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Miscellaneous Refrigeration Products Working Group Negotiations May 4
- 5, 2015 Joseph Hagerman Department of Energy Building Technologies Program2 

### Background

• DOE published a Notice of Public Meeting and preliminary technical s upport document (preliminary TSD) for energy c onservation s tandards for miscellaneous r efrigeration ( MRef ) products on December 3, 2014 (79 FR 71705).

• DOE published a test procedure Notice of Proposed Rulemaking (NOPR) for these products on December 16, 2014 (79 FR 74893).

• On April 1, 2015, DOE published a notice of intent to seek nominations for the formation of this working group to negotiate the energy conservation standards and test procedures for MRef products (80 FR 17355).3 

### Scope & Definitions: Product Categories4 

### Preliminary Analysis Proposal – Product Categories

• DOE proposed multiple definitions to refer to both groups of products and individual product categories.

Consumer Refrigeration Products
Refrigerators, Refrigerator

Freezers, or Freezers* Miscellaneous Refrigeration Products

Cooled Cabinets Non
- Compressor Refrigerators

Hybrid Products Ice Makers * DOE did not propose new definitions for refrigerators, refrigerator

- freezers, or freezers, but did propose clarifications to better differentiate between these and the newly defined MRef products.5 

### Preliminary Analysis Proposal – Product Categories

• Consumer Refrigeration Product

• A refrigerator

, refrigerator

- freezer, freezer, or miscellaneous refrigeration product.

• Refrigerator

, refrigerator

- freezer, and freezer

• DOE proposed amendments to the existing refrigerator, refrigerator

- freezer, and freezer definitions to have a consistent structure with the newly proposed product definitions, and to improve clarity for distinguishing between the products.

• Added clarification that the products are capable of maintaining compartment temperatures in a 72 ° F ambient.

• Excluded products with characteristics typical of commercial refrigeration equipment:

• Permanently open compartments, separate compressors or condensers, and certification to ANSI/NSF 7

- 2009 or ANSI/UL 471

- 20066 

### Preliminary Analysis Proposal – Product Categories

• DOE proposed the following definitions for MRef products : Miscellaneous refrigeration product: A consumer refrigeration product other than a refrigerator, refrigerator

- freezer, or freezer, which includes hybrid refrigeration products, cooled cabinets, non

- compressor refrigerators, and ice makers.7 

### Preliminary Analysis Proposal – Product Categories Cooled cabinet: A cabinet that has a source of refrigeration requiring electric energy input only and is capable of maintaining compartment temperatures either (a) no lower than 39 ° F (3.9 ° C), or (b) in a range that extends no lower than 37 ° F (2.8 ° C) but at least as high as 60 ° F (15.6 ° C) as determined according to the provisions in § 429.61(c)(2 ) [determined in a 72 ° F ambient temperature].8 

### Preliminary Analysis Proposal – Product Categories Hybrid refrigeration product: A hybrid refrigerator, hybrid refrigerator

- freezer, hybrid freezer, or hybrid non

- compressor refrigerator
. Generally for hybrid products, at least half but not all of the product’s refrigerated volume comprises one or more cellar compartments . The remaining product compartments would satisfy the definitions for refrigerator, refrigerator

- freezer, freezer, or non - compressor refrigerator.9 

### Preliminary Analysis Proposal – Product Categories Non
- compressor refrigerator: A cabinet that has a source of refrigeration that does not include a compressor and condenser unit, requires electric energy input only, and is capable of maintaining compartment temperatures above 32 ° F (0 ° C) and below 39 ° F (3.9 ° C ).
Non
- compressor cooled cabinet: A cooled cabinet that has a source of refrigeration that does not include a compressor and condenser unit.10 

### Preliminary Analysis Proposal – Product Categories Ice maker: A consumer product other than a refrigerator, refrigerator

freezer, freezer, hybrid refrigeration product, non

- compressor refrigerator, or cooled cabinet designed to automatically produce and harvest ice, but excluding any basic model that is certified under NSF/ANSI 12

- 2012 Automatic Ice Making Equipment. Such a product may also include a means for storing ice, dispensing ice, or storing and dispensing ice.11 

### Stakeholder Feedback – Product Categories

• Some stakeholders commented that the proposed definitions required further clarification so as not to allow the use of ANSI, NSF, and UL standards for food storage equipment to be used as a loophole to avoid coverage.

• One stakeholder noted that the range of products covered by this rule are not one type of consumer product, but are designed and marketed for very different purposes
.12 

### Stakeholder Feedback – Product Categories

• Stakeholders commented that the 50% cellar compartment threshold to differentiate hybrid products from other consumer refrigeration products is an arbitrary cutoff.

• Many stakeholders commented to oppose DOE’s grouping of ice makers with the other MREF products. They stated that ice makers serve a different consumer need and are sufficiently different in their operation from the other product categories that grouping them is not appropriate
.13 

### Stakeholder Feedback – Product Categories

• One stakeholder pointed out that the product definitions, and the standard, as proposed only cover electricity usage, whereas many of these products
– especially ice

- makers
– also use large volumes of water.

• Commenters objected to using this rulemaking to amend definitions for residential refrigerator/freezers because those amendments would effectively amend coverage and standards for certain products.14 

### Key Issues – Product Categories

• Do the definitions of each product category need to be amended in any way?

• How would definitions for these products be amended to best differentiate between consumer products and commercial equipment?

• Is the 72 ° F ambient temperature appropriate for determining the compartment temperatures products are capable of maintaining for the purposes of product classification?

• Are any clarifications needed to better differentiate between the non

- ice maker product categories?15 

### Scope & Definitions: Product Classes16 

### Preliminary Analysis Proposal – Product Classes In the preliminary analysis, DOE proposed the following product classes for MRef products: Product Category Product Classes Cooled Cabinets Single product class. Non
- Compressor Refrigerators Single product class. Hybrid Products 40 product classes analogous to the product classes for

refrigerators, refrigerator
– freezers, and freezers. However, DOE is aware of hybrid products available on the market in only four out of these forty product classes. Ice Makers  Uncooled Storage

 Cooled Storage  Portable17 

### Preliminary Analysis Proposal – Product Classes

• DOE identified the following hybrid product classes during the preliminary analysis:

Hybrid Refrigeration Products H
- 3A
- BI Built

- in standard

- sized* hybrid all

- refrigerators with automatic defrost H
- 9I
- BI Built

- in standard

- sized hybrid freezers with automatic defrost and an automatic icemaker H
- 11A Compact* hybrid all

- refrigerators with manual defrost H
- 13A Compact hybrid all

- refrigerators with automatic defrost * Note: “Compact” products are defined as having a total compartment volume of less than 7.75 cubic feet; for compartment sizes larger than this, the term “standard

- sized” is used.18 

### Preliminary Analysis Proposal – Product Classes

• DOE proposed the following definitions for ice maker product classes: Portable ice maker
– An ice maker that does not require connection to a household water supply for operation and is operable using one or more on

- board reservoirs that must be manually supplied with water
. Uncooled

- storage ice maker
– An ice maker that does not maintain ice storage bin temperatures below 32 ° F
. Cooled

- storage ice maker
– An ice maker that maintains ice storage bin temperatures below 32 ° F.19 

### Stakeholder Feedback – Product Classes

• Several stakeholders expressed agreement with DOE’s definitions and proposed product classes for MRef products.

• Some stakeholders commented that cooled cabinets required multiple product classes

• One commented that thermo

- electric cooled cabinets serve a specific utility.

• Others commented that cooled cabinets should be separated into standard/compact and built

- in/freestanding product classes.

• Stakeholders noted that ice makers for ‘clear ice’ could require a separate product class.20 

### Stakeholder Feedback – Product Classes

• Some stakeholders questioned DOE’s mapping of Hybrid product classes to existing refrigerator/refrigerator

- freezer product classes, noting that of the forty classes thus defined, very few are actually currently on the market.

• Further, stakeholders noted that it may be better to divide hybrids into product classes based on the type of cellar compartment door, or on the percentage of the total volume dedicated to cellar compartments.21 

### Key Issues – Product Classes

• Is there a need to adjust the product classes DOE analyzed in the preliminary analysis?

• If so, what is the unique feature or consumer utility and the associated energy impact for each of the potential product classes?

• How would these product classes be defined to clearly differentiation between the different product classes?

• Note: any major revisions to the proposed product class structure would require new standards analysis on the updated product class structure.22 

### Test Procedures23 

### Background

• DOE published a Test Procedure NOPR in December 2014 ( 79 FR 74893 ) and based the preliminary analysis for energy conservation standards o n these proposed test procedures.

• DOE proposed that the test procedures for cooled cabinets, hybrid refrigerators, and NCRs be incorporated into the existing test procedures for refrigerators and refrigerator

freezers, and freezers in 10 CFR part 430 Appendix A and Appendix B, with adjusted ambient temperatures and usage factors as appropriate.

• DOE proposed a separate test procedure for ice makers due to the different measurements necessary to measure ice production rather than cooled air.24 

### Test Procedures: Ambient Temperatures25 

### NOPR Proposal – Ambient Temperatures

• For the MRef test procedures incorporated into Appendix A and Appendix B, DOE recommended a 90 o F ambient test temperature, consistent with the method for refrigerators, refrigerator

- freezers, and freezers.

• However, DOE proposed that the ambient test temperature be set at 72 o F for non

- compressor cooled cabinets.

• DOE selected 72 o F in this case because the thermoelectric cooled cabinets were unable to meet compartment temperatures of 55 o F at a 90 o F ambient, leading to unrepresentative energy use results.

• For ice makers, DOE also proposed testing in a 72 o F ambient due to fewer door openings and the lack of cooling warm food loads in these products.26 

### NOPR Proposal – Ambient Temperatures

• For NCRs, DOE similarly observed that many are not capable of maintaining refrigerator temperatures (39 o F ) in the 90 o F ambient.

• DOE proposed that for those NCRs unable to achieve and maintain compartment temperatures at 90 o F , the results of the cold setting test be used for the overall test result, and that the lowest compartment temperatures maintained at the cold setting be reported (if above 39 o F ).

• For other product types (other than ice makers) not able to maintain compartment temperatures at 90 o F , DOE proposed an extrapolation approach similar to that included in the previous Appendix A1.27 

### Stakeholder Feedback – Ambient Temperatures

• Some interested parties supported testing all products covered under this rulemaking in 72 o F ambient conditions, while others supported a 90 ° F ambient temperature for all products.

• Stakeholders commented that a lower ambient temperature is appropriate for ice makers, but 70 o F may be more appropriate than the proposed 72 o F
.

• Certain commenters expressed opposition to the linear extrapolation approach for products not able to maintain compartment temperatures at the 90 o F ambient.28 

### Key Issues – Ambient Temperatures

• Should the ambient test temperatures for any of the products be amended? If so, what temperatures would be more representative?

• How should the test procedure address units that are unable to maintain standardized compartment temperatures at a 90 ° F ambient temperature?

• For NCRs, is the approach of taking the results of the cold setting appropriate for products unable to maintain the 39 ° F compartment temperature? If not, should these products be tested at a 72 ° F ambient, or should the extrapolation approach be applied?29 

### Test Procedures: Usage Factors30 

### NOPR Proposal – Usage Factors

• For vapor
- compression cooled cabinets, DOE proposed a usage factor of 0.55 to address the over

- estimation of energy use associated with 90 ° F ambient testing, based on:

• The 0.46 ratio between measured energy use at 72 ° F and 90 ° F observed in closed door testing, and

• A 1.2 usage factor used to represent additional thermal loads, such as door openings or loading warm items (0.46 × 1.2=0.55).

• For non
- compressor cooled cabinets, DOE proposed a usage factor of 1.2 (i.e., only the thermal load adjustment) because these products would be tested at a 72 ° F ambient.

• For NCR’s, DOE proposed a usage factor of 1.0, consistent with the usage factors in the existing refrigerators test procedure.31 

### NOPR Proposal – Usage Factors

• For hybrid products, DOE proposes a usage adjustment factor of 0.85.

• Because at least half of the refrigerated volume of these products is occupied by the cellar compartment, which is often for wine storage, DOE believes that the door opening frequency for these products would be closer to cooled cabinets than for refrigerators
. • However, the 0.85 usage factor is higher than for cooled cabinets because the 90 ° F ambient temperature likely has less of an impact on hybrid performance because at least one compartment would be at the lower refrigerator or freezer compartment temperatures.
• Ice makers do not have a similar usage factor adjustment, but the overall energy used in the test procedure is based on an ice consumption rate of 4 lb /day for all product classes.32 

### Stakeholder Feedback – Usage Factors

• Several interested parties commented that DOE did not have sufficient data to determine appropriate usage factors for the different product types.

• One stakeholder submitted data indicating that cooled cabinets and hybrid products are used more similarly to freezers than to refrigerators, with respect to door openings.

• Many stakeholders felt that it would be preferable to use a 90 o F ambient test temperature than to test at 72 ° F with an adjustment factor for door openings.33 

### Key Issues – Usage Factors

• What usage factors best represent field usage of these products?

• Are the ambient temperature impacts and additional thermal load impacts quantified correctly?

• Do working group members have any additional test data to inform appropriate usage factors?

• Note: if the test procedures are revised from the NOPR, this will in turn affect the analysis conducted for energy conservation standards.