI 

1200-2010 and AHAM Standard HRF-1-2008, which 

incorporate the following changes:

– AHRI 1200-2010

– changes in equipment class nomenclature, 

– method of normalizing energy consumption, 

and

– the ice-cream freezer test temperature.

– AHAM Standard HRF-1-2008

– reorganized some sections; however,

– content was not substantially changed.

Updated Industry Test Procedures
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Update Test Procedure References

• The updated AHRI Standard 1200-2010 has incorporated changes which align 

it with the current DOE test procedure.

• DOE proposes updating the current DOE test procedure to reference AHRI 

Standard 1200-2010 and AHAM Standard HRF-1-2008. 

Item 4 - DOE requests comment on updating the referenced industry test 

procedures to the most current versions.

Updated Test Procedure References
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Proposed Test Procedure Amendments

Night Curtains

• A night curtain is: 

– Designed to be used on an open case.

– Is typically made of an insulating material, for example insulated aluminum fabric.

– Is designed to be used when the merchandizing establishment is closed or the 

customer traffic is significantly decreased. 

– Decrease infiltration and conductive and radiative heat transfer into the case. 

Definition:

Night curtain means a device that is temporarily 

employed to decrease air exchange and heat transfer 

between the refrigerated case and the surrounding 

environment.

Additional Comment C - DOE requests comments on the proposed 

definition for night curtain.

Address Energy Conservation Features – Night Curtain Definition
Building Technologies Program 29 eere.energy.gov

Proposed Test Procedure Amendments

• It is important to capture the differences in energy use reduction from different 

night curtain designs because of the large performance disparities that can 

exist due to differences in: 

– emissivity of materials,

– insulating characteristics,

– night curtain design, 

– case dimensions, and

– default infiltration load.

• A physical test will accurately capture differences in the energy conservation 

utility of night curtains as a function of night curtain characteristics and case 

dimension. 

Night Curtains – Background and Approach
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Proposed Test Procedure Amendments

• DOE proposes to use the following test method, adapted from section 7.2 in 

ASHRAE Standard 72-2005, “Door-Opening Requirements”:

• 6-hour test period chosen to approximate the typical usage of a night curtain.

– Previously used in other studies.

– Accounts for stocking time.

Night Curtain Requirements. For open display cases sold with night 

curtains installed, the night curtain shall be employed according to 

manufacturer instructions for a total of 6 hours, 3 hours after the start of 

a defrost period. Upon the completion of the 6-hour period, the night 

curtain shall be raised until the completion of the 24-hour test period.

Night Curtain Proposed Test Method

Item 5 - DOE requests comment on the proposed incorporation of night 

curtains into the DOE test procedure. DOE is especially interested in the 

appropriateness of the proposed 6-hour test period when night curtains are 

deployed.
Building Technologies Program 31 eere.energy.gov

Proposed Test Procedure Amendments

Definitions:

Lighting control means an electronic device that automatically adjusts 

the lighting in a display case at scheduled times throughout the day. 

Lighting occupancy sensor means an electronic device that uses passive 

infrared, ultrasonic, or other motion-sensing technology to detect the 

presence of a customer or employee, allowing the lights within the 

equipment to be turned off or dimmed when no motion is detected in 

the sensor’s coverage area.

Additional Comment D - DOE requests comment on the proposed 

definitions for lighting occupancy sensor and lighting control.

Energy Conservation Features – Lighting Occupancy Sensor and 

Scheduled Controls
Building Technologies Program 32 eere.energy.gov

Proposed Test Procedure Amendments

• Unlike fluorescent lighting, LED lighting is more amenable to turn off/on under 

cold conditions and suitable for use with occupancy sensors.

• Energy reduction due to lighting occupancy sensors and scheduled controls is 

two-fold:

1) reduction in direct electricity consumption when lights are off or dimmed, 

and

2) reduction in heat load on the refrigeration system. 

