EERE-2006-BT-STD-0126 COMMENT 46
2006 

STANDARD for

PERFORMANCE 

RATING OF 

COMMERCIAL 

REFRIGERATED 

DISPLAY 

MERCHANDISERS 

AND STORAGE 

CABINETS 

Standard 1200

4100 N. FAIRFAX DR., SUITE 200 y ARLINGTON, VIRGINIA 22203 

EERE-2006-BT-STD-0126 COMMENT 46
Price $10.00 (M) $20.00 (NM) ©Copyright 2006, by Air-Conditioning and Refrigeration Institute 

IMPORTANT 

SAFETY DISCLAIMER

ARI does not set safety standards and does not certify or guarantee the safety of any products, components or 

systems designed, tested, rated, installed or operated in accordance with this standard/guideline. It is strongly 

recommended that products be designed, constructed, assembled, installed and operated in accordance with 

nationally recognized safety standards and code requirements appropriate for products covered by this 

standard/guideline. 

ARI uses its best efforts to develop standards/guidelines employing state-of-the-art and accepted industry 

practices. ARI does not certify or guarantee that any tests conducted under its standards/guidelines will be 

non-hazardous or free from risk. 

Note: 

This standard supersedes ARI Standard 1200-2004. 

Printed in U.S.A. Registered United States Patent and Trademark Office

EERE-2006-BT-STD-0126 COMMENT 46
TABLE OF CONTENTS

SECTION PAGE 

Section 1. Purpose ..............................................................................................................................1 

Section 2. Scope .................................................................................................................................1 

Section 3. Definitions .........................................................................................................................1 

Section 4. Test Requirements ............................................................................................................4 

Section 5. Rating Requirements for Remote Commercial Refrigerated Display 

Merchandisers and Storage Cabinets.................................................................................4 

Section 6. Rating Requirements for Self-contained Commercial Refrigerated 

 Display Merchandisers and Storage Cabinets ...................................................................8 

Section 7. Symbols and Subscripts.....................................................................................................9 

Section 8. Minimum Data Requirements for Published Ratings......................................................10 

Section 9. Marking and Nameplate Data..........................................................................................11 

Section 10. Conformance Conditions.................................................................................................11 

TABLES 

Table 1. EER and COP for Remote Commercial Refrigerated Display 

Merchandisers and Storage Cabinets.................................................................................6 

Table 2. Motor Efficiency Values, ηm.............................................................................................7 

Table 3. Presentation of Data for Remote Commercial Refrigerated Display 

Merchandisers and Storage Cabinets...............................................................................12 

Table 4. Presentation of Data for Self-contained Commercial 

Refrigerated Display Merchandisers and Storage Cabinets ............................................12 

EERE-2006-BT-STD-0126 COMMENT 46
APPENDICES 

Appendix A. References - Normative ..................................................................................................13 

Appendix B. References - Informative.................................................................................................13 

Appendix C. Commercial Refrigerated Display Merchandiser and Storage 

Cabinet Load Line Volume Calculation - Normative.....................................................14 

Appendix D. Commercial Refrigerated Display Merchandiser Total Display Area 

(TDA) Calculation - Normative......................................................................................16 

Appendix E. Example – Energy Performance Representation for a Remote Commercial 

Refrigerated Display Merchandiser or Storage Cabinet - Informative...........................21 

Appendix F. Example – Energy Performance Representation for a Self-contained 

Commercial Refrigerated Display Merchandiser or Storage Cabinet - Informative ......24 

TABLES FOR APPENDICES 

Table E1. Sample Presentation of Data for Remote Commercial 

Refrigerated Display Merchandisers and Storage Cabinets............................................23 

Table F1. Sample Presentation of Data for Self-contained Commercial 

Refrigerated Display Merchandisers or Storage Cabinets..............................................25 

FIGURES FOR APPENDICES 

Figure C1. Sample Cross Sections of Commercial Refrigerated Display Merchandisers 

for Load Line Volume Calculation..................................................................................14 

Figure C2. Sample Cross Section of Commercial Refrigerated Storage Cabinets for 

 Volume Calculation.........................................................................................................15 

Figure D1. Vertical Multi-deck .........................................................................................................16 

Figure D2. Vertical Multi-deck with Transparent Front....................................................................16 

Figure D3. Semi-vertical Multi-deck.................................................................................................17 

Figure D4. Semi-vertical Multi-deck with Transparent Front...........................................................17 

Figure D5. Horizontal Single-deck....................................................................................................17 

EERE-2006-BT-STD-0126 COMMENT 46
Figure D6. Horizontal Single-deck with Transparent Front ..............................................................17 

Figure D7. Serve Over Counter with Flat Transparent Front ............................................................18 

Figure D8. Serve Over Counter with Curved Transparent Front ......................................................18 

Figure D9. Horizontal Single-deck Island .........................................................................................18 

Figure D10. Horizontal Single-deck Island with Transparent Wall ....................................................18 

Figure D11. Horizontal Single-deck Island with Transparent Walls...................................................18 

Figure D12. Vertical Multi-deck with Transparent Door ....................................................................18 

Figure D13. Vertical Multi-deck End Wall with Transparent Section ................................................19 

Figure D14. Semi-vertical Multi-deck End Wall with Transparent Section .......................................19 

Figure D15. Horizontal Single-deck and Single-deck Island End Wall with Transparent Section.....19 

Figure D16. Serve Over Counter End Wall with Transparent Section................................................19 

Figure D17. Example TDA for Unique Geometries............................................................................20 

EERE-2006-BT-STD-0126 COMMENT 46
__________________________________________________________________ ARI STANDARD 1200-2006 

PERFORMANCE RATING OF COMMERCIAL 

REFRIGERATED DISPLAY MERCHANDISERS AND 

STORAGE CABINETS 

Section 1. Purpose 

1.1 Purpose. The purpose of this standard is to establish for Commercial Refrigerated Display Merchandisers and Storage 

Cabinets: definitions; test requirements; rating requirements; symbols and subscripts; minimum data requirements for 

Published Ratings; marking and nameplate data and conformance conditions. 

1.1.1 Intent. This standard is intended for the guidance of the industry, including manufacturers, engineers, 

installers, contractors and users. The values reported using this standard allow comparison of energy consumption 

within each of the following product categories: Remote Commercial Refrigerated Display Merchandisers, Remote 

Commercial Refrigerated Storage Cabinets, Self-contained Commercial Refrigerated Display Merchandisers and Selfcontained Commercial Refrigerated Storage Cabinets. 

1.1.2 Review and Amendment. This standard is subject to review and amendment as technology advances. 

Section 2. Scope 

2.1 Scope. This standard applies to the following manufacturers’ standard catalog Commercial Refrigerated Display 

Merchandisers and Storage Cabinets, provided that the cases are equipped and designed to work with electrically driven, 

direct expansion type systems: 

a. Self-contained and Remote Commercial Refrigerated Display Merchandisers and Storage Cabinets 

b. Open and Closed Commercial Refrigerated Display Merchandisers 

c. Service and Self-service Commercial Refrigerated Display Merchandisers 

2.2 Exclusions. This standard does not apply to the following: 

a. Commercial Refrigerated Display Merchandisers forming the front wall of a refrigerated storage room backed up 

to a walk-in cooler 

b. Miter transition display merchandisers used as a corner section between two refrigerated display merchandisers 

c. Floral merchandisers 

d. Refrigerated vending machines 

e. Ice makers 

f. Ice cream dipping cabinets 

g. Soft serve extruders 

h. Secondary coolant applications 

Section 3. Definitions 

All terms in this document shall follow the standard industry definitions in the current edition of ASHRAE Terminology of 

Heating, Ventilation, Air Conditioning and Refrigeration unless otherwise defined in this section. 

3.1 Anti-condensate Energy Consumption (AEC). The Total Daily Energy Consumption used in condensate removal on 

the outside of the Commercial Refrigerated Display Merchandiser or Storage Cabinet, which typically includes fan and 

condensate heater energy expressed in kW·h/ft [kW·h/m] per day. 

3.2 Calculated Daily Energy Consumption (CDEC). This is a value for Remote Commercial Refrigerated Display 

Merchandisers or Storage Cabinets based upon the requirements of this standard expressed in kW·h/ft [kW·h/m] per day. 

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EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006__________________________________________________________________ 

3.4.1

3.4.2

3.4.3

3.4.4

3.4.5

3.4.6

3.5.1

3.5.2

3.9.1

3.3 Coefficient of Performance (COP). A ratio of the cooling capacity in watts [W] to the power input value in watts [W] 

at any given set of Rating Conditions expressed in watts/watt [W/W]. 

3.4 Commercial Refrigerated Display Merchandiser. A cabinet cooled by a refrigerating system for displaying chilled 

and/or frozen food to be maintained within prescribed temperature limits. 

Closed Commercial Refrigerated Display Merchandiser. A refrigerated display merchandiser where food is 

accessible for removal by opening or moving doors or panels. 

Open Commercial Refrigerated Display Merchandiser. A refrigerated display merchandiser where food is 

accessible for removal without opening or moving doors or panels. 

Remote Commercial Refrigerated Display Merchandiser. A refrigerated display merchandiser that has a 

remote condensing unit. 

Self-contained Commercial Refrigerated Display Merchandiser. A refrigerated display merchandiser that has 

the condensing unit attached to the display case. 

Self-service Commercial Refrigerated Display Merchandiser. A refrigerated display merchandiser, either 

open or closed, where food is readily accessible and intended to be removed by the consumer.

Service Commercial Refrigerated Display Merchandiser. A closed refrigerated display merchandiser where 

food is served from behind the unit. 

3.5 Commercial Refrigerated Storage Cabinet. A closed cabinet cooled by a refrigerating system for storing chilled 

and/or frozen food to be maintained within prescribed temperature limits. 

Remote Commercial Refrigerated Storage Cabinet. A refrigerated storage cabinet that has a remote 

condensing unit. 

Self-contained Commercial Refrigerated Storage Cabinet. A refrigerated storage cabinet that has the 

condensing unit attached to the unit.

3.6 Compressor Energy Consumption (CEC). The energy consumed by the compressor expressed in kW·h/ft [kW·h/m] 

per day. 

3.7 Condensate Evaporator Pan Energy Consumption (PEC). The amount of heat energy required to change condensate 

from liquid to a vapor in the evaporator pan expressed in kW·h/ft [kW·h/m] per day. 

3.8 Defrost Energy Consumption (DEC). The energy consumed during defrost cycles expressed in kW·h/ft [kW·h/m] per 

day. 

3.9 Dew Point. Refrigerant vapor saturation temperature at a specified pressure expressed in °F [°C]. 

Adjusted Dew Point. An adjusted temperature lower than actual Dew Point temperature expressed in °F [°C], 

resulting from suction line pressure losses, equal to saturated suction temperature at the compressor. 

3.10 Energy Efficiency Ratio (EER). A ratio of the cooling capacity in Btu/h to the power input values in watts at any given 

set of Rating Conditions expressed in Btu/(W·h). 

3.11 Fan Energy Consumption (FEC). The energy consumed by fan motors expressed in kW·h/ft [kW·h/m] per day. 

3.12 Integrated Average Temperature. The average of all test package measurements taken during the test expressed in °F 

[°C]. 

3.13 Lighting Energy Consumption (LEC). The energy consumed by lighted shelves and lighting internal to the refrigerated 

display merchandiser or storage cabinet expressed in kW·h/ft [kW·h/m] per day. 

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EERE-2006-BT-STD-0126 COMMENT 46
__________________________________________________________________ ARI STANDARD 1200-2006 

3.14.1

3.14.2

3.14.3

3.14.4

3.15.1

3.15.2

3.16.1

3.17.1

3.17.2

3.20.1

3.20.2

3.14 Product Temperature. Commercial Refrigerated Display Merchandisers or Storage Cabinets shall be tested with one 

or more of the following Integrated Average Temperatures: 

Ice Cream Applications. Commercial Refrigerated Display Merchandisers and Storage Cabinets intended for 

Ice Cream Applications shall have an Integrated Average Temperature of all test package averages of -5.0°F ± 2.0°F 

[-21°C ± 1.1°C]. 

Low Temperature Applications. Commercial Refrigerated Display Merchandisers and Storage Cabinets 

intended for Low Temperature Applications shall have an Integrated Average Temperature of all test package 

averages of 0.0°F ± 2.0°F [-18°C ± 1.1°C]. 

Medium Temperature Applications. Commercial Refrigerated Display Merchandisers and Storage Cabinets 

intended for Medium Temperature Applications, shall have an Integrated Average Temperature of all test package 

averages of 38°F ± 2.0°F [3.3°C ± 1.1°C]. 

Application Product Temperature. This test allows Integrated Average Temperatures other than 3.14.1, 

3.14.2 and 3.14.3. 

3.15 Published Rating. A statement of the assigned values of those performance characteristics, under stated Rating 

Conditions, by which a unit may be chosen for its application. The term Published Rating includes the rating of all 

performance characteristics shown on the unit or published in specifications, advertising or other literature controlled by the

manufacturer, at stated Rating Conditions. 

Application Rating. A rating based on tests performed at application Rating Conditions (other than Standard 

Rating Conditions). 

Standard Rating. A rating based on tests performed at Standard Rating Conditions. 

3.16 Rating Conditions. Any set of operating conditions under which a single level of performance results and which 

causes only that level of performance to occur. 

Standard Rating Conditions. Rating Conditions used as the basis of comparison for performance 

characteristics. 

3.17 "Shall" or "Should". "Shall" or "should" shall be interpreted as follows: 

Shall. Where "shall" or "shall not" is used for a provision specified, that provision is mandatory if 

compliance with the standard is claimed. 

Should. "Should" is used to indicate provisions which are not mandatory but which are desirable as good 

practice. 

3.18 Total Daily Energy Consumption (TDEC). A calculated energy consumption value for Self-contained Commercial 

Refrigerated Display Merchandisers and Storage Cabinets based upon the requirements of this standard expressed in kW·h/ft 

[kW·h/m] per day. 

3.19 Total Display Area (TDA). The sum of the projected area(s) for visible product expressed in ft2 [m2

]. 

3.20 Volume. Two methods are defined for determining refrigerated volume. 

AHAM Volume Method. The interior volume of a refrigerator as calculated by ANSI/AHAM HRF-1-2004. 

Load Line Volume Method. The gross interior volume of the refrigerator contained within the load limit lines. 

This gross volume calculated without display devices installed.

3 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006___________________________________________________________________ 

Section 4. Test Requirements 

4.1 Test Requirements. The tests required for this standard shall be conducted in accordance with ANSI/ASHRAE 

Standard 72.

4.1.1 Dry-Bulb Temperature. The average test-room dry-bulb temperature shall be 75.2oF ± 1.8oF [24.0oC ± 

1.0oC], when measured in accordance with ANSI/ASHRAE Standard 72. 

4.1.2 Wet-Bulb Temperature. The average test-room wet-bulb temperature shall be 64.4oF ± 1.8oF [18.0oC ± 

1.0oC], when measured in accordance with ANSI/ASHRAE Standard 72.

4.1.3 Electrical Conditions. Nameplate voltages for 60 Hz systems are shown in Table 1 of ARI Standard 110. 

Nameplate voltages for 50 Hz systems shall include one or more of the utilization voltages shown in Table 1 of IEC 

Standard 60038. Tests shall be performed at the nameplate rated voltage and frequency unless otherwise specified in 

this standard. For all dual nameplate voltage equipment covered by this standard, tests shall be performed at both 

voltages or at the lower voltage if only a single rating is to be published. 

Section 5. Rating Requirements for Remote Commercial Refrigerated Display Merchandisers and Storage 

Cabinets 

5.1 General. This section identifies the necessary data required to calculate the CDEC for Remote Commercial 

Refrigerated Display Merchandisers and Storage Cabinets. 

5.2 CDEC for Remote Commercial Refrigerated Display Merchandisers and Storage Cabinets. The total electrical load 

shall be measured and adjusted to determine CDEC. The electrical load categories shall include compressors, evaporator fan 

motors, lighting, surface anti-condensate load including fans and heaters, defrost heaters, condensate evaporator pans and any 

other suitable electrical loads when they are part of the unit. If measured electrical loads are not available, the following 

calculations shall be done to determine the CDEC. 

 CDEC = CEC + FEC + LEC + AEC + DEC + PEC 1

Remote Commercial Refrigerated Display Merchandisers and Storage Cabinets shall report the individual loads in the 

calculation of CDEC. Shown below are formulae for the required individual loads. 

5.2.1 Calculation of CEC. The EER or COP in Table 1 shall be used to calculate CEC for a 24 hour period. 

Note: The EER and COP values in Table 1 are based on an evaporator temperature and the Commercial 

Refrigerated Display Merchandiser or Storage Cabinet classification. Commercial Refrigerated Display Merchandisers 

and Storage Cabinets for Medium Temperature Applications shall use a temperature that is 2.0°F [1.2°C] lower than 

the Commercial Refrigerated Display Merchandiser or Storage Cabinet Dew Point. 

Commercial Refrigerated Display Merchandisers and Storage Cabinets for Low Temperature Applications shall use a 

temperature that is 3.0°F [1.7°C] lower than the Commercial Refrigerated Display Merchandiser or Storage Cabinet 

Dew Point. Table 1 shall be used for consistency, understanding that other compressor selections can lead to a 

different efficiency. 

CEC = [(Qrt / L) · (t – tdt)] / (EER · 1000) I-P 2 

CEC = [(Qrt / L) · (t – tdt)] / (COP · 1000) SI 3

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EERE-2006-BT-STD-0126 COMMENT 46
___________________________________________________________________ ARI STANDARD 1200-2006 

5.2.2 Calculation of FEC. The FEC shall be measured data for all fan motors or calculated data using the motor 

efficiency values in Table 2: 

FEC = (Pf · tf) / (L · 1000) 4

where: 

Pf = Pfi (measured) 

Pf = (Pfo · n) / (ηm) (calculated) 

5.2.3 Calculation of LEC. 

LEC = (Pli · tl) / (L · 1000) 5 

5.2.4 Calculation of AEC. 

AEC = (Pai · ta) / (L · 1000) 6 

5.2.5 Calculation of DEC. 

DEC = (Pd · td) / (L · 1000) 7 

5.2.6 Calculation of PEC. 

PEC = (Pc · tc) / (L · 1000) 8 

5.2.7 Other Electric Energy Consumption. If there are additional options that decrease or increase the electrical 

units, they should be noted under “Other Loads” (Section 8) with an appropriate calculation for energy consumption 

expressed in kW·h/ft [kW·h/m] per day. 

5.3 Alternate Components - Direct Effects. The energy consumption of substituted or alternate components shall be 

measured or calculated from the component’s nameplate rating. The energy usage of the substituted or alternate components 

shall be used to recalculate the CDEC in 5.2. The energy consumption of the substituted or alternate components and the 

recalculated CDEC shall be reported as shown in Section 8. 

5.3.1 FEC. When removing or substituting a fan motor, the fan energy shall be measured or calculated according 

to 5.2.2. The energy usage of the substituted or alternate components shall be used to recalculate the CDEC according 

to 5.2. The energy consumption of the substituted or alternate components and the recalculated CDEC shall be 

reported according to Section 8. When calculating the fan motor energy for substituting a fan motor, the airflow rate 

produced from the assembly shall be equal to the original configuration. 

5.3.2 LEC. When removing or substituting lighting, the lighting energy shall be measured or calculated according 

to 5.2.3. The energy usage of the substituted or alternate components shall be used to recalculate the CDEC according 

to 5.2. The energy consumption of the substituted or alternate components and the recalculated CDEC shall be 

reported according to Section 8. 

5.3.3 AEC. When removing or substituting an anti-condensate heater, the heater energy shall be measured or 

calculated according to 5.2.4. The energy usage of the substituted or alternate components shall be used to recalculate 

the CDEC according to 5.2. The energy consumption of the substituted or alternate components and the recalculated 

CDEC shall be reported according to Section 8. 

5 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

Table 1. EER and COP for Remote Commercial Refrigerated Display Merchandisers and 

Storage Cabinets 

Medium Temperature Low Temperature 

Adjusted Dew Point Adjusted Dew Point 

oF oC 

EER COP 

oF oC 

EER COP 

0.0 -17.8 9.25 2.71 -36.0 -37.8 5.48 1.61 

1.0 -17.2 9.37 2.75 -35.0 -37.2 5.56 1.63 

2.0 -16.7 9.50 2.78 -34.0 -36.7 5.64 1.65 

3.0 -16.1 9.63 2.82 -33.0 -36.1 5.73 1.68 

4.0 -15.6 9.76 2.86 -32.0 -35.6 5.81 1.70 

5.0 -15.0 9.87 2.89 -31.0 -35.0 5.9 1.73 

6.0 -14.4 10.03 2.94 -30.0 -34.4 5.98 1.75 

7.0 -13.9 10.19 2.99 -29.0 -33.9 6.06 1.78 

8.0 -13.3 10.36 3.04 -28.0 -33.3 6.15 1.80 

9.0 -12.8 10.52 3.08 -27.0 -32.8 6.24 1.83 

10.0 -12.2 10.69 3.13 -26.0 -32.2 6.33 1.85 

11.0 -11.7 10.87 3.18 -25.0 -31.7 6.41 1.88 

12.0 -11.1 11.05 3.24 -24.0 -31.1 6.5 1.90 

13.0 -10.6 11.22 3.29 -23.0 -30.6 6.6 1.93 

14.0 -10.0 11.4 3.34 -22.0 -30.0 6.7 1.96 

15.0 -9.4 11.58 3.39 -21.0 -29.4 6.78 1.99 

16.0 -8.9 11.79 3.45 -20.0 -28.9 6.88 2.02 

17.0 -8.3 11.99 3.51 -19.0 -28.3 6.98 2.05 

18.0 -7.8 12.19 3.57 -18.0 -27.8 7.08 2.07 

19.0 -7.2 12.39 3.63 -17.0 -27.2 7.19 2.11 

20.0 -6.7 12.59 3.69 -16.0 -26.7 7.29 2.14 

21.0 -6.1 12.85 3.77 -15.0 -26.1 7.39 2.17 

22.0 -5.6 13.04 3.82 -14.0 -25.6 7.49 2.19 

23.0 -5.0 13.27 3.89 -13.0 -25.0 7.60 2.23 

24.0 -4.4 13.49 3.95 -12.0 -24.4 7.70 2.26 

25.0 -3.9 13.72 4.02 -11.0 -23.0 7.81 2.29 

26.0 -3.3 13.95 4.09 -10.0 -23.3 7.92 2.32 

27.0 -2.8 14.18 4.15 -9.0 -22.8 8.03 2.35 

28.0 -2.2 14.47 4.24 -8.0 -22.2 8.14 2.38 

29.0 -1.7 14.73 4.32 -7.0 -21.7 8.25 2.42 

30.0 -1.1 14.98 4.39 -6.0 -21.1 8.36 2.45 

31.0 -0.6 15.27 4.47 -5.0 -20.6 8.48 2.48 

32.0 0.0 15.56 4.56 -4.0 -20.0 8.59 2.52 

33.0 0.6 15.84 4.64 -3.0 -19.4 8.71 2.55 

34.0 1.1 16.13 4.73 -2.0 -18.9 8.83 2.59 

35.0 1.7 16.42 4.81 -1.0 -18.3 8.95 2.62 

Note: 

 1. EER and COP values at Medium and Low Temperature Applications are based on a typical reciprocating 

 compressor. 

2. Linear interpolation should be used to calculate EER and COP values for temperatures not shown in Table 1. 

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EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

Table 2. Motor Efficiency Values, ηm

Motor Type Motor Efficiency Value 

Shaded Pole 0.20 

PSC 0.29 

Electronic 0.66 

5.3.4 DEC. When removing or substituting a defrost heater, the heater energy shall be measured or calculated 

according to 5.2.5. The energy usage of the substituted or alternate components shall be used to recalculate the CDEC 

according to 5.2. The energy consumption of the substituted or alternate components and the recalculated CDEC shall 

be reported according to Section 8. 

5.3.5 PEC. When removing or substituting a condensate evaporator pan, the pan energy shall be measured or 

calculated according to 5.2.6. The energy usage of the substituted or alternate components shall be used to recalculate 

the CDEC according to 5.2. The energy consumption of the substituted or alternate components and the recalculated 

CDEC shall be reported according to Section 8. 

5.4 Alternate Component Indirect Effects. The revised Compressor Energy Consumption (CECR) is the indirect effect of 

alternate component(s) on the Compressor Energy Consumption (CEC) and shall be measured or calculated. The total 

revised Compressor Energy Consumption (CECR) is the sum of the CEC and the additional Compressor Energy Consumption 

(CECA) for each component. 

CECR = CEC + ∑CECA 9 

5.4.1 Fans. When substituting a fan motor located in the refrigerated space, the change in energy affects the CEC. 

The change in CEC shall be calculated by multiplying the difference in power usage between the alternate components 

by the operating time and dividing by the compressor’s COP rating. This change in CEC shall be added back to the 

original CEC: 

CECA = [(Ps·ts) – (Po ·to)] / (COP· L·1000) 10

5.4.2 Lights. When substituting internal lighting located in the refrigerated space, the change in energy affects the 

CEC. The change in CEC shall be calculated by multiplying the difference in power usage between the alternate 

components by the operating time and dividing by the compressor’s COP rating. This change in CEC shall be added 

back to the original CEC. 

For ballast located internal or external to the refrigerated space: 

CECA = [(Ps·ts) – (Po· to)] / (COP· L·1000) 11

 5.4.3 Anti-Condensate Heater. When substituting an anti-condensate heater located in the refrigerated space, the 

change in energy affects the CEC. The change in CEC shall be calculated by dividing the difference in energy usage 

between the alternate components by the compressor’s COP rating. This change in CEC shall be added back to the 

original CEC: 

CECA = [(Ps ·ts) – (Po ·to)] / (COP ·L·1000) 12

5.4.4 Condensate Evaporator Pans. When substituting a condensate evaporator pan located in the refrigerated 

space, the change in energy affects the CEC. The change in CEC shall be calculated by dividing the difference in 

energy usage between the alternate components by the compressor’s COP rating. 

This change in CEC shall be added back to the original CEC: 

CECA = [(Ps ·ts) – (Po ·to)] / (COP· L·1000) 13 

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EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

5.5 Refrigerated Volume. The refrigerated volume of the Commercial Refrigerated Display Merchandiser or Storage 

Cabinet shall be calculated based on the equation below using the load line Volume as described in Appendix C:

Vr = Ar ·L 14 

5.6 Total Display Area. The total display area of the Commercial Refrigerated Display Merchandiser shall be calculated 

based on the equation below and as described in Appendix D:

TDA = (Dh ·L) + Ae 15 

5.7 Tolerances. To comply with this standard, published CDEC ratings shall be based on data obtained in accordance 

with this section, and shall be such that any production unit, when tested, shall not exceed these ratings by more than 5%. 

Values obtained using calculated component substitutions must also meet these tolerances.

5.8 Multiples. The CDEC, in kW·h/ft [kW·h/m] per day, shall be expressed in 0.01 kW·h/ft [kW·h/m] per day increments. 

Section 6. Rating Requirements for Self-contained Commercial Refrigerated Display Merchandisers and 

Storage Cabinets 

6.1 General. This section identifies the necessary data required to calculate the TDEC for Self-contained Commercial 

Refrigerated Display Merchandisers and Storage Cabinets. 

6.2 TDEC for Self-contained Commercial Refrigerated Display Merchandisers and Storage Cabinets. The total electrical 

load shall be measured to determine TDEC. The electrical load measurement shall include compressors, evaporator fan 

motors, condensing fan motors, lighting, anti-condensate loads including fans and heaters, defrost heaters, condensate 

evaporator pans and any other suitable electrical loads when they are part of the unit: 

TDEC = Et / L 16 

The values are expressed in kW·h/ft [kW·h/m] per day. 

6.3 Alternate Components for Self-contained Commercial Refrigerated Display Merchandisers and Storage Cabinets. 

The direct energy consumption of alternate components shall be measured or calculated from the component’s nameplate 

rating. A calculated change in the energy usage for the alternate component shall be substituted for the energy usage of the 

component used in the total energy test only if the alternate component uses less energy than the original component. A credit 

for a reduction in the CEC due to alternate components in a Self-contained Commercial Refrigerated Display Merchandiser 

or Storage Cabinet shall not be taken if a calculated value is used. A direct measurement of the total electrical load shall be

made if the alternate component uses more energy than the original component or it is desired to take a credit for the 

compressor energy reduction. 

The calculated direct effect in energy usage shall be added back to the original TDEC and the adjusted Total Daily Energy 

Consumption (TDECA) determined for each component substitution. 

 TDECA = (Es − Eo) / L 17 

 

 Where: 

 Es= Ps · ts 

 Eo= Po · to

6.3.1 FEC. When removing or substituting a fan motor, the fan energy shall be measured or calculated according 

to 5.2.2. The adjusted Total Daily Energy Consumption (TDECA) shall be measured or calculated using equation 17. 

When calculating the fan motor energy for substituting a fan motor, the airflow produced from the assembly shall be 

equal to the original configuration. 

8 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

6.3.2 LEC. Lights. When removing or substituting internal lighting, lighting energy shall be measured or 

calculated from the product nameplate according to 5.2.3. The adjusted Total Daily Energy Consumption 

(TDECA) shall be measured or calculated using equation 17. It does not matter if the ballast is internal or 

external to refrigerated space because the CEC adjustment cannot be made for the Self-contained Commercial 

Refrigerated Display Merchandiser or Storage Cabinet. 

6.3.3 AEC. Anti-Condensate Heater. When removing or substituting an anti-condensate heater, the heater energy 

shall be measured or calculated from the product’s nameplate according to 5.2.4. The adjusted Total Daily Energy 

Consumption (TDECA) shall be measured or calculated using equation 17. 

6.3.4 DEC. Defrost Heaters. When removing or substituting a defrost heater, the change in energy shall be 

measured or calculated according to 5.2.5. The adjusted Total Daily Energy Consumption (TDECA) shall be measured 

or calculated using equation 17. 

6.3.5 PEC. Condensate Evaporator Pans. When removing or substituting a condensate evaporator pan, the 

change in energy shall be measured or calculated according to 5.2.6. The adjusted Total Daily Energy Consumption 

(TDECA) shall be measured or calculated using equation 17. 

6.4 Refrigerated Volume. The refrigerated volume of the Commercial Refrigerated Display Merchandiser or Storage 

Cabinet shall be calculated using one of the two following methods.

6.4.1 AHAM Volume Method. The refrigerated volume of closed Self Service Commercial Refrigerated Display 

Merchandisers and Commercial Refrigerated Storage Cabinets is determined using the AHAM volume. 

6.4.2 Load Line Volume Method. The Refrigerated Volume of all other Commercial Refrigerated Display 

Merchandisers is determined using Load Line volume. 

6.5 Total Display Area. The total display area of the Commercial Refrigerated Display Merchandiser is calculated 

according to 5.6.

6.6 Tolerances. To comply with this standard, published TDEC ratings whether measured or calculated shall be based on 

data obtained in accordance with this section, and shall be such that any production unit, when tested, shall not exceed these 

ratings by more than 5%. 

6.7 Multiples. The TDEC, expressed in kW·h/ft [kW·h/m] per day, shall be stated in 0.01 kW·h/ft [kW·h/m] per day 

increments. 

Section 7. Symbols and Subscripts 

7.1 Symbols and Subscripts. The symbols and subscripts used in this standard are as follows: 

 

Ae = Projected area from visible product through end walls, ft2 [m2

] 

Ar = Gross refrigerated area, ft2

 [m2] 

AEC = Anti-condensate energy consumption, kW·h/ft [kW·h/m] per day 

CDEC = Calculated Daily Energy Consumption, kW·h/ft [kW·h/m] per day 

 CEC = Compressor Energy Consumption, kW·h/ft [kW·h/m] per day 

CECA = Additional Compressor Energy Consumption for an alternate component, kW·h/ft [kW·h/m] per day 

 CECR = Revised Compressor Energy Consumption, kW·h/ft [kW·h/m] per day 

COP = Coefficient of Performance (Table 1) 

DEC = Defrost Energy Consumption, kW·h/ft [kW·h/m] per day 

Dh = Dimension of projected visible product, ft[m] 

Eo = Original energy consumption, kW·h [kW·h] 

9 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

Es = Energy consumption with substituted component, kW·h [kW·h] per day 

Et = Total energy measured or calculated for 24 hour period, kW·h [kW·h] per day 

EER = Energy Efficiency Ratio (Table 1) 

FEC = Fan Energy Consumption, kW·h/ft [kW·h/m] per day 

LEC = Light Energy Consumption, kW·h/ft [kW·h/m] per day 

LECR = Revised Light Energy Consumption,kW·h/ft [kW·h/m] per day 

L = Length of unit, ft [m] 

n = Number of fan motors 

Pai = Power anti-condensate heater input, W [W] 

Pc = Power condensate evaporator pan heater input, W [W] 

Pd = Power defrost heater input, W [W] 

Pf = Power fan, W [W] 

Pfi = Power fan input, W [W] 

Pfo = Power fan output found on part nameplate, W [W] 

Pli = Power light input, W [W] 

Po = Power input calculated for original part, W [W] 

Ps = Power input calculated for substitution part, W [W] 

PEC = Condensate Evaporator Pan Energy Consumption, kW·h/ft [kW·h/m] per day 

 Qrt = Commercial refrigerated display merchandiser or storage cabinet load, Btu/h [W] 

t = Time unit is tested in 24 h period, h [h] 

ta = Time anti-condensate heaters are on in 24 hour period, h [h] 

tc = Time condensate evaporator pan heaters are on in 24 hour period, h [h] 

td = Time defrost heaters are on in 24 hour period, h [h] 

tdt = Time unit is in defrost, h [h] 

tf = Time fans are on in 24 hour period, h [h] 

tl = Time lights are on in 24 hour period, h [h] 

to = Time original part is on in 24 hour period, h [h] 

ts = Time substitution part is on in 24 hour period, h [h] 

TDA = Total Display Area, ft2 [m2

]/Unit of Length, ft [m] 

TDEC = Total Daily Energy Consumption,kW·h/ft [kW·h/m] per day 

TDECA= Adjusted Total Daily Energy Consumption, kW·h/ft [kW·h/m] per day 

Vr = Refrigerated Volume, ft3

 [m3] 

ηm = Motor efficiency 

Note: Per day denotes a 24-hour period. 

Section 8. Minimum Data Requirements for Published Ratings 

8.1 Minimum Data Requirements for Published Ratings. As a minimum, Published Ratings shall include all Standard 

Ratings. All claims to ratings within the scope of this standard shall include the statement "Rated in accordance with ARI 

Standard 1200". All claims to ratings outside the scope of this standard shall include the statement "Outside the scope of ARI 

Standard 1200". Wherever Application Ratings are published or printed, they shall include a statement of the conditions at 

which the ratings apply. 

8.2 Table 3 represents the remote commercial refrigerated display merchandiser or storage cabinet data that shall be 

reported for each appropriate model(s). Only one set of units should be printed in the data table. 

8.3 Table 4 represents the self-contained commercial refrigerated display merchandiser or storage cabinet data that shall 

be reported for each appropriate model (s). Only one set of units should be printed in the data table. 

10 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

Section 9. Marking and Nameplate Data

Marking and Nameplate Data. As a minimum, the following information shall be shown in a conspicuous place on the 

equipment: 

a. Name or trade name of manufacturer 

b. Manufacturer’s model number 

c. Heat transfer fluid (where appropriate) 

Nameplate voltages for 60 Hertz systems shall include one or more of the equipment nameplate voltage ratings shown in 

Table 1 of ARI Standard 110. Nameplate voltages for 50 Hertz systems shall include one or more of the utilization voltages 

shown in Table 1 of IEC Standard 60038. 

Section 10. Conformance Conditions 

Conformance. While conformance with this standard is voluntary, conformance shall not be claimed or implied for products 

or equipment within the standard’s Purpose (Section 1) and Scope (Section 2) unless such product claims meet all of the 

requirements of the standard and all of the testing and rating requirements are measured and reported in complete compliance 

with the standard. Any product that has not met all the requirements of the standard shall not reference, state, or 

acknowledge the standard in any written, oral, or electronic communication. 

11 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

Table 3. Presentation of Data for Remote Commercial Refrigerated Display Merchandisers and 

Storage Cabinets 

Item 

Number Informational Item Data 

1 Commercial Refrigerated Display Merchandiser or Storage Cabinet Model Number 

2 Adjusted Dew Point, °F [°C] 

3 Load Capacity, Btu/h [kW] 

4 Refrigerated Volume, ft3 [m3]/Unit of Length, ft [m] 

5 Total Display Area, ft2 [m2]/Unit of Length, ft [m] 

6 Commercial Refrigerated Display Merchandiser or Storage Cabinet Test Voltage, V 

7 Commercial Refrigerated Display Merchandiser or Storage Cabinet Evaporator Dew Point 

Temperature, °F [°C] 

8 Integrated Average Temperature of Product Simulators, °F [°C] 

9 CEC, kW·h/ft [kW·h/m] per day 

10 FEC, kW·h/ft [kW·h/m] per day 

11 LEC, kW·h/ft [kW·h/m] per day 

12 PEC, kW·h/ft [kW·h/m] per day 

13 AEC, kW·h/ft [kW·h/m] per day 

14 DEC, kW·h/ft [kW·h/m] per day 

15 CDEC, kW·h/ft [kW·h/m] per day 

16 Other Loads, Notes: 

Table 4. Presentation of Data for Self-contained Commercial Refrigerated Display Merchandisers 

and Storage Cabinets 

Item 

Number Informational Item Data 

1 Commercial Refrigerated Display Merchandiser or Storage Cabinet Model Number 

2 Refrigerated Volume, ft3[m3]/Unit of Length, ft [m] 

3 Total Display Area, ft2[m2]/Unit of Length, ft [m] 

4 Commercial Refrigerated Display Merchandiser or Storage Cabinet Test Voltage, V 

5 Integrated Average Temperature of Product Simulators, °F [°C] 

6 TDEC, kW·h/ft [kW·h/m] per day 

7 Other Loads, Notes: 

12 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

APPENDIX A. REFERENCES – NORMATIVE 

A1 Listed here are all standards, handbooks, and other publications essential to the formation and implementation of the 

standard. All references in this appendix are considered as part of this standard. 

A1.1 ANSI/AHAM Standard HRF-1-2004, Energy, Performance and Capacity of Household Refrigerators, 

Refrigerator-Freezers, and Freezers, 2004 Association of Home Appliance Manufacturers, 1111 19th Street NW, 

Suite 402, Washington, DC 20036 . 

 A1.2 ANSI/ASHRAE Standard 72-2005, Method of Testing Commercial Refrigerators and Freezers, 2005, 

American Society of Heating, Refrigerating, and Air-Conditioning Engineers, Inc., 1791 Tullie Circle N.E., Atlanta, 

GA 30329, U.S.A. 

A1.3 ARI Standard 110-2002, Air-Conditioning and Refrigerating Equipment Nameplate Voltages, 2002, AirConditioning and Refrigeration Institute, 4100 N. Fairfax Drive, Suite 200, Arlington, VA 22203, U.S.A. 

 

A1.4 ASHRAE, Terminology of Heating, Ventilation Air Conditioning and Refrigeration, Second Edition, 1991, 

American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc., 1791 Tullie Circle N.E. Atlanta, 

GA 30329, U.S.A. 

A1.5 IEC Standard 60038, IEC Standard Voltages, 2002, International Electrotechnical Commission, 3, rue de 

Varembe, P. O. Box 131, 1211 Geneva 20, Switzerland. 

APPENDIX B. REFERENCES – INFORMATIVE 

None 

13 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

APPENDIX C. COMMERCIAL REFRIGERATED DISPLAY 

MERCHANDISER AND STORAGE CABINET LOAD LINE 

VOLUME CALCULATION – NORMATIVE 

C1 The commercial refrigerated display merchandiser refrigerated Volume (Vr) equals the gross refrigerated area (Ar) 

multiplied by the case length (L). The gross refrigerated area shall be calculated within the manufacturer’s specified load 

limit lines, without display devices installed in the Commercial Refrigerated Display Merchandiser, and shall be calculated 

using straight-line segments following the interior of the Commercial Refrigerated Display Merchandiser without display 

devices installed. The sample cross sections shown in Figure C1 shall be used as a guide in equation C1. 

Vr = Ar · L C1

 Figure C1: Sample Cross Sections of Commercial Refrigerated Display Merchandisers for 

Load Line

Gross 

Refrigerated 

Area

 Load Line Volume Calculation

14 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

C2 The commercial refrigerated storage cabinet refrigerated Volume (Vr) equals the gross refrigerated area (Ar) multiplied 

by the case length (L). The gross refrigerated area shall be calculated within the manufacturer’s specified load limit. The 

gross refrigerated area shall be calculated using straight-line segments following the interior of the Commercial Refrigerated 

Storage Cabinet without display devices installed. The sample cross section in Figure C2 shall be used as a guide in equation 

C1. 

 

Gross 

Refrigerated 

Area

Figure C2: Sample Cross Section of Commercial 

 Refrigerated Storage Cabinets for 

 Volume Calculation 

15 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006___________________________________________________________________ 

APPENDIX D. COMMERCIAL REFRIGERATED DISPLAY 

MERCHANDISER TOTAL DISPLAY AREA (TDA) 

CALCULATION - NORMATIVE 

The Total Display Area (TDA) is the sum of the projected area(s) for visible product, ft2 [m2]. 

 TDA = Dh·L + Ae D1 

Ae = Projected area from visible product through end walls (Figures D13 to D16) 

Dh = Dimension of projected visible product (Figures D1 to D12) 

L = Length of Commercial Refrigerated Display Merchandiser 

Note: For unique geometries, the TDA shall be calculated manually. Refer to Figure D17

. 

Nominal Length Display Merchandisers: 

PRODUCT ZONE

TRANSPARENT MATERIAL ( 65% LIGHT TRANSMITTANCE)

OPAQUE MATERIAL

Figure D1: Vertical Multi-deck Figure D2: Vertical Multi-deck with 

X

D = X h

X

D = X h

 Transparent Front 

16 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

Figure D3: Semi-vertical Multi-deck Figure D4: Semi-vertical Multi-deck 

with Transparent Front 

Figure D5: Horizontal Single-deck Figure D6: Horizontal Single-deck 

X

D = X h

X

D = X h

X

D = X h D = X + Y h

Y

X

with Transparent Front

17 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

Figure D7: Serve Over Counter with Flat Figure D8: Serve Over Counter with 

 Transparent Front Curved Transparent Front

Figure D9: Horizontal Single-deck Island Figure D10: Horizontal Single-deck 

 Island with Transparent Wall 

Figure D11: Horizontal Single-deck Island 

 with Transparent Walls 

Figure D12: Vertical Multi-deck 

D = X + Y h

X

Y

X AND Y = TRANSPARENT DIMENSION

X Y

D = X + Y h

X AND Y = TRANSPARENT DIMENSION

X

D = X h

X

Y

D = X + Y h

X

D = X h

X

Y

Dh = X + Y + Z 

Z 

 with Transparent Door 

18 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

End Walls: 

 

 Figure D14: Semi-vertical Multi-deck End 

 Wall with Transparent Section 

Figure D13: Vertical Multi-deck End Wall 

With Transparent Section 

Figure D15: Horizontal Single-deck and 

Single-deck Island End Wall 

with Transparent Section 

 Figure D16: Serve Over Counter End Wall 

A = ( X )( Y ) e

Y

X

A = CALCULATED AREA OF e

X

Y

A = ( X )( Y ) e

A = CALCULATED AREA OF e

 with Transparent Section 

19 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

Figure D17: Example TDA for Unique Geometries 

TDA = CALCULATED FACE AREA OF 

20 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

APPENDIX E. EXAMPLE – ENERGY PERFORMANCE 

REPRESENTATION FOR A REMOTE COMMERCIAL 

REFRIGERATED DISPLAY MERCHANDISER OR STORAGE 

CABINET – INFORMATIVE 

E1 Example of Performance Calculation and Presentation (I-P Units Only). 

E1.1 Situation. A manufacturer produces a remote commercial refrigerated display dairy merchandiser for Medium 

Temperature Applications in 4.0 ft, 6.0 ft, 8.0 ft, and 12.0 ft lengths. The gross refrigerated area of these cases is 

11.67 ft2

 and the dimension of projected visible product is 4.35 ft. The cross-sections of all cases with this model are 

identical. The display case is rated at 120 V. 

E1.2 Measured Results (per ANSI/ASHRAE Standard 72 Energy Calculations). 

-Remote unit 12.0 ft long (actual measured interior length) with two solid end walls. 

-Capacity load: 16,400 Btu/h at 23.0°F evaporator temperature 

-Integrated Average Temperature = 37.6°F 

-Fan power = 60 W (fans on during defrost) 

-Anti-condensate power = 0 W 

-Lighting watts = 294 W (located in the refrigerated space) 

-Electric defrost power = 0 W (off cycle) 

-Condensate pan power = 0 W (none) 

-Number of defrosts in 24 h = 4 

-Length of each defrost = 0.6 h 

E1.3 Energy Performance Calculations. 

E1.3.1 Calculation of Refrigerated Volume. 

Vr = Ar · L

 = 11.67 ⋅ 12.0 = 140 ft3 E1

E1.3.2 Calculation of TDA.

TDA = (Dh ⋅ L) + Ae

 = (4.35 ⋅ 12) + 0 = 52.2 ft2 E2 

E1.3.3 Calculation of CEC. 

 EER (Table 1) based on 21.0°F Adjusted Dew Point (23.0°F for Medium Temperature Applications) = 12.82 

Defrost total time = 4 x 0.6 = 2.4 h 

CEC = [(Qrt / L) · (t – tdt)] / (EER · 1000) E3 

 = [(16,400 /12.0) · (24 - 2.4)] / (12.82 ·1000) 

= 2.30 kW·h/ft per day 

E1.3.4 Calculation of FEC. 

FEC = (Pfi · tf) / (L · 1000) E4 

= (60 · 24)/ (12.0 · 1000) 

= 0.12 kW·h/ft per day 

21 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

E1.3.5 Calculation of LEC. 

LEC = (Pli · tl) / (L · 1000) E5 

 = (294 · 24) / (12.0 · 1000) 

 = 0.59 kW·h/ft per day 

E1.3.6 Calculation of AEC. 

AEC = 0 kW·h/ft per day 

E1.3.7 Calculation of DEC.

DEC = 0 kW·h/ft per day 

E1.3.8 Calculation of PEC.

PEC = 0 kW·h/ft per day

E1.3.9 Calculation of CDEC.

CDEC = CEC + FEC + LEC + AEC + DEC + PEC E6

 = 2.30 + 0.12 + 0.59 + 0 + 0 + 0 

 = 3.01 kW·h/ft per day 

E1.4 Presentation of CDEC Data. Refer to Table E1 for correct display of performance data.

E2 Example of Performance Calculation and Presentation with Component Substitution (I-P Units Only). 

E2.1 Situation. The manufacturer of the case in the situation shown in Section E1 substitutes the lamp ballasts with 

new ballasts. 

E2.2 Nameplate Data. The original ballast had a nameplate rating of 294 W. The new ballast has a nameplate rating 

of 360 W. 

E2.3 Energy Performance Calculations with Component Substitution. 

E2.3.1 Calculation of Revised Light Energy Consumption. 

LECR = (Ps · tl) / (L · 1000) E7 

 = (360 · 24) / (12.0 · 1000) 

 = 0.72 kW·h/ft per day 

E2.3.2 Calculation of revised Compressor Energy Consumption. 

a. Calculation of CECA. 

CECA = [(Ps·ts) – (Po·to)] / (COP·L·1000) E8 

 = [(360·24) – (294 ·24)] / (3.76·12·1000) 

 = 0.04 kW⋅h/ft per day 

b. Calculation of CECR.

CECR = CEC + CECA E9 

 = 2.30 + 0.04 

 = 2.34 kW·h/ft per day 

22 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

 c. Calculation of Revised CDEC.

CDEC = CECR + FEC + LECR + AEC + DEC + PEC E10 

 = 2.34 + 0.12 + 0.72 + 0 + 0 

 = 3.18 kW·h/ft per day 

Table E1. Sample Presentation of Data for Remote Commercial Refrigerated Display Merchandisers and 

Storage Cabinets 

Item 

Number Informational Item I-P Data 

1 Commercial Refrigerated Display Merchandiser or Storage Cabinet Model Number Model X 

2 Adjusted Dew Point, °F 21 

3 Load Capacity, Btu/h 16,400 

4 Refrigerated Volume, ft3/Unit of Length, ft 11.67 

5 Total Display Area, ft2 52.2 

6 Commercial Refrigerated Display Merchandiser or Storage Cabinet Test Voltage, V 120 

7 Commercial Refrigerated Merchandiser or Storage Cabinet Case Evaporator Dew 

Point Temperature, °F 

23.0 

8 Integrated Average Temperature of Product Simulators, °F 37.6 

9 CEC, kW·h/ft per day 2.30 

10 FEC, kW·h/ft per day 0.120 

11 LEC, kW·h/ft per day 0.59 

12 PEC, kW·h/ft per day N/A 

13 AEC, kW·h/ft per day 0.0 

14 DEC, kW·h/ft per day 0.0 

15 CDEC, kW·h/ft per day 3.01 

16 Other Loads, Notes: 

23 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006 

APPENDIX F. EXAMPLE – ENERGY PERFORMANCE 

REPRESENTATION FOR A SELF-CONTAINED 

COMMERCIAL REFRIGERATED DISPLAY 

MERCHANDISER OR STORAGE CABINET– INFORMATIVE 

F1 Example of Performance Calculation and Presentation (I-P Units). 

F1.1 Situation. A manufacturer produces a self-contained commercial refrigerated display bakery merchandiser 

for Medium Temperature Applications in 4.0 ft, 6.0 ft, and 8.0 ft lengths. The gross refrigerated area of these cases is 

3.95 ft2 and the dimension of projected visible product is 3.81 ft. The cross-sections of all cases with this model are 

identical. The display merchandiser is rated at 120 V.

F1.2 Measured Results (per ANSI/ASHRAE Standard 72). 

- Self-contained commercial refrigerated display bakery merchandiser, 4.0 ft long (actual measured interior 

length) with two end walls each containing 2.74 ft2

 of transparent area. 

- Integrated Average Temperature = 38.2°F (measured 24 hour total) 

- Total energy measured for 24 hour period = 21.2 kW·h per day 

F1.3 Energy Performance Calculations. 

F1.3.1 Calculation of Gross Volume. 

Vr = Ar · L F1 

 = 3.95 ⋅ 4.0

 = 15.8 ft3 

F1.3.2 Calculation of TDA.

TDA = (Dh · L) + Ae F2

 = (3.81 · 4) + (2.74 · 2) 

 = 20.7 ft2

F1.3.3 Calculation of TDEC. 

TDEC = Et / L F3 

 = 21.2 /4.0 

 = 5.30 kW·h/ft per day 

F1.4 Presentation of TDEC Data. Refer to Table F1 for display of performance data. 

24 

EERE-2006-BT-STD-0126 COMMENT 46
ARI STANDARD 1200-2006

25 

Table F1. Sample Presentation of Data for Self-contained Commercial 

Refrigerated Display Merchandisers and Storage Cabinets 

Item 

Number 

Informational Item I-P Data 

1 Commercial Refrigerated Display Merchandiser or Storage Cabinet Model 

Number 

Model X 

2 Refrigerated Volume, ft3/Unit of Length, ft 3.95 

3 Total Display Area, ft2 20.7 

4 Commercial Refrigerated Display Merchandiser or Storage Cabinet Test 

Voltage, V 

120 

5 Integrated Average Temperature of Product Simulators, °F 38.2 

6 TDEC, kW·h/ft per day 5.30 

7 Other Loads, Notes: 

Et, Total energy for 24 hour period, kW·h [kW·h] per day 21.2 

EERE-2006-BT-STD-0126 COMMENT 46
American National Standard

Energy, Performance and Capacity of

Household Refrigerators, Refrigerator-Freezers 

and Freezers 

ANSI/AHAM HRF-1-2004 

 (Revision of ANSI/AHAM HRF-1-2002)

EERE-2006-BT-STD-0126 COMMENT 46
i

PREFACE

The Association of Home Appliance Manufacturers develops standards in accordance with AHAM's "Policy and 

Procedures Governing Technical Standards" which states:

“AHAM Standards shall be in the best interest, mutually, of consumers who use appliances, the 

industries which provide and service appliances, and other interested parties. They shall relate to 

actual use conditions and be technically and scientifically sound.”

Use or observance of AHAM standards is voluntary.

AHAM standards are presented to the American National Standards Institute (ANSI) for recognition as American 

National Standards. This edition of this standard was approved by ANSI on July 7, 2004, and is currently 

published as ANSI/AHAM HRF-1-2004. This edition superseded ANSI/AHAM HRF-1-2002. 

This standard contains test procedures that may be applied to any brand or model of household electric refrigerator, 

refrigerator-freezer or freezer for measuring performance. Results of tests in accordance with this standard may be 

publicly stated.

With regard to safety, AHAM recommends that all appliance products--both major and portable --manufactured or 

marketed in the United States be submitted to an appropriate independent laboratory for inspection and listing in 

conformance with the safety standards and procedures followed by such laboratories. The relevant standard for 

refrigerators, refrigerator-freezers and freezers is ANSI/UL 250/CSA C22.2 No. 63 "Standard for Safety, 

Household Refrigerators and Freezers".

AHAM welcomes comments and suggestions regarding this standard. Any standard may be reviewed and 

improved as needed. All standards must be updated or reconfirmed at least every five years. Any interested party, 

at any time, may request a change in an AHAM standard. Such request should be addressed to AHAM's President, 

and should be accompanied by a statement of reason for the request and a suggested alternate proposal.

Copyright © 2004 by the Association of Home Appliance Manufacturers (AHAM) 

All rights reserved.

The hard copy print version of this document shall be for individual use only.

The electronic file version of this document shall be for storage on one computer for purposes of viewing and/or 

printing one copy for individual use only. 

This document shall not be reproduced in whole or in part by any means, and shall not be transmitted electronically 

or otherwise to a third person without the prior written permission of AHAM.

EERE-2006-BT-STD-0126 COMMENT 46
ii

CONTENTS

Section Page

1. PURPOSE .................................................................................................................................................1 

2. SCOPE......................................................................................................................................................1 

3. DEFINITIONS..........................................................................................................................................2 

4. METHOD FOR COMPUTING TOTAL REFRIGERATED VOLUME AND TOTAL SHELF AREA 

OF HOUSEHOLD REFRIGERATORS AND HOUSEHOLD WINE CHILLERS .....................................6 

4.1 Scope of Section 4. ..............................................................................................................................6 

4.2 Total Refrigerated Volume..................................................................................................................6 

4.3 Legend for Figures 4-1 through 4-12 ..................................................................................................8 

4.4 Total Shelf Areas.................................................................................................................................8 

4.5 Legend for Figures 4-13 through 4-17 ................................................................................................9 

5. METHOD FOR COMPUTING TOTAL REFRIGERATED VOLUME AND TOTAL SHELF AREA 

OF HOUSEHOLD FREEZERS...................................................................................................................27 

5.1 Scope of Section 5.............................................................................................................................27

5.2 Total Refrigerated Volume................................................................................................................27 

5.3 Legend for Figures 5-1 through 5-9 ..................................................................................................28 

5.4 Total Shelf Area (Vertical Freezer)...................................................................................................28 

5.5 Legend for Figures 5-10 through 5-14 ..............................................................................................29 

6. METHOD FOR COMPUTING THE VOLUME OF SPECIAL FEATURES OF HOUSEHOLD 

REFRIGERATORS AND HOUSEHOLD FREEZERS..............................................................................41 

6.1 Scope of Section 6.............................................................................................................................41

6.2 Special Features.................................................................................................................................41 

7. PERFORMANCE TEST PROCEDURES AND RECOMMENDED LEVELS OF PERFORMANCE 

FOR HOUSEHOLD REFRIGERATORS, HOUSEHOLD WINE CHILLERS AND HOUSEHOLD 

FREEZERS ..................................................................................................................................................51 

7.1 Scope of Section 7.............................................................................................................................51

7.2 Test Room.........................................................................................................................................51 

7.3 Instruments........................................................................................................................................51 

7.4 General Test Requirements. ..............................................................................................................52 

7.5 No-Load Pull-Down Test (Household Refrigerators and Household Freezers)...............................55 

7.6 Simulated Load Test (Household Refrigerators) ..............................................................................57 

7.7 Simulated Load Test (Household Freezers)......................................................................................60 

7.8 Ice-Making Test (Household Refrigerators and Household Freezers)..............................................62 

7.9 Temperature Rise Test (Household Freezers)...................................................................................64 

8. METHOD FOR DETERMINING THE ENERGY CONSUMPTION OF HOUSEHOLD...................74 

8.1 Scope of Section 8. ............................................................................................................................74 

8.2 Purpose..............................................................................................................................................74 

EERE-2006-BT-STD-0126 COMMENT 46
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8.3 Definitions.........................................................................................................................................74 

8.4 Test Conditions. ................................................................................................................................74 

8.5 Temperature Control Settings ...........................................................................................................75 

8.6 Test Period.........................................................................................................................................77 

8.7 Test Measurements............................................................................................................................78 

8.8 Determination of Results of Average Per-Cycle Energy Consumption............................................81 

9. METHOD FOR COMPUTING ADJUSTED VOLUME AND ENERGY FACTOR OF HOUSEHOLD 

REFRIGERATORS, HOUSEHOLD WINE CHILLERS, AND HOUSEHOLD FREEZERS..................85 

9.1 Scope of Section 9.............................................................................................................................85

9.2 Purpose..............................................................................................................................................85 

9.3 Adjusted Volume...............................................................................................................................85 

9.4 Calculation of Energy Factor ............................................................................................................85 

10. DURABILITY AND CONDENSATE TEST PROCEDURES FOR HOUSEHOLD 

REFRIGERATORS AND HOUSEHOLD FREEZERS..............................................................................86 

10.1 Scope of Section 10.........................................................................................................................86 

10.2 Handling and Storage Test (Household Refrigerators and Household Freezers) ...........................86 

10.3 External Surface Condensation Test (Household Refrigerators and Household Freezers) ............87 

10.4 Internal Moisture Accumulation Test (Household Refrigerators and Household Freezers)...........88 

10.5 Environmental Cracking Resistance Test (Household Refrigerators and Household Freezers).....90 

10.6 Bottom Breaker Strip(s) Impact Test (Household Refrigerators and Household Freezers) ...........92 

11. SAFETY OF HOUSEHOLD REFRIGERATORS, HOUSEHOLD WINE CHILLERS AND 

HOUSEHOLD FREEZERS .......................................................................................................................100 

EERE-2006-BT-STD-0126 COMMENT 46
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1. PURPOSE

1.1 The purpose of this standard is to establish a uniform and repeatable procedure or standard method for 

measuring specified product characteristics of household refrigerators, household wine chillers and household 

freezers. The standard methods and the recommended levels of performance, where they appear, are intended to 

provide a means by which different brands and models of household refrigerators, household wine chillers and 

household freezers can be compared and evaluated with respect to characteristics of significance in the design and 

use of the products.

The standard methods and recommended levels of performance are not intended to inhibit improvement and 

innovation in product testing, design or performance.

2. SCOPE

2.1 This standard applies to household refrigerators as defined in 3.1, household freezers as defined in 3.2 and 

household wine chillers as defined in 3.3.

2.2 This standard covers definitions, methods for computing volumes and shelf areas, methods for determining 

volumes of special features, performance test procedures, durability test procedures, methods for determining 

energy consumption and energy factor, and safety recommendations.

2.3 This standard does not include methods of testing household refrigerators, household wine chillers and 

household freezers using gas fuel as defined in ANSI Standard Z21.19.

2.4 The principal subdivisions of this standard are as follows:

Section 1 - Purpose

Section 2 - Scope

Section 3 - Definitions

Section 4 - Method for Computing Total Refrigerated Volume and Total Shelf Area of Household 

Refrigerators and Household Wine Chillers.

Section 5 - Method for Computing Total Refrigerated Volume and Total Shelf Area of Household Freezers

Section 6 - Method for Computing the Volume of Special Features of Household Refrigerators and 

Household Freezers

Section 7 - Performance Test Procedures and Recommended Levels of Performance for Household 

Refrigerators and Household Freezers

Section 8 - Method for Determining the Energy Consumption of Household Refrigerators, Household Wine 

Chillers and Household Freezers

Section 9 - Method for Computing the Energy Factor of Household Refrigerators, Household Wine Chillers 

and Household Freezers

EERE-2006-BT-STD-0126 COMMENT 46
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Section 10 - Durability and Condensate Test Procedures for Household Refrigerators and Household 

Freezers

Section 11 - Safety of Household Refrigerators, Household Wine Chillers and Household Freezers

3. DEFINITIONS

3.1 Household Refrigerator. A cabinet or any part of a cabinet which is designed for the refrigerated storage of 

food at temperatures above 32°F (0°C), which has a source of refrigeration and which is intended for household 

use. It may include a compartment for the freezing and storage of ice and/or for storage of food at temperatures 

below 32°F (0°C).

3.1.1 Basic Refrigerator. A refrigerator which includes a low temperature compartment for the freezing 

and storage of ice and intended for short-term storage of food at temperatures below 32°F (0°C) and normally 

above 8°F (-13.3°C). It is characterized by a refrigerated surface(s) that partially encloses the low 

temperature compartment and cools the fresh food compartment by natural convection. It frequently has a 

partition (called the chiller or drip tray) which when removed or adjusted exposes an additional area of the 

refrigerated surface to the fresh food compartment.

3.1.1.1 Class I. A basic refrigerator with a low temperature frozen food storage compartment greater than 

0.5 cubic feet in volume capable of maintaining temperatures at or below 15oF (-9.4oC).

3.1.1.2 Class II. A basic refrigerator with a low temperature compartment greater than 0.5 cubic feet in 

volume capable of maintaining temperatures below 32oF (0oC) and normally above 15oF (-9.4oC)

3.1.2 All-Refrigerator. A refrigerator which does not include a compartment for the storage of food at 

temperatures below 32°F (0°C). It may include a compartment of 0.5 cu. ft. (14.2 L) or less for freezing and 

storage of ice.

3.1.3 Combination Refrigerator-Freezer. A cabinet which consists of two or more compartments, with at 

least one of the compartments designed for the refrigerated storage of foods at temperatures above 32°F (0°C) 

and with at least one of the compartments designed for the freezing and storage of frozen foods at 

temperatures of 8°F (-13.3°C) average or below, and typically capable of being adjusted by the user to a 

temperature of 0°F (-17.8°C) or below.

3.2 Household Freezer. A cabinet which is designed for the extended storage of frozen food at an average 

temperature of 0°F (-17.8°C) or below and with inherent capability for freezing of food, which has a source of 

refrigeration, and which is intended for household use.

3.2.1 Chest Type. A household freezer which is accessible from the top.

3.2.2 Upright (Vertical) Type. A household freezer which is accessible from the front.

3.3 Household Wine Chiller. A cabinet designed exclusively for the cooling and storage of wine.

3.4 Defrost System. A means to remove frost and/or ice from the refrigerated surfaces. Types of defrost 

systems that apply to household refrigerators and household freezers are:

3.4.1 Manual Defrost. Manual defrost is one in which defrosting of the refrigerated surface is 

accomplished by natural or manual means with manual initiation and manual termination of the overall 

defrost operation.

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3.4.2 Semi-Automatic Defrost. A system in which the defrost cycle is manually initiated and automatically 

terminated, with automatic resumption of normal refrigeration at the conclusion of the defrost operation. 

Defrost water is disposed of automatically or collected in a container for subsequent manual removal. A 

means of accelerating the rate of defrost may or may not be included in the product design.

3.4.3 Automatic Defrost (No-Frost). A system in which the defrost cycle is automatically initiated and 

terminated, with resumption of normal refrigeration at the conclusion of the defrost operation. The system 

automatically prevents the permanent formation of frost on all refrigerated surfaces. Nominal refrigerated 

food temperatures are maintained during operation of the automatic defrost system(s). The defrost water is 

disposed of automatically.

3.4.4 Partial Automatic (Cycle) Defrost (Household Refrigerators). A system in which the refrigerated 

surfaces of the freezer compartment are defrosted manually and the refrigerated surfaces of the fresh food 

compartment are defrosted automatically. Defrost water from the fresh food compartment is disposed of 

automatically or collected in a container for subsequent manual removal.

3.5 Air Ducts. Passages which direct the flow of air.

3.6 Automatic Icemaker. A device, connected to a water supply, which automatically produces, harvests, and 

stores ice in a storage bin, with means to automatically interrupt the harvesting operation when the bin is filled to 

a pre-determined amount.

3.6.1 Cyclic Type. An automatic icemaker with separate and sequential water fill, freezing and harvesting 

phases of the ice-making operation.

3.6.2 Non-Cyclic (Continuous) Type. An automatic icemaker with simultaneous water supply, freezing 

and/or harvesting phases in the ice-making operation.

3.6.3 Ice Storage Bin Rating. The capacity of an automatic icemaker storage bin is the average weight of 

ice contained in the bin when the bin-fill device terminates the ice-making operation.

3.7 Baffle. A plate, wall or partition which is designed to perform one or more of the following functions:

(a) Prevent contact of food with refrigerated surfaces.

(b) Prevent dripping of condensate on food.

(c) Regulate and/or direct circulation of refrigerated air.

3.8 Cabinet Breaker Strip. A separate insulating element or integral extension of the cabinet interior surfaces 

around the periphery of the cabinet door or drawer opening(s) which functions as a thermal barrier to minimize 

heat flow to the interior of the cabinet.

3.9 Drip (Drain) Trough. A device for channeling water.

3.10 Door

3.10.1 Right-hand Door. A door that is hinged on the right-hand side when viewed facing the cabinet.

3.10.2 Left-hand Door. A door that is hinged on the left-hand side when viewed facing the cabinet.

EERE-2006-BT-STD-0126 COMMENT 46
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3.10.3 Door Dike. A projection on the door which extends into the refrigerated compartment(s) and which 

functions primarily as a barrier to minimize heat flow to the interior of the cabinet.

3.11 Fan Shroud. A protective housing which surrounds the fan and which may also direct the flow of air.

3.12 Ice Tray. A container for freezing water into ice.

3.12.1 Automatic Fill Ice Tray. A tray which is automatically filled with water for freezing into ice.

3.12.2 Ice Tray Capacity Rating. The weight of water with the tray filled per manufacturer's instructions 

(if specified) or to within 1/8 inch (within 3 mm) of the top and with the grids in place.

3.13 Liner. The enclosure forming the interior of the fresh food compartment and/or some freezer 

compartment(s). The complete liner comprises the compartment liner in the cabinet, the exposed breaker strip 

surfaces and the door liner(s).

3.14 Plaque and/or Sump. The volume generated by embossed areas on the interior surfaces of the fresh food 

and/or freezer compartment(s).

3.15 Shelf. Any generally horizontal surface within the cabinet which is provided for the storage of food.

3.15.1 Adjustable Shelf. One that can have its vertical position changed without the use of tools.

3.15.2 Door Shelf. Any surface on the door that can be used for the storage of food.

3.15.3 Full Shelf. One which essentially fills the interior cross-section of the cabinet.

3.15.4 Fractional Shelf. One which is less than either the width or the depth, or both, of the full shelf.

3.15.5 Revolving Shelf. One which can be either partially rotated, fully rotated or pivoted on its support.

3.15.6 Roll-out or Sliding Shelf. One which can roll or slide on its support(s).

3.16 Total Shelf Area

3.16.1 For household refrigerators, a calculated value based on the net areas of the main shelves, door 

shelves, bottoms of suspended containers or dispensers, and the bottom of the liner(s) of the fresh food and 

freezer compartments. (See Section 4.)

3.16.2 For household freezers, a calculated value based on the net areas of main shelves, door shelves, 

bottoms of suspended containers or dispensers, and the bottom of the liner(s). (See Section 5.)

3.17 Fresh Food Compartment. In a household refrigerator, that compartment(s) designed for the refrigerated 

storage of food at an average temperature above 32°F (0°C). Special compartments designed for the storage of 

fresh foods at temperatures near 32°F (0°C) shall be considered part of the fresh food compartment. Special 

compartments of combination refrigerator-freezers operating at average temperatures between 8°F (-13.3°C) and 

32°F (0°C) shall be considered part of the fresh food compartment.

3.18 Freezer Compartment. In a basic refrigerator, the compartment designed for short-term storage of food at 

temperatures below 32°F (0°C); in a combination refrigerator-freezer, the compartment(s) designed for storage of 

foods at temperatures of 8°F (-13.3°C) average or lower; and in a household freezer the compartment(s) designed 

EERE-2006-BT-STD-0126 COMMENT 46
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for extended storage of frozen foods at an average temperature of 0°F (-17.8°C) or below and having inherent 

capability for freezing of food.

3.19 Special Compartments. Compartments designed for maintaining special environmental conditions for a 

particular type of product or purpose.

3.19.1 Butter, Margarine, or Cheese Compartment(s). A compartment provided for the storage of butter, 

margarine or cheese.

3.19.2 Butter or Margarine Conditioner. An enclosed compartment which is provided for the storage of 

butter and/or margarine and which has an auxiliary temperature control.

3.19.3 Chiller or Drip Tray. A tray or drawer which is located beneath the refrigerated surfaces of a 

manual or semi-automatic defrosting refrigerator for chilling of food and/or collecting of water during 

defrosting. It may also serve as a baffle to regulate compartment temperature.

3.19.4 Crisper. An enclosed compartment or container provided primarily to retard the dehydration of fruits 

and vegetables.

3.19.5 Ice Storage Bin. A container in which ice can be stored.

3.19.6 Meat Keeper. An enclosed compartment or container which is designed for the storage of meat at or 

near 32°F (0°C).

3.20 Steady State Condition. Steady state conditions exist if the temperature measurements in all measured 

compartments taken at 4 minute intervals, or less, during a stabilization period are not changing at a rate greater 

than 0.042°F (0.023°C) per hour as determined by the applicable condition of (a) or (b).

(a) The average of the measurements during a 2 hour period if no cycling occurs or during a number of complete 

repetitive compressor cycles through a period of no less than 2 hours is compared to the average over an 

equivalent time period with at least 3 hours elapsed between the two measurement periods.

(b) If defrost controls are operative during the test and (a) above cannot be used, the average of the measurements 

during a number of complete repetitive compressor cycles through a period of no less than 2 hours and including 

the last complete cycle prior to a defrost period, or if no cycling occurs, the average of the measurements during 

the last 2 hours prior to a defrost period is compared to the same averaging period prior to the following defrost 

period.

3.21 Volume

3.21.1 Fresh Food Compartment Volume. That portion of the total refrigerated volume above 32°F (0°C) 

average for basic refrigerators and all-refrigerators or above 8°F (-13.3°C) average for combination 

refrigerator-freezers. (See Section 4.) Regardless of its temperature, the volume of the refrigerated chiller 

tray and other special compartment(s) for storage of fresh food near 32°F (0°C) is to be included in the fresh 

food compartment volume.

3.21.2 Freezer Compartment Volume. That portion of the total refrigerated volume below 32°F (0°C) 

average for basic refrigerators (exception, see Paragraph 3.21.1) and 8°F (-13.3°C) average or below for 

combination refrigerator-freezers and household freezers. (See Section 4 and Section 5.)

EERE-2006-BT-STD-0126 COMMENT 46
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3.21.3 Total Refrigerated Volume. For a household refrigerator, the sum of the fresh food compartment 

volume and the freezer compartment volume.

For a household freezer, the freezer compartment volume.

3.21.4 Adjusted Total Volume. For refrigerators and refrigerator-freezers: The sum of (i) the fresh food 

compartment volume in cubic feet and (ii) the product of an adjustment factor and the net freezer 

compartment volume in cubic feet. (See Paragraph 9.3).

3.22 Anti-Sweat Heater. A device incorporated into the design of a household refrigerator or freezer to prevent 

the accumulation of moisture on exterior surfaces of the cabinet under conditions of high ambient humidity. This 

heater may be switchable from fully-on to fully-off or some condition of operation in-between.

4. METHOD FOR COMPUTING TOTAL REFRIGERATED VOLUME AND TOTAL SHELF AREA 

OF HOUSEHOLD REFRIGERATORS AND HOUSEHOLD WINE CHILLERS

4.1 Scope of Section 4. This section describes methods for computing total refrigerated volume (see Paragraph 

3.21) and total shelf area (see Paragraph 3.16) of household refrigerators and household wine chillers. Section 

4 is intended to provide a uniform means of determining the size, taking into consideration the special features 

and/or functional components which are located within the refrigerated compartment(s). It is not intended to 

provide a means of measuring the food-storage capacity.

4.2 Total Refrigerated Volume (see Paragraph 3.21)

4.2.1 Volumes

4.2.1.1 Volumes to Be Included. The total refrigerated volume is to include:

(a) Volume occupied by special features, such as baskets, crispers, meat pans, chiller trays, icemakers 

(including storage bins for automatic icemakers) and water coolers.

In the case of through-the-door ice and/or liquid dispensers, the volume occupied by all parts of the 

apparatus that are components of its design. Volume included shall be the average height x average width x 

average depth, or the actual volume as indicated by fig. 4-18. This means do not deduct the conveying 

chute and insulating hump. Include that portion of the volume of the fountain cavity extending to the door 

front surface (between the inner door liner and outer door face) even though that volume is forward of the 

door liner. The volume shall not include the escutcheon, paneling or anything that would extend the volume 

forward of the outer face of the door. See diagram fig. 4-18. 

(b) Volume occupied by cabinet shelves, door shelf fronts and bottoms, and doors of special feature 

compartments located within the door.

(c) Volume occupied by features, such as light shields, trims, and aesthetic items, which are removable 

without the use of tools.

4.2.1.2 Volumes to Be Deducted. The total refrigerated volume is not to include:

(a) Volume occupied by parts necessary for the proper functioning of the unit, such as evaporator doors, 

cooling coils, evaporators, air ducts, drip troughs, condensers, baffles, fan shrouds and control boxes.

(b) Volume occupied by door dikes that do not serve as shelves.

EERE-2006-BT-STD-0126 COMMENT 46
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(c1) Collective volume occupied by partitions and projections within the door(s) enclosing a fresh food 

compartment as defined in paragraph 3.17 that do not serve as shelves. If the total of these volumes equals 

or exceeds 0.05 cu. ft. (1.4 L), deduct the total. If the total does not exceed 0.05 cu. ft. (1.4 L), do not deduct 

the total.

(c2) Collective volume occupied by partitions and projections within the door(s) enclosing a freezer 

compartment as defined in paragraph 3.18 that do not serve as shelves. If the total of these volumes equals 

or exceeds 0.05 cu. ft. (1.4L), deduct the total. If the total does not exceed 0.05 cu. ft. (1.4 L), do not deduct 

the total. 

(d) Volume between the deductible door dikes and cabinet breaker strips or adjacent liner wall.

(e1) Collective volume occupied by fixed projections in a fresh food compartment as defined in paragraph 

3.17, such as control knobs, shelf hangers, shelf and pan rails, and escutcheons. If the total of these volumes 

equals or exceeds 0.05 cu. ft. (1.4 L), deduct the total. If the total does not exceed 0.05 cu. ft. (1.4 L), do not 

deduct the total.

(e2) Collective volume occupied by fixed projections in a freezer compartment as defined in paragraph 

3.18, such as control knobs, shelf hangers, shelf and pan rails, and escutcheons. If the total of these volumes 

equals or exceeds 0.05 cu. ft. (1.4 L), deduct the total. If the total does not exceed 0.05 cu. ft. (1.4 L), do not 

deduct the total.

4.2.2 Method of Computation

4.2.2.1 All linear dimensions are to be measured to the nearest 1/16 inch (nearest 2 mm) or better.

4.2.2.2 Divide the fresh food compartment volume and the freezer compartment volume into various 

sections having similar width and depth dimensions (see Figures 4-1 through 4-6).

4.2.2.3 Calculate the volume of each section and the volume of all shaded spaces shown in Figures 4-1 

through 4-6. Summate separately the volumes of the fresh food compartment sections and freezer 

compartment sections to determine the total unadjusted fresh food compartment volume and the total 

unadjusted freezer compartment volume.

4.2.2.4 Deduct from both the total refrigerated spaces (the total unadjusted fresh food compartment volume 

and the total unadjusted freezer compartment volume) the volumes of those items listed in Paragraph 

4.2.1.2 and shown with double cross-hatching in Figures 4-1 through 4-12 in order to determine the fresh 

food compartment volume and the freezer compartment volume.

4.2.2.5 Determine the total refrigerated volume by adding the fresh food compartment volume and the 

freezer compartment volume.

4.2.3 Data To Be Recorded. The total refrigerated volume is to be recorded to the nearest 0.1 cu. ft. 

(nearest 1.0 L).

The fresh food compartment volume is to be recorded to the nearest 0.01 cu. ft. (nearest 0.1 L).

The freezer compartment volume is to be recorded to the nearest 0.01 cu. ft. (nearest 0.1 L).

EERE-2006-BT-STD-0126 COMMENT 46
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4.3 Legend for Figures 4-1 through 4-12. Figures 4-1 through 4-12 show typical household refrigerators, 

and are not intended to cover all design variations. However, a combination of components from the various 

figures may be used for other designs.

The dimension symbols used in the figures are:

HG - Height of fresh food compartment and wine storage compartment.

HF - Height of freezer compartment.

WG - Width of fresh food compartment and wine storage compartment.

WF - Width of freezer compartment.

DG - Depth of fresh food and wine storage compartment.

DF - Depth of freezer compartment.

DG3 - Subscript numerals are typical of section variations used to compute individual volumes.

 The cross-hatchings used in the figures indicate:

 Volume to be included.

 Volume to be deducted.

4.4 Total Shelf Areas (see Paragraph 3.16). (Not applicable to wine chillers).

4.4.1 Areas. The total shelf area is to be determined from the areas of the main shelves, door shelves, bottoms 

of suspended containers or dispensers, and the bottom of the liner(s) of the fresh food, and freezer 

compartments.

4.4.2 Clearances. The area of any part of a shelf in the fresh food compartment which has less than 4 inches 

(10.2 cm) clearance above the shelf is not to be included in the total shelf area, except on the door or as 

otherwise provided in Paragraph 4.4.3.

4.4.3 Method of Computation

4.4.3.1 Units of Measurements. All linear dimensions are to be measured to the nearest 1/16 inch (nearest 

2 mm) or better.

4.4.3.2 Shelves in Fresh Food Compartment.

4.4.3.2.1 Full Shelves and Liners. The area of the full shelves and of the bottom of the liner(s) is to be 

the product of the mean depth and mean width as shown in Figures 4-13 and 4-14.

If the bottom of the liner(s) cannot qualify as a full shelf, its area is to be computed as the area of a cutout 

shelf or a fractional shelf.

The depth dimension used for computing the shelf area is to be measured from the front of the shelf. (See 

Figures 4-13 and 4-14.)

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The depth of the shelf is to be the distance from the front edge of the shelf to the rear liner or to a point 11⁄2 

inches (3.8 cm) beyond the rear edge of the shelf, whichever is less. (See Figures 4-13 and 4-14.)

The width of a shelf is to be measured to the liner side(s) or to a point 11⁄2 inches (3.8 cm) beyond the shelf 

edge, whichever is less. (See Figures 4-13 and 4-14.)

4.4.3.2.2 Fractional Shelves. The area of fractional shelves is to be the product of the width and depth, 

including the allowable overhang, determined in accordance with Paragraph 4.4.3.2.1 and Figure 4-14.

4.4.3.2.3 Cutout Shelves. When any part of a full shelf or a fractional shelf is cut out, the area of the 

cutout which exceeds the allowable overhang as determined in accordance with Paragraph 4.4.3.2.1 is to be 

deducted from the calculated shelf area. (See Figure 4-14.)

4.4.3.3 Shelves in Freezer Compartment. The area of shelves in the freezer compartment is to be included 

in the total shelf area provided there is a minimum clearance of 2 inches (5.1 cm) above such shelves. (See 

Figures 4-13 and 4-14.)

4.4.3.4 Door Shelves. The area of door shelves is to be the product of the mean depth and mean width of 

the shelf. The area of any part of a door shelf having an access clearance of less than 2 inches (5.1 cm) is not 

to be included in the total shelf area. (See Figures 4-13 and 4-14.)

4.4.3.5 Suspended Containers. The area of the bottom of suspended containers is to be included in the 

total shelf area provided there is a minimum clearance of 2 inches (5.1 cm) above the bottom of the container. 

(See Figure 4-16.)

4.4.4 Data To Be Recorded. The total shelf area is to be recorded to the nearest 0.1 ft2 (nearest 100 cm2).

4.5 Legend for Figures 4-13 through 4-17. Figures 4-13 through 4-17 show typical shelf configurations for 

household refrigerators, and are not intended to cover all design variations. However, a combination of 

components from the various figures may be used for specific designs. The dimension symbols used in the 

figures indicate:

D - Depth of cabinet or shelf from front edge of shelf.

W - Width of cabinet or shelf.

 - Area to be deducted.

EERE-2006-BT-STD-0126 COMMENT 46
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Deduct volume between evaporator

top and liner top unless 2" or more

and is recommended by manufacturer as freezer compartment

volume (see Fig. 4-6)

Include volume occupied

by egg shelves

Include volume occupied

by horizontal shelves,

shelf fronts or

compartment doors

Deduct the bottom

dike or the volume

between it and cabinet

wall when bottom 

dike is not used as a 

Single Door Combination Refrigerator-Freezer or Wine Chiller (Total Refrigerated Volume)

Include volume of 

shaded plaques and

sumps (see Fig. 4-5)

Fig. 4-1

Include volume occupied

by chiller tray

Deduct volume between

evaporator and liner side

and rear walls if less than 4"

(see Figs. 4-6, 4-7 and 4-8)

DF1

D G4

D

D

DG1

HG5

HG3

HG2

HG1

G2

G3

When vertical dikes

are cut back, deduct

the volume occupied 

by the actual dike

DG5

HF1

Less than 2"

Less than 4"

Deduct volume occupied

by evaporator

(see Figs. 4-6, 4-7 and 4-8)

Deduct volume occupied by

evaporator door (see Fig. 4-6)

Deduct volume occupied by top

dike and space between it and

cabinet wall (see Fig. 4-5)

Include volume between

interior door panel and

evaporator door if 2" or more

providing there are shelves

on the door

2"

HG4

For Legend See Par. 4.3

shelf (see fig. 4.5)

EERE-2006-BT-STD-0126 COMMENT 46
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D F3

D F2

DF1

HF2

HF1

HF3

DG4

H G4

D G3

D G2

D G1

HG3

HG2

H G1

For Legend See Par. 4.3

If less than 4",

deduct volume above

evaporator

Deduct volume occupied

by evaporator, drain

trough, drain space,

and space between

evaporator and liner wall

If less than 4", deduct

volume below trough

Deduct volume occupied

by projections formed

into liner for compressor

clearance, insulation, etc.

Include volume of

liner plaques and

sumps (see Fig. 4-5)

Deduct space occupied by evaporator door

(see Fig. 4-7 and 4-8)

Deduct volume occupied by top

dike and space between it and 

cabinet wall (see Fig. 4-5)

Include volume between

bottom dike and cabinet

wall when bottom dike

is used as a shelf (see fig. 4-5)

Include volume occupied

by horizontal shelves,

egg shelves, shelf fronts

Single Door Combination Refrigerator-Freezer or Wine Chiller (Total Refrigerated Volume)

Fig. 4-2

or compartment doors

EERE-2006-BT-STD-0126 COMMENT 46
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by top dike and space

H

D

H

D

D

H

H

D

4"

D F

H F

For Legend See Par. 4.3

Deduct volume occupied

by air ducts or evaporator

(see Fig. 4-9 and 4-10)

Include volume above

evaporator if 4" or more

Deduct volume occupied

by evaporator, drain trough,

drain space, and space

between evaporator and

liner wall

Deduct volume occupied

by projections formed into

liner for compressor

clearance, insulation, etc.

Include volume of

liner plaques and

sumps (see Fig. 4-5)

Deduct volume occupied

between it and cabinet wall

(see Fig. 4-5)

Include volume occupied

by horizontal shelves, shelf

or compartment doors

Include volume between

bottom dike and

cabinet wall when bottom dike

is used as a shelf(see Fig. 4-5)

Two-Door Combination Refrigerator-Freezer with Top Mounted Freezer (Total Refrigerated Volume)

Fig. 4-3

G4

G4

G3

G3

G2

G2

G1

G1

EERE-2006-BT-STD-0126 COMMENT 46
13

For Legend See Par. 4.3

D

D

DF1

DF2

Fig. 4-4

Two-Door Combination Refrigerator-Freezer with Bottom Mounted Freezer (Total Refrigerated Volume)

HF1

HF2

H

H

D

H

HG4

DG4

G3 G3

G2

G2

G1

G1

Deduct volume occupied by

top dike and space between

it and cabinet wall (see Fig. 4-5)

Include volume occupied by

egg shelves, horizontal 

shelves, shelf fronts 

or compartment doors

Include volume between

bottom dike and cabinet

wall when bottom dike is

used as a shelf (see Fig. 4-5)

Include volume of

shaded liner plaques

and sumps (see Fig. 4-5)

Deduct volume occupied

by evaporator shrouds

when fixed or necessary

to system function

Deduct volume occupied by

evaporator, drain trough,

drain space and space

between evaporator and

liner walls

Include volume occupied by

evaporator shrouds which

are non-functional and

removable

Deduct volume occupied by

fan shrouds, fan covers,

air grilles, etc., when fixed or

necessary to system function

(see Fig. 4-11)

Nonfunctional and

removable shroud

EERE-2006-BT-STD-0126 COMMENT 46
14

FIGURE 4-5

FRESH FOOD COMPARTMENT FREEZER COMPARTMENT

Deduct volume occupiedby evaporator, drain trough,drain space and spacebetween evaporator andliner wallDeduct volume occupied by projections formed intoliner for compressorclearance insulation, etc.

Deduct volumeoccupied by topdike and spacebetween it andcabinet wallInclude volumeoccupied byhorizontal shelves,shelf fronts orcompartment doorsInclude volumebetween bottomdike and cabinetwall when bottomdike is used asa shelf Include volume ofliner plaques andsumps

Deduct volumeoccupied byair ducts

EERE-2006-BT-STD-0126 COMMENT 46
15

or

W W

Door Dike and Liner Plaque Dimensions (Total Refrigerated Volume)

D

Plaque or sump

Y

X

D

For Legend See Par. 4.3

Fig. 4-6

Deduct volume occupied by dikes

or space between dikes on adjacent

doors

X/2

Deductible horizontal or vertical

dikes which do not serve as

shelves (see 4.2.2)

Deductible horizontal or vertical

partitions which do not serve as

shelves (see 4.2.2)

Deduct volume occupied by vertical door

dikes and partitions for depth "D" and width "W" 

Note: Dimensions for deductible

horizontal dikes shall be determined

by this same method

Determine liner plaque or sump

area by dimensions "X" and "Y".

Dimension "Y" is located at each

end by points established by X/2.

D/2

Cabinet wall

D/2

W or W G F

H or H G F

EERE-2006-BT-STD-0126 COMMENT 46
16

Side View Front View

Evaporator With Open Sides

Less than 2"

Less than 4"Less than 4"

Less than 4"

Less than 4"Less than 4"

Less than 4"

Evaporator With Closed Top, Bottom, Sides and Back

Evaporator With Open Back

Evaporator Applications (Total Refrigerated Volume)

Fig. 4-7

For Legend See Par. 4.3

EERE-2006-BT-STD-0126 COMMENT 46
17

Side View

Less than 4"

Less than 4"

Evaporator With Open Top and Bottom

Evaporator With Open Top and Back

Evaporator With Shelf, Open Top and Partial Back

Include volume behindopen-back evaporator

Deduct volume behindclosed-back evaporatorif dimension is less than 4"

Evaporator Applications (Total Refrigerated Volume)

4" or more 2" or more

Front View

Fig. 4-7

(Continued)

For Legend See Par. 4.3

Less than 4" Less than 4"

Less than 4"

EERE-2006-BT-STD-0126 COMMENT 46
18

(see Fig. 3-3)

Side

For Legend See Par. 4.3

Front View

Fig. 4 -7

Evaporator Applications (Total Refrigerated Volume)

(Continued)

SERPENTINE COIL WITH OPEN AREA

A

Less than 4"

Section A - A

4" or more

A

Less than 4"

EERE-2006-BT-STD-0126 COMMENT 46
19

Less than 4"

Front view

Fig. 4-8

Evaporator Door Deductions (Total Refrigerated Volume)

Plate or wires

Fin and tube

Tube on plate or wire

Fig. 4-9

Types of Evaporators (Total Refrigerated Volume)

Less than 2"

For Legend See Par. 4.3

Side view

Deduct volume between tubes if

dimension is less than 11⁄2"

11⁄2"

tions if dimension is less than 11⁄2"

Deduct volume between convolu11⁄2"

Less than 4"

EERE-2006-BT-STD-0126 COMMENT 46
20

Exterior cabinet

Volume in Freezer Compartment Occupied by Air Duct (Total Refrigerated Volume)

Fig. 4 - 10

Deduct volume occupied

by air duct or fan shroud

Liner wall

Liner wall

Exterior cabinet

For Legend See Par. 4.3

Volume in Freezer Compartment Occupied by Evaporator in Forced-air Systems (Total Refrigerated Volume)

Fig. 4 - 11

Deduct volume occupied

by evaporator

EERE-2006-BT-STD-0126 COMMENT 46
21

For Legend See Par. 4.3

Deduct volume above shrouds or covers, air

grilles, etc., if less than 4"

Deduct volume occupied by fan shrouds, fan

covers, air grilles, etc., when fixed or

necessary to system function

Volume in Fresh Food Compartment Occupied by Fan Shrouds, Etc. (Total Refrigerated Volume)

Fig. 4-12

Evaporator

Include volume above evaporator

if 4" or more

Evaporator

Less than 4"

4"

EERE-2006-BT-STD-0126 COMMENT 46
22

Shelf Clearance Requirements (Total Shelf Area)

Fig. 4-13

Do not include area unless

there is 4" or more in height 

between overlapping door

shelves and cabinet shelves

Do not include area unless

there is 2" or more in height

between overlapping door

shelves and freezer shelves

For Legend See Par. 4.5

Do not include space beyond 11⁄2"

from shelf

Include space beyond shelf when

11⁄2" or less

Refrigerator shelf area must have a

minimum clearance of 4" above it

Include overhang beyond 

shelf into plaque*

Freezer shelf area must have a 

minimum clearance above it of 2"

See Fig. 4-16 for beveled liner

11⁄2"

11⁄2"

PLUS

11⁄2" OR LESS

11⁄2" OR LESS

4" OR

MORE

4" OR

MORE 4" OR

MORE

4" OR MORE

4" OR MORE

2" OR MORE

2" OR MORE

D

D

D

D

D

D

D

* To be included, any shelf area (except on the doors) must have at least 4" clearance above it in the fresh food compartment and 2" in the

freezer compartment. These clearance limitations do not apply to the door shelves (see Fig. 4-14). A minimum overhang of 11⁄2" at the rear

of main shelves in the fresh food and freezer compartments may be included in the shelf depth provided the overhang conforms with the 

4" and 2" clearance limitations. 

D

EERE-2006-BT-STD-0126 COMMENT 46
23

D

W

W D W

B

Y

D

W

A

D

X

W

For Legend See Par. 4.5

Deduct area of all cutouts as noted

Deduct this area generated by "X" and "Y"

CUT-OUT SHELF

FULL SHELF

Do not include

FRACTIONAL SHELF

FRACTIONAL SHELVES

Width and Depth Requirements (Total Shelf Area)

Fig. 4-14

11⁄2" OR

LESS

11⁄2" OR LESS

11⁄2"

11⁄2"

11⁄2"

11⁄2" OR LESS

Deduct this area generated by the amount that

"A" exceeds 3" and "B" exceeds 11⁄2"

11⁄2" OR

LESS

11⁄2" 11⁄2"

11⁄2" OR LESS

11⁄2" OR LESS

11⁄2"

Measure shelf width to include

allowable 11⁄2" overhang on

fractional shelves

Fractional shelves which

equal a full shelf shall be

included as a full shelf width

Fractional shelf width

which is less than full

shelf width

11⁄2"

11⁄2" OR LESS

Measure shelf width to liner wall

if space is 11⁄2" or less

EERE-2006-BT-STD-0126 COMMENT 46
24

For Legend See Par. 4.5

Use W when clearances above shaded area do not

comply with access, depth and clearance requirements

1

W

W

D

Local emboss

1 Shelf front

Doors (Total Shelf Area)

Fig. 4-15

Access to door shelf area must be 2" or more

before including shelf area

2" or more

2" or

more

D

D

D

D

D

11⁄2" or

more

11⁄2" or

more

2" or 

more

11⁄2" or

more

D/2

EERE-2006-BT-STD-0126 COMMENT 46
25

D

D1

H

2

H 2 (2" or 4")

(2" or more) W H

*

D

H/2

1

(2" or 4")

For Legend See Par. 4.5

Suspended Containers (Total Shelf Area)

FIGURE 4-16

Beveled Liner Surfaces

FIGURE 4-17

* There must be a minimum of 4" clearance in a fresh food compartment and 2" clearance in a freezer

 compartment between the bottom of a suspended container and the shelf beneath it to include the shelf

 area of both.

FRONT VIEW SIDE VIEW

Plaque, side or back

SHELF

SHELF

For beveled, sloped bottoms,

or plaqued liner walls, use

depth or width extended to

vertical line in compliance

with 4" clearance limitation

for fresh food compartment

and 2" clearance limitation

for freezer compartment.

NOTE:

EERE-2006-BT-STD-0126 COMMENT 46
26

Side View of Fountain

Top View of Fountain

Fig. 4-18

Measurement of Icemaker Volume

EERE-2006-BT-STD-0126 COMMENT 46
27

5. METHOD FOR COMPUTING TOTAL REFRIGERATED VOLUME AND TOTAL SHELF AREA OF 

HOUSEHOLD FREEZERS

5.1 Scope of Section 5. This section describes methods for computing total refrigerated volume (see Paragraph 

3.21) and total shelf area (see Paragraph 3.16) of household freezers.

Section 5 is intended to provide a uniform means for determining the size of the freezer, taking into consideration 

the special features and/or functional components which are located within the refrigerated compartment(s). It is 

not intended to provide a means of measuring the food storage capacity.

5.2 Total Refrigerated Volume

5.2.1 Volumes

5.2.1.1 Volumes to Be Included. The total refrigerated volume shall include:

(a) Volume occupied by special features, such as can or package racks, dividers or dispensers (provided such 

features are not projections -- see Paragraphs 5.2.1.2(c) and 5.2.1.2(e), baskets, compartment fronts, 

icemakers and non-refrigerated shelves.

(b) Volume occupied by door-shelf fronts and bottoms, doors of special feature compartments located within 

the door.

(c) Volume occupied by aesthetic items and features, such as light shields, trims and shelf, pan and basket 

rails, which are removable without the use of tools.

5.2.1.2 Volumes to Be Deducted. The total refrigerated volume is not to include:

(a) Volume occupied by parts necessary for the proper functioning of the unit, such as cooling coils, 

evaporators, air duct, drip trough, baffles, fan shrouds and control boxes.

(b) Volume occupied by door dikes that do not serve as shelves.

(c) Collective volume occupied by partitions and projections within the door(s) enclosing a compartment that 

do not serve as shelves. If the total of these volumes equals or exceeds 0.05 cu. ft. (1.4 L), deduct the total. If 

the total does not exceed 0.05 cu. ft., do not deduct the total.

(d) Volume between the deductible door dikes see Paragraph 5.2.1.2(b) and cabinet breaker strips or adjacent 

liner walls.

(e) Collective volume occupied by fixed projections, such as control knobs, shelf hangers, shelf and basket 

rails, and escutcheons. If the total of these volumes equals or exceeds 0.05 cu. ft. (1.4 L), deduct the total.. If 

the total does not exceed 0.05 cu. ft., do not deduct the total.

5.2.2 Method of Computation

5.2.2.1 All linear dimensions are to be measured to the nearest 1/16 inch (nearest 2 mm) or better.

5.2.2.2 Divide the total refrigerated volume into various sections having similar width and depth dimensions 

(see Figures 5-1 through 5-5).

EERE-2006-BT-STD-0126 COMMENT 46
28

5.2.2.3 Calculate the volume of each section and the volume of all shaded spaces shown in Figures 5-1 

through 5-6. Summate the volumes of the sections to determine the total unadjusted refrigerated volume.

5.2.2.4 Deduct from the total unadjusted refrigerated volume those items listed in Paragraph 5.2.1.2 and 

shown with double cross-hatching in Figures 5-1 through 5-9 in order to determine the total refrigerated 

volume.

5.2.3 Data to Be Recorded. The total refrigerated volume is to be recorded to the nearest 0.1 cu. ft. (nearest 

1.0 L).

5.3 Legend for Figures 5-1 through 5-9. Figures 5-1 through 5-9 show typical freezers and are not intended to 

cover all design variations. However, a combination of components from the various figures may be used for 

specific designs.

The dimension symbols used in the figures are:

H - Height of compartment.

W- Width of compartment.

D - Depth of compartment.

D4- Subscript numerals are typical of section

variations used to compute individual volumes.

The cross-hatchings used in the figures indicate:

 Volume to be included.

 Volume to be deducted.

5.4 Total Shelf Area (Vertical Freezer) (see Paragraph 3.16)

5.4.1 Area. The total shelf area is to be determined from the areas of the main shelves, door shelves, bottoms 

of suspended containers or dispensers, and the bottom of the liner(s).

5.4.2 Clearances. The area of any part of a shelf which has less than 2 inches (5.1 cm) clearance above the 

shelf is not to be included in the total shelf area, except on the door or as otherwise provided in Paragraph 5.4.3.

5.4.3 Method of Computation

5.4.3.1 Units of Measurements. All linear dimensions are to be measured to the nearest 1/16 inch (nearest 

2 mm) or better.

EERE-2006-BT-STD-0126 COMMENT 46
29

5.4.3.2 Cabinet Shelves

5.4.3.2.1 Full Shelves and Liners. The area of the full shelves and of the bottom of the liner(s) is to be 

the product of the mean depth and mean width as shown in Figures 5-10 and 5-11. If the bottom of the 

liner(s) cannot qualify as a full shelf, its area is to be computed as the area of a cutout shelf or a fractional 

shelf.

The depth dimension used for computing the shelf area is to be measured from the front of the shelf. (See 

Figures 5-10 and 5-11).

The depth of the shelf is to be the distance from the front edge of the shelf to the rear liner or to a point 11⁄2 

inches (3.8 cm) beyond the shelf, whichever is less (see Figures 5-10 and 5-11).

The width of a shelf is to be measured to the liner side(s) or to a point 11⁄2 inches (3.8 cm) beyond the shelf 

edge, whichever is less (see Figure 5-11).

5.4.3.2.2 Fractional Shelves. The area of fractional shelves is to be the product of the width and depth, 

including the allowable overhang, and is to be determined in accordance with Paragraph 5.4.3.2.1 and 

Figure 5-11.

5.4.3.2.3 Cutout Shelves. When any part of a full shelf or a fractional shelf is cut out, the area

of the cutout which exceeds the allowable overhang as determined in accordance with Paragraph 5.4.3.2.1 

is to be deducted from the calculated shelf area (see Figure 5-11).

5.4.3.3 Door Shelves. The area of door shelves is to be the product of the mean depth and mean width of 

the shelf. The area of any part of a door shelf having an access clearance of less than 2 inches (5.1 cm) is not 

to be included in the net shelf area (see Figures 5-10 and 5-12).

5.4.3.4 Suspended Containers. The area of the bottom of suspended containers is to be included in the net 

shelf area provided there is a minimum clearance of 2 inches (5.1 cm) above the bottom of the containers. 

(See Figure 5-13).

5.4.4 Data To Be Recorded. The net shelf area is to be recorded to the nearest 0.1 ft.2 (nearest 100 cm2).

5.5 Legend for Figures 5-10 through 5-14. Figures 5-10 through 5-14 show typical shelf configurations for 

household freezers and are not intended to cover all design variations. However, a combination of components 

from the various figures may be used for specific designs.

The dimension symbols used in the figures are:

 H - Height of compartment.

 W- Width of compartment.

 D - Depth of compartment.

D4- Subscript numerals are typical of section variations used to compute individual areas.

The cross-hatching used in the figures indicates area to be deducted.

EERE-2006-BT-STD-0126 COMMENT 46
30

Household Freezer (Total Refrigerated Volume) - Upright Type

D5

D4

D 3

D2

D1

H5

H4

H3

H 2

H 1

For Legend See Par 5.3

Fig. 5-1

Deduct volume occupied by top

dike and space between it and

cabinet wall (see Fig. 5-6)

Include volume occupied by

juice can shelves or racks

Include volume occupied by

horizontal shelves, shelf fronts

or compartment doors

Deduct the bottom dike or the 

volume between it and cabinet 

wall when bottom dike is not

used as a shelf (see Fig. 5.6)

Deduct volume occupied by projections

formed into liner for compressor

clearance, insulation, etc.

Deduct volume between refrigerated

shelf and liner sides and rear walls

if less than 11⁄2"

Deduct volume occupied by evaporator

(see Fig. 5-7)

Deduct volume below or above evaporator

if less than 2"

Deduct volume between evaporator and liner

rear walls if less than 4" or evaporator and

liner side walls if less than 11⁄2"

Deduct volume between evaporator

top and liner top unless 2" or more

and is recommended by manufacturer

as freezer total refrigerated volume

EERE-2006-BT-STD-0126 COMMENT 46
31

D

D

D

D

D

H

H

H

H

H

For Legend See Par. 5.3

Fig. 5-2

Household Freezer (Total Refrigerated Volume) - Upright Type

5

5

4

4

3

3

2

2

1

1

Deduct volume occupied by top dike

and space between it and cabinet wall

Include volume occupied by juice

can shelves or racks, horizontal

shelves, shelf fronts or

compartment doors

Include volume between interior

door panel and evaporator if 2"

or more providing there are

shelves on the door

Include volume between bottom dike

and cabinet wall when bottom

dike is used as a shelf (see Fig. 5-6)

Deduct volume occupied by evaporator

shrouds when fixed or necessary to

system function

Deduct volume occupied by

evaporator, drain trough, drain

space, and space between 

evaporator and liner wall

Include volume above or below

evaporator if 2" or more

Include volume occupied by

evaporator shrouds which are

nonfunctional and removable

Deduct volume occupied by

fan shrouds, fan covers, air

grills, etc., when fixed or

necessary to system function

(see Fig. 5-8 and 5-9)

Include volume of shaded liner plaques

and sumps (see Fig. 5-6)

EERE-2006-BT-STD-0126 COMMENT 46
32

W2

W1

H2

H1

W2

H2

H1

W

Fig. 5-3

Household Freezer (Total Refrigerated Volume) - Chest Type

Household Freezer (Total Refrigerated Volume) - Chest Type

Fig. 5-4

1

Deduct volume occupied by evaporator, drain

trough, drain space, shrouds or partitions when

fixed or necessary to system function (see

Fig. 5-7, 5-8 and 5-9)

For Legend See Par. 5.3

Include volume of shaded plaques

and sumps (see Fig. 5-6)

Deduct volume occupied by door dikes or

space between them and cabinet wall

Include volume of that portion of door dike

(and space between it and liner wall)

utilized as a package compartment bottom

when door is opened

Deduct volume occupied by projections

formed into liners for compressor or system

clearances, insulation, etc. (see Fig. 5-14)

EERE-2006-BT-STD-0126 COMMENT 46
33

Household Freezer (Total Refrigerated Volume) - Chest Type

Fig. 5-5

For Legend See Par. 5.3

H1

W1

W

H 2

2

Include volume occupied by projections

utilized as a package compartment 

front or bottom

Deduct volume of fixed partitions or

projections utilized as compartment 

ends or separators which individually

occupy a volume of more than 0.01

cubic foot (see Fig. 5-6)

Deduct volume occupied by evaporator, drain trough,

drain space, fans, fan covers, air grilles, shrouds or

partitions when fixed or necessary to system function

(see Fig. 5-8 and 5-9)

EERE-2006-BT-STD-0126 COMMENT 46
34

W

Cabinet wall

W W

Door Dike and Liner Plaque Dimensions (Total Refrigerated Volume)

D

Plaque or sump

Y

X

D

For Legend See Par. 5.3

Fig. 5-6

Deduct volume occupied by vertical

door dikes and partitions for depth

"D" and width "W"

Note: Dimensions for deductible

horizontal dikes shall be determined

by this same method

D/2

D/2

Deductible horizontal or vertical

partitions which do not serve as

shelves (see Par. 5.2.1.2)

Deductible horizontal or vertical

dikes which do not serve as shelves

(see Par. 5.2.1.2)

X/2

Determine liner plaque or sump

area by dimensions "X" and "Y".

Dimension "Y" is located at each

end by points established by X/2

Deduct volume occupied by dikes

or spaces between dikes on adjacent

doors

EERE-2006-BT-STD-0126 COMMENT 46
35

Plate or wires

Tube on plate or wire

Deduct volume between convolutions

if dimension is less than 11⁄2"

Fin and tube

Deduct volume occupied by

evaporator connecting tubes

Fig. 5-7

Types of Evaporators (Total Refrigerated Volume)

For Legend See Par. 5.3

11⁄2"

11⁄2"

Deduct volume between tubes if

dimension is less than 11⁄2"

Deduct volume of shaded area

between evaporator connector

tubes and liner walls if less

than 11⁄2"

Deduct volume of shaded area

when tube covers are used

EERE-2006-BT-STD-0126 COMMENT 46
36

Exterior cabinet

Volume Occupied by Air Duct (Total Refrigerated Volume)

Fig. 5-8

Deduct volume occupied by

air duct or fan shroud

Liner wall

Liner wall

Exterior cabinet

Volume Occupied by Evaporator in Forced-air Systems (Total Refrigerated Volume)

Fig. 5-9

Deduct volume occupied

by evaporator

For Legend See Par. 5.3

EERE-2006-BT-STD-0126 COMMENT 46
37

See Fig. 5-14 beveled liner

11⁄2"

For Legend See Par. 5.5

Fig. 5 - 10

Shelf Clearance Requirements (Total Shelf Area)

*

2" or more

Less than 2"

D

D

D

D

D

D

2"

2" D

2"

Shelf area must have

a minimum clearance

above it of 2"

Do not include area unless

there is 2" or more in height

between overlapping door

shelves and cabinet shelves

11⁄2"

Do not include space beyond

11⁄2" from shelf

Include space beyond shelf

when 11⁄2" or less

Less than 2"

(see Fig. 5-14)

Include overhang beyond

shelf into plaque*

*To be included, any shelf area (except the doors) must have at least 2" clearance above it. This clearance limitation

does not apply to the door shelves (see Fig. 5-12). A maximum overhang of 11⁄2" in front or rear of main shelves

may be included in the shelf depth provided the overhang conforms with the 2" clearance limitation

EERE-2006-BT-STD-0126 COMMENT 46
38

Y

B

D

W

W D W

D

W

A

D

X

W

For Legend See Par. 5.5

Deduct this area generated by the amount that

"A" exceeds 3" and "B" exceeds 11⁄2"

Deduct area of all cutouts as noted

Deduct this area generated by "X" and "Y"

CUT-OUT SHELF

FULL SHELF

Do not include

Measure shelf width to liner wall

if space is 11⁄2" or less

Measure shelf width to include

allowable 11⁄2" overhang on

fractional shelves

FRACTIONAL SHELF

FRACTIONAL SHELVES

Width and Depth Requirements (Total Shelf Area)

Fig. 5-11

11⁄2" or less

11⁄2" or less 11⁄2" or less

11⁄2"

11⁄2"

11⁄2" 11⁄2"

11⁄2" or less

11⁄2"

11⁄2"

11⁄2" or less

11⁄2" or less

11⁄2" or less

11⁄2"

Fractional shelves which

equal a full shelf shall be

included as a full shelf width

Fractional shelf width

which is less than full

shelf width

EERE-2006-BT-STD-0126 COMMENT 46
39

For Legend See Par. 5.5

Use W when clearances above shaded area do not

comply with access, depth and clearance requirements

1

W

W

D

Local emboss

1 Shelf front

Doors (Total Shelf Area)

Fig. 5-12

Access to door shelf area must be 2" or more

before including shelf area

2" or more

2" or

more

D

D

D

D

D

11⁄2" or

more

11⁄2" or

more

2" or 

more

11⁄2" or

more

D/2

EERE-2006-BT-STD-0126 COMMENT 46
40

D

D1

H

2

H2 (2")

(2" or more) W H

*

D

H/2

1

FRONT VIEW

For Legend See Par. 5.5

Suspended Containers (Total Shelf Area)

FIGURE 5-13

SIDE VIEW

* There must be a minimum of 2" clearance between the bottom of a suspended container and the shelf

 beneath it to include the shelf area of both.

Beveled Liner Surfaces (Total Shelf Area)

FIGURE 5-14

PLAQUE, SIDE OR BACK

SHELF

SHELF

NOTE: For beveled, sloped bottoms,

 or plaqued liner walls, use

 depth or width extended to

 vertical line in compliance

with 2" clearance limitation.

(2")

EERE-2006-BT-STD-0126 COMMENT 46
41

6. METHOD FOR COMPUTING THE VOLUME OF SPECIAL FEATURES OF HOUSEHOLD

REFRIGERATORS AND HOUSEHOLD FREEZERS

6.1 Scope of Section 6. This section describes methods for measuring the space occupied by and the space 

provided by special features occupying volume within the total refrigerated volume of household refrigerators 

and household freezers.

6.2 Special Features

6.2.1 Special features to be included for household refrigerators are for example: baskets, crispers, meat pans, 

chiller trays, water coolers, can or package racks, movable compartments such as drawers or trays and icemakers 

(including storage bins).

6.2.2 Special features to be included for household freezers are for example: baskets, pan or package racks, 

icemakers (including storage bins) and movable compartments such as drawers or trays.

6.2.3 Door features of household refrigerators and household freezers such as shelves, racks, rails, retainers, or 

any component that is attached or formed into the door liner and intended to improve its utility for storing jars, 

cans and packages, are not to be included in the category of a special feature that requires volume considerations.

Special features located in the door, such as crispers, liquid or ice dispensers, compartment doors, etc., are to be 

included in the volume calculations.

6.2.4 A freestanding special feature is one that rests freely on a shelf or on a storage compartment bottom such as 

an ice tray or a set-in pan.

6.2.5 A supported-fixed special feature is one that is supported in a fixed location such as an automatic icemaker 

or a chiller tray.

6.2.6 A supported-relocatable special feature is one that is supported in a location chosen by the user such as a 

meat pan or an egg container.

6.2.7 Storage Volume Occupied by Special Features (see Figures 6-1 and 6-2)

6.2.7.1 Freestanding Special Features. Calculate the volume occupied by freestanding special features on an 

individual basis as the product of the values of width, length and height of an encompassing right angle 

envelope for each feature. When special features are adjacent to each other, do not include volume between 

them more than once. Measure all linear dimensions to the nearest 1/16 inch (nearest 2 mm) or better.

6.2.7.2 Supported-Fixed Special Features. Calculate the volume occupied by supported-fixed special 

features on an individual basis as the product of adjusted values of width, length and height of each feature. 

These adjusted values are the actual average exterior dimensions of the feature, increased by the distances to 

adjacent surfaces or shelves where the volume defined by the distances is not readily accessible for normal use. 

A volume not readily accessible for normal use is defined as volume that is accessible only by removal of parts 

from the cabinet.

A volume adjacent to a special feature which has a dimension of less than 4 inches (10.2 cm) in the case of a 

fresh food compartment, or less than 2 inches (5.1 cm) in the case of a freezer compartment, is considered as 

not readily accessible for normal use unless specific means are provided for supporting stored articles and 

preventing their interference in the operation of the special feature.

EERE-2006-BT-STD-0126 COMMENT 46
42

In the case of icemakers or other features where the volume occupied by the feature is defined in part by the 

movements of parts associated with the mechanical operation of the feature, the adjusted value of width and 

length shall include the maximum dimension(s) required by the path of the moving part(s), increased by the 

distances to adjacent surfaces or shelves where the volume defined by these distances is not readily accessible 

for normal use. This includes the dimensions of any volume that is not readily accessible for normal use.

6.2.7.3 Supported-Relocatable Special Features. Calculate the volume occupied by supported-relocatable 

special features on an individual basis as the product of adjusted values of width, length and height of each 

feature with the feature located in the position occupying the least volume.

6.2.7.4 Volume If Claimed. Any volumes occupied by the special features to be claimed are stated to the 

nearest 0.01 cu. ft. (nearest 0.3 L.

6.2.8 Storage Volume Provided by Special Features (See Figures 6-1 to 6-3)

6.2.8.1 Freestanding Special Features. The storage volume provided by freestanding special features is the 

product of the average interior width, length and the height from the interior bottom to the cover of the 

container when installed in its normal position in use. For ice trays, ice storage bins, and liquid containers, the 

storage volume is the interior volume when filled to the maximum operating level. Measure all linear 

dimensions to the nearest 1/16 inch (nearest 2 mm) or better.

6.2.8.2 Supported-Relocatable Special Features (same as 6.2.8.1)

6.2.8.3 Supported-Fixed Special Features (same as 6.2.8.1)

6.2.8.4 Volume If Claimed Any volumes provided by special features to be claimed are stated to the nearest 

0.01 cu. ft. (nearest 0.3 L) 

EERE-2006-BT-STD-0126 COMMENT 46
43

FIGURE 6-1

Volumes Occupied by and Provided by Typical Free-standing

and Supported-Relocatable Special Features

OCCUPIED BY: PROVIDED BY:

EERE-2006-BT-STD-0126 COMMENT 46
44

Volumes Occupied by and Provided by Typical Free-standing

and Supported-Relocatable Special Features

FIGURE 6-1 (Continued)

OCCUPIED BY:

PROVIDED BY:

EERE-2006-BT-STD-0126 COMMENT 46
45

FIGURE 6-1 (Continued)

Volumes Occupied and Provided by Typical Free-Standing

and Supported-Relocatable Special Features

OCCUPIED BY:

PROVIDED BY:

EGG TRAYS

EERE-2006-BT-STD-0126 COMMENT 46
46

FIGURE 6-2

*

Volumes Occupied By and Provided By Typical 

Supported-Fixed Special Features

* Less Than 2 Inches

IIIustration of ice tray storage compartments.

Volumes to be included are dependent upon the dimensional requirements of Section IV. If the distance

in front or behind the storage compartment is 2 inches or more, that volume is not deducted.

Space Provided

Space Occupied

EERE-2006-BT-STD-0126 COMMENT 46
47

* *

FIGURE 6-2 (Continued)

OCCUPIED