• DOE proposes to use an analytical method to calculate decreased energy 

consumption due to the use of lighting occupancy sensors and scheduled 

controls to simplify testing requirements and minimize additional burden on 

manufacturers. 

Lighting Occupancy Sensor and Scheduled Controls –

Background and Approach
Building Technologies Program 33 eere.energy.gov

Proposed Test Procedure Amendments

• The proposed lighting occupancy sensor consists of 3 primary calculations: 

1. Calculate direct energy use of lighting with occupancy sensors or scheduled 

controls installed. 

– Requires default specifications for the time lighting is off or dimmed due to 

lighting occupancy sensors or scheduled controls.

2. Calculate reduced refrigeration load when energy use of lights within the 

refrigerated volume is decreased. 

– Requires default specifications for the EER of the compressor and to account for 

the fact that not all of the heat produced from the lights will impact the 

compressor load.

3. Calculate the adjusted daily energy consumption based on the decreased 

lighting energy use and decreased compressor energy use. 

Lighting Occupancy Sensor and Scheduled Controls –

Proposed Test Method
Building Technologies Program 34 eere.energy.gov

Proposed Test Procedure Amendments

• The time off period for scheduled controls was chosen to approximate the typical usage 

of lighting control products based on comments received during previous DOE 

rulemakings for this equipment.

• The time off period for lighting occupancy sensors was derived based on the previously 

cited demonstration project conducted through the DOE GATEWAY program.

Case has...

Only scheduled 

lighting controls 

installed

Only lighting 

occupancy sensors

installed

Both lighting 

occupancy sensors 

and scheduled 

controls installed

Times are... toff,controls + tdim,controls= 

8 hours

toff,sensors + 

tdim,sensors= 10.8 hours

toff,controls + 

tdim,controls= 8 hours

AND

toff,sensors + 

tdim,sensors= 2.8 hours

Determination of toff and tdim
Building Technologies Program 35 eere.energy.gov

Proposed Test Procedure Amendments

• Note: The CECA includes a multiplication factor of 0.75 to account for the fact that not all of the heat 

produced from the lights will impact the compressor load. 

li l

sc

A

(P t

1000 3.4121 (LEC )

CEC 0.75 EER

× ) × −

= × Eq. 4

Operating Temperature Class EER1,2

Btu/W

Medium 11.26

Low 7.14

Ice Cream 4.80

Note:

1. EER values for operating temperature classes are calculated based on 

the average EER value of all equipment in that class which was analyzed 

as part of the previous (2009) rulemaking. 

2. These values only represent compressor EER and do not include 

condenser fan energy use. 

• EER for Self-Contained Commercial Refrigerated Display Merchandisers and Storage Cabinets

Calculation of Alternate Compressor Energy Consumption

• EER for Remote Condensing Commercial Refrigerated Display Merchandisers and Storage Cabinets

= Table 1. in AHRI 1200-2010
Building Technologies Program 36 eere.energy.gov

Proposed Test Procedure Amendments

Item 6 - DOE requests comment on the proposed calculation method for 

treatment of lighting occupancy sensors and controls in the DOE test 

procedure for commercial refrigeration equipment. Specifically, DOE 

requests comment on the values assumed for the time period when 

lighting is off or reduced due to lighting occupancy sensors or controls and 

the factor used to scale the amount of heat produced by case lighting. 

Request for Comment
Building Technologies Program 37 eere.energy.gov

Proposed Test Procedure Amendments

• In the 2009 rulemaking, DOE found that only 1.7 percent of units under that 

rulemaking operated at temperatures other than the prescribed test 

temperatures, or “application product temperatures.”

– Of these, units that operated at 45 °F had the highest shipments. 

– Because of the low volume of shipments, DOE decided not to develop 

separate standards for this equipment. 72 FR 41162, 41168−69 (July 26, 

2007).

• At the Framework document public meeting, DOE received comments 

recommending the inclusion of “application temperatures” for the rating of 

commercial refrigeration equipment.

Testing at Lowest Application Product Temperature – Comments 

Received
Building Technologies Program 38 eere.energy.gov

Proposed Test Procedure Amendments

• DOE understands that some equipment covered under this rulemaking is 

designed to operate at significantly higher temperatures (45, 55, or 60 °F) 

and may not be able to maintain an integrated average product temperature 

of 38 °F (±2 °F).

– Most of this equipment is self-contained equipment.

– Self-contained medium-temperature equipment was not covered in 

the 2009 rulemaking.

– Self-contained equipment is covered in the scope of the concurrent 

ECS and the test procedure rulemaking.

• AHRI Standard 1200-2010 has provisions for testing equipment at the 

application product temperature. 

Lowest Application Product Temperature – Background
Building Technologies Program 39 eere.energy.gov

Proposed Test Procedure Amendments

• However, equipment that operates at temperatures greater than the 

38 °F (±2 °F) rating temperature: 

– may operate more efficiently if tested at temperatures other than 38 °F (±2 

°F), and 

– may represent a large enough shipment volume to warrant separate 

consideration.

• DOE proposes including a provision for rating refrigerators that cannot operate 

at the prescribed 38 °F (±2 °F) integrated average product temperature at the 

lowest application product temperature.

Lowest Application Product Temperature Rating
Building Technologies Program 40 eere.energy.gov

Proposed Test Procedure Amendments

Definition:

Lowest application product temperature means the lowest 

integrated average product temperature achievable and 

maintainable within ± 2 °F for the duration of the test. 

Item 7 - DOE requests comment on the provision for testing commercial 

refrigerators that cannot be tested at 38 °F (±2 °F) at the lowest 

application product temperature. 

• When testing a case using the lowest application product temperature, the 

integrated average product temperature achieved during the test should be 

recorded and reported with energy consumption information. 

• Equipment tested at the lowest application product temperature will still be 

required to comply with the applicable energy conservation standard for its 

respective medium-temperature equipment class.

Lowest Application Product Temperature Definition
Building Technologies Program 41 eere.energy.gov

Proposed Test Procedure Amendments

Burden of Testing & Regulatory Review

Closing Remarks, Contacts & Information

Public Meeting Topics

4

5

6

2 Rulemaking History & Timelines 

3 Test Procedure Rulemaking Scope

1 Welcome, Introductions & Opening Remarks 
Building Technologies Program 42 eere.energy.gov

• DOE understands that amending the test procedures to incorporate the 

proposed changes and additions could increase the burden on manufacturers 

to quantify the performance of their equipment. 

• EPCA requires that the test procedures promulgated by DOE be reasonably 

designed to produce test results that reflect energy efficiency, energy use, and 

estimated operating costs of the covered equipment during a representative 

average use cycle and not be unduly burdensome to conduct. (42 U.S.C. 

6314(a)(2)) 

Burden of Testing & Regulatory Review

Background
Building Technologies Program 43 eere.energy.gov

• All commercial refrigeration equipment is currently required to be tested using 

the DOE test procedure.

• The updated versions of AHRI Standard 1200-2010 and AHAM 

HRF-1-2008 do not vary substantially from the previously referenced versions.

Burden of Testing & Regulatory Review

Current Proposed

Referenced Industry Test 

Procedures

AHRI Standard 1200-2006 

AHAM HRF-1-2004

AHRI Standard 1200-2010 

AHAM HRF-1-2008

Burden One 24-hour test One 24-hour test

Current Burden of Test
Building Technologies Program 44 eere.energy.gov

• For equipment that has the option of being sold with night curtains or lighting 

occupancy sensors or controls installed, additional testing may be required.

• The following table shows an example for night curtains:

Burden of Testing & Regulatory Review

Burden of Test – Energy Conservation Features

Case is only sold 

with night 

curtains

Case is only sold 

without night 

curtains

Case is sold both with and 

without night curtains

Number 

of Tests ONE ONE

•If complies with ECS w/o night 

curtains ONE

•If does not comply with ECS w/o 

night curtains but does comply 

with night curtains TWO 
Building Technologies Program 45 eere.energy.gov

Proposed Test Procedure Amendments

• Since the same test is being performed in both cases, DOE believes that this 

will not increase the burden of test for those manufacturers and is likely to 

lead to more representative energy consumption values. 

Current Proposed

Referenced Industry Test 

Procedures

AHRI Standard 1200-2006 

AHAM HRF-1-2004

AHRI Standard 1200-2010 

AHAM HRF-1-2009

Burden One 24-hour test One 24-hour test

Temperature 38 °F (±2 °F) Lowest application product 

temperature

Burden of Test – Lowest Application Product Temperature
Building Technologies Program 46 eere.energy.gov

Burden of Testing & Regulatory Review

Item 1 - DOE requests comment on its conclusion that the proposed test 

procedure amendments would not be unduly burdensome to conduct. 

• The proposed changes to the test procedure for commercial refrigeration 

equipment were chosen to help minimize the impact of additional testing.

• For the reasons stated previously, DOE believes that the proposed amended 

test procedures would not be unduly burdensome to conduct. 

Proposed Burden of Test and Request for Comment
Building Technologies Program 47 eere.energy.gov

Burden of Testing & Regulatory Review

Item 8 - DOE seeks comments on the number of small businesses in the 

CRE market.

• DOE has used the SBA definition of small entities:

– Commercial Refrigeration manufacturers are included in NAICS 333415, 

“Air-Conditioning and Warm Air Heating Equipment and Commercial and 

Industrial Refrigeration Equipment Manufacturing.”

– The Small Business Administration standard for small entities in this 

industry description is < 750 employees.

• DOE found 22 manufacturers of commercial refrigeration equipment that 

qualify as small businesses.

DOE must determine whether the rule would result in a 

significant impact on a substantial number of small entities. 

Review Under the Regulatory Flexibility Act
Building Technologies Program 48 eere.energy.gov

Burden of Testing & Regulatory Review

• Impacts are associated with the cost of testing and length of time it takes to 

perform the tests.

• DOE quantified the impact on manufacturers by assessing the incremental 

increase in cost of testing compared to the annual average value added.

– Cost of testing estimated as $5,000 and one week of laboratory time per 

unit to perform AHRI 1200-2010. 

– Annual average value added is the cost of materials, supplies, containers, 

fuel, purchased electricity, and contract work subtracted from the cost of 

shipments. 

Definitions and Assumptions
Building Technologies Program 49 eere.energy.gov

Burden of Testing & Regulatory Review

• Measures that may affect burdens include:

– Provisions for testing cases with night curtains.

• Measures that are not expected to affect burdens include:

– Updating DOE test procedure references to AHRI 1200-2010 and AHAM 

HRF-1-2008.

– Equivalent to current burden of test.

– Provisions for testing cases with occupancy sensors.

– Minimal increase due to additional calculations.

– Provisions for testing cases at temperatures greater than 38 F (±2 °F).

– Equivalent to current burden of test. 

Assessment of Burden
Building Technologies Program 50 eere.energy.gov

• Number of open cases 

– DOE found that the larger manufacturers sell more open cases than smaller 

manufacturers.

– DOE estimates that for both small and large manufacturers who offer open cases, 

open cases that could be sold with night curtains comprised 20 percent of total 

models (between 1 and 50 models).

– A single small manufacturer produces majority of all open cases produced by small 

manufacturers.

• Number of additional tests that will be performed

– Units that are compliant without optional night curtains installed do not require 

additional testing with night curtains installed.

– Half of the cases will require two tests.

• Costs associated with extra test

– DOE found the incremental cost of running the extra tests ranged from 

approximately 0.3 to 0.6 percent of annual average value added. 

Burden of Testing & Regulatory Review

Potential Burden Due to Night Curtain Provision Based on:
Building Technologies Program 51 eere.energy.gov

• Aligning DOE test procedure with industry standards AHRI 1200-2010 and 

AHAM HRF-1-2008.

– Should not increase burden due to similar testing requirements.

• Provisions for testing cases with occupancy sensors.

– Calculation methodology does not require additional testing.

– Manufacturers only required to show compliance of units with lighting occupancy 

controls installed if unit without controls is noncompliant.

– DOE estimates a 15 percent increase in calculation intensity, which corresponds to 

<0.01 percent increase in total burden or $50 per unit.

– If additional calculation required for 50 percent of units, the total incremental 

increase in cost of testing will range from $50 to $6,500, or < 0.0005 percent of the 

annual average value added for all CRE manufacturers.

• Provisions for testing cases at temperatures greater than 38 °F (±2 °F).

– With identical 24-hour test, DOE believes that this will not increase the burden of 

test.

Burden of Testing & Regulatory Review

Potential Burden Due to Other Provisions:
Building Technologies Program 52 eere.energy.gov

Burden of Testing & Regulatory Review

Item 9 - DOE seeks comment on its certification that the 

proposed test procedure changes will not have a significant 

impact on a substantial number of small entities.

Request for Comment
Building Technologies Program 53 eere.energy.gov

Proposed Test Procedure Amendments

Burden of Testing & Regulatory Review

Closing Remarks, Contacts & Information

Public Meeting Topics

4

5

6

Rulemaking History & Timelines 2

3 Test Procedure Rulemaking Scope

1 Welcome, Introductions & Opening Remarks 
Building Technologies Program 54 eere.energy.gov

Closing Remarks, Contacts & Information

At this time DOE welcomes any closing remarks 

from interested parties.
Building Technologies Program 55 eere.energy.gov

Closing Remarks, Contacts & Information

Please reference all correspondence for this rulemaking with the following information:

– Title: Commercial Refrigeration Equipment Rulemaking,

– Docket Number: EERE-2010-BT-TP-0034, and

– Regulatory Identification Number: RIN 1904-AC40

Email: CRE-2010-TP-0034@ee.doe.gov

Postal Mail: Hand Delivery or Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Mailstop: EE-2J, Room 1J-018

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 6th Floor

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202-586-2945

Comment period ends: January 24, 2011

CRE TP Comment Submittal Information
Building Technologies Program 56 eere.energy.gov

Closing Remarks, Contacts & Information

• DOE Appliance Standards

– http://www1.eere.energy.gov/buildings/appliance_standards/

• Commercial Refrigeration Equipment Rule

– http://www2.eere.energy.gov/buildings/appliance_standards/commercial/refriger

ation_equipment.html

• Contact Charles Llenza, Project Manager, from the Appliance Standards Program for 

additional information: 

– Charles.Llenza@ee.doe.gov

– 202.586.2192

• Contact John Cymbalsky, Supervisor, from the Appliance Standards Program for 

additional information: 

– John.Cymbalsky@ee.doe.gov

– 202.287.1692

CRE TP WebPages and DOE Contacts
Building Technologies Program 57 eere.energy.gov

Back Up Slides
Building Technologies Program 58 eere.energy.gov

Lighting Occupancy Sensors and 

Scheduled Controls – Variables

CECA = the alternate compressor energy consumption (kilowatt-hours); 

LECsc = the lighting energy consumption of internal case lights with lighting occupancy sensors and 

controls deployed (kilowatt-hours);

Pli = the rated power of lights when they are fully on (watts); 

Pli(off) = the power of lights when they are off (watts);

Pli(dim) = the power of lights when they are dimmed (watts);

TDECo = the total daily energy consumption with lights fully on, as measured by AHRI Standard 1200-

2010 (kilowatt-hours);

tdim = the time period which the lights are dimmed due to the use of lighting occupancy sensors or 

scheduled controls (hours);

tdim,controls = the time case lighting is dimmed due to the use of lighting controls (hours); 

tdim,sensors= the time case lighting is dimmed due to the use of lighting occupancy sensors (hours);

tl = the time period when lights would be on without lighting occupancy sensors or controls (24 

hours); 

toff = the time period which the lights are off due to the use of lighting occupancy sensors or 

scheduled controls (hours); 

toff,controls = the time case lighting is off due to the use of lighting controls (hours);

toff,sensors = the time case lighting is off due to the use of lighting occupancy sensors (hours); and

tsc = the time period when lighting is fully on with lighting occupancy sensors and controls 

enabled (hours).
Building Technologies Program 59 eere.energy.gov

Lighting Occupancy Sensors and Controls 

– Proposed Test Method

1) Calculate energy use of lighting within the refrigerated volume.

• DOE proposes to use an analytical method similar to equation 4, section 

5.2.3 of AHRI Standard 1200-2010:

Where:

LECsc = lighting energy consumption of internal case lights with lighting occupancy sensors and 

controls deployed (kilowatt-hours);

Pli = rated power of lights when they are fully on (watts); 

Pli(off) = power of lights when they are off (watts);

Pli(dim) = power of lights when they are dimmed (watts);

tsc = time period when lighting is fully on with lighting occupancy sensors and controls 

enabled (hours);

toff = time period which the lights are off due to the use of lighting occupancy sensors or 

scheduled controls (hours); and

tdim = time period which the lights are dimmed due to the use of lighting occupancy sensors or 

scheduled controls (hours).

( ) ( ( ( ) ) ( ( ) ))

( )

li sc li off off li dim dim

sc

P t P t P t

LEC

1000

×+ ×+ ×

= Eq. 1
Building Technologies Program 60 eere.energy.gov

Lighting Occupancy Sensors and Controls –

Proposed Test Method (cont.)

• The time the case lighting is dimmed or off will be calculated as follows:

Where:

toff = time period which the lights are off due to the use of lighting occupancy sensors or 

scheduled controls (hours); 

tdim = time period which the lights are dim due to the use of lighting occupancy sensors or 

scheduled controls (hours);

toff,controls = time case lighting is off due to the use of lighting controls (hours);

tdim,controls = time case lighting is dimmed due to the use of lighting controls (hours); 

toff,sensors = time case lighting is off due to the use of lighting occupancy sensors (hours); and

tdim,sensors= time case lighting is dimmed due to the use of lighting occupancy sensors (hours). 

off off ,sensors off ,controls

dim dim,sensors dim,controls

t t t

t t t

= +

= + Eq. 2
Building Technologies Program 61 eere.energy.gov

Lighting Occupancy Sensors and Controls –

Proposed Test Method (cont.)

• The time the case lighting is fully on with lighting occupancy sensors and 

controls enabled during the 24-hour test will be calculated as follows:

Where:

toff = time period which the lights are off due to the use of lighting occupancy sensors or scheduled 

controls (hours); 

tdim = time period which the lights are dim due to the use of lighting occupancy sensors or 

scheduled controls (hours);

tsc = time period when lighting is fully on with lighting occupancy sensors and controls enabled 

(hours);

tl = time period when lighting would be on without lighting occupancy sensors or controls (24 

hours); with the sum of all toff and tdim from both lighting occupancy sensors and controls 

not to exceed 10.8 hours. 

sc l off dim t =− − t t t Eq. 3
Building Technologies Program 62 eere.energy.gov

Example Lighting Calculation

• Example for a case where lighting that is dimmed throughout the day by occupancy sensors 

and is turned off completely by scheduled controls during closing hours:

l

off,sensors

dim,sensors

off,controls

dim,controls

off off ,sensors off ,controls

dim dim,sensors dim,controls

24 hours

0

2.8 hours

8 hours

0

 = 0 + 8 hours = 8 hours

 = 2.8 hours + 0 = 2.8 hour

t

t

t

t

t

t t t

t t t

= +

= +

=

=

=

=

=

sc l off dim

s

t =− − t t t = 24 hours - 8 hours - 2.8 hours = 13.2 h s our

( ) ( ( ( ) ) ( ( ) ))

( )

li sc li off off li dim dim

sc

P t P t P t

LEC

1000

×+ ×+ ×

= Eq. 1
Building Technologies Program 63 eere.energy.gov

Lighting Occupancy Sensors and Controls –

Proposed Test Method (cont.)

2) Calculate decreased energy use from reduction in heat load from lights that 

are located inside the refrigerated volume.

• For remote condensing and self-contained equipment, a modified calculation of 

“Alternate Components Indirect Effects” from section 5.4.2 of AHRI 1200-2010 can 

be applied:

Where:

CECA= alternate compressor energy consumption (kilowatt-hours); 

LECsc = lighting energy consumption of internal case lights with lighting occupancy sensors and 

controls deployed (kilowatt-hours);

Pli = rated power of lights when they are fully on (watts); 

tsc = time period when lighting is fully on with lighting occupancy sensors and controls 

enabled (hours);

tl = time lighting would be on without lighting occupancy sensors or controls (24 hours); and

EER = energy efficiency ratio from Table 1 in AHRI Standard 1200-2010 for remote condensing 

equipment and the values shown in the following table for self-contained equipment 

(British thermal units/watt).

sc li l

A

3.4121 (LEC P t /1000) CEC 0.75 EER× −×

= × Eq. 4
Building Technologies Program 64 eere.energy.gov

Calculation of Alternate Compressor Energy 

Consumption

• Note: The CECA includes a multiplication factor of 0.75 to account for the fact that not all 

of the heat produced from the lights will impact the compressor load. 

li l

sc

A

(P t

1000 3.4121 (LEC )

CEC 0.75 EER

× ) × −

= × Eq. 4

Operating Temperature Class EER

Btu/W

Medium 11.26

Low 7.14

Ice Cream 4.80

Note:

1. EER values for operating temperature classes are calculated based on the average EER value of all 

equipment in that class which was analyzed as part of the previous (2009) rulemaking. This does not 

include equipment for which standards were set by Congress in EPACT 2005 (VCT, VCS, HCT, HCS, and 

SOC at M and L temperatures) or classes for which standard were set using extension multipliers in 

the 2009 rulemaking (VOP.SC.L, SVO.SC.L, VOP.SC.I, SVO.SC.I, HZO.SC.I, VOP.SC.I, SVO.SC.I, HZO.SC.I, 

HCS.SC.I, SOC.SC.I).

2. These values only represent compressor EER and do not include condenser fan energy use. 

EER for Self-Contained Commercial Refrigerated Display 

Merchandisers and Storage Cabinets
Building Technologies Program 65 eere.energy.gov

Calculation of Daily Energy Consumption 

– Remote Condensing

• Different calculations for remote condensing and self-contained equipment:

A. For remote condensing equipment

– Can continue to apply AHRI Standard 1200-2010, section 5.4, “Alternate 

Component Indirect Effects”:

Where:

CECR = reduced compressor energy consumption (kilowatt-hours); 

CEC = compressor energy consumption as measured by AHRI Standard 1200 

(kilowatt-hours); and

CECA = alternate compressor energy consumption (kilowatt-hours).

CEC CEC CEC R A = + Eq. 5
Building Technologies Program 66 eere.energy.gov

Calculation of Daily Energy Consumption –

Remote Condensing (cont.)

– Substitute CECR and LECsc to calculate combined daily energy consumption 

(CDEC):

Where:

CDEC = combined daily energy consumption (kilowatt-hours); 

CECR = reduced compressor energy consumption (kilowatt-hours);

FEC = fan energy consumption (kilowatt-hours);

LECsc = lighting energy consumption with lighting sensors and controls deployed 

kilowatt-hours);

AEC = anti-condensate energy consumption (kilowatt-hours);

DEC = defrost energy consumption (kilowatt-hours); and

PEC = condensate evaporator pan energy consumption (kilowatt-hours). 

CDEC= ++ + + + CECR FEC LECsc AEC DEC PEC Eq. 6
Building Technologies Program 67 eere.energy.gov

Calculation of Daily Energy Consumption 

– Self-Contained

• Different calculations for remote condensing and self-contained equipment:

B. For self-contained equipment

– CECA and LECsc used directly with the total daily energy consumption (TDEC) as 

measured by AHRI Standard 1200-2010 with the lights fully on:

Where:

TDECo = total daily energy consumption with lights fully on, as measured by AHRI Standard 

1200-2010 (kilowatt-hours);

Pli = rated power of lights when they are fully on (watts);

tl = time period when lights would be on without lighting occupancy sensors or controls 

(24 hours); 

CECA = alternate compressor energy consumption (kilowatt-hours); and

LECsc = lighting energy consumption with lighting occupancy sensors and controls deployed 

(kilowatt-hours).

li l

o A sc

(P t ) TDEC TDEC CEC L EC 1000

  ×

= +− −     Eq. 7
Building Technologies Program 68 eere.energy.gov

• For equipment that has the option of being sold with night curtains or lighting 

occupancy sensors or controls installed, additional testing may be required:

• Additionally, cases sold ONLY with night curtains or lighting occupancy sensors 

installed will only require one test. 

Proposed Test Procedure Amendments

1. Test case without night 

curtains or lighting 

occupancy sensors or 

controls installed.

2. Test case with night 

curtains or lighting 

occupancy sensors or 

controls installed. 

Only this test is necessary to show 

compliance with DOE energy 

conservation standards.

Case can be sold with or without 

night curtains/lighting occupancy 

sensors controls.

IIf passes

IIf fails

IIf passes

Two tests are required to show 

compliance with DOE energy 

conservation standards.

Case can ONLY be sold in 

configuration that meets ECS.

Burden of Test – Energy Conservation Features
Building Technologies Program 69 eere.energy.gov

Requests for Comment in TP NOPR

Item 1 - DOE requests comment on its conclusion that the proposed test procedure amendments 

would not be unduly burdensome to conduct. 

Item 2 - DOE requests comment on the burden to manufacturers associated with testing NSF Type II 

equipment at the standard test condition. Specifically, DOE requests comment and data on 

the ability of NSF Type II equipment to show compliance with DOE energy conservation 

standards when tested at the DOE standard rating condition. 

Item 3 - DOE requests comment on the burden to manufacturers associated with testing energy 

efficiency technologies other than those explicitly accounted for in this test procedure 

revision, namely night curtains and lighting occupancy sensors and scheduled control. 

Item 4 - DOE requests comment on updating the referenced industry test procedures to the most 

current versions. 

Item 5 - DOE requests comment on the proposed incorporation of night curtains into the DOE test 

procedure. DOE is especially interested in the appropriateness of the proposed 6-hour test 

period when night curtains are deployed. 

Item 6 - DOE requests comment on the proposed calculation method for treatment of lighting 

occupancy sensors and controls in the DOE test procedure for commercial refrigeration 

equipment. 

Item 7 - DOE seeks comments on the number of small businesses in the CRE market.

Item 8 - DOE seeks comment on its certification that the proposed test procedure changes will not 

have a significant impact on a substantial number of small entities.
Building Technologies Program 70 eere.energy.gov

Additional TP NOPR Comments 

Additional Comment A - DOE welcomes comment on the effective date 

of the test procedure Final Rule. 

Additional Comment B - DOE welcomes on the coverage of secondary 

coolant systems in the DOE test procedure. 

Specifically, DOE requests comment on if the 

DOE test procedure should include secondary 

coolant systems and, if so, how the testing of this 

could be accommodated in the DOE test 

procedure. 

Additional Comment C - DOE requests comment on the proposed 

definition for night curtain.

Additional Comment D - DOE requests comment on the proposed 

definition for lighting occupancy sensor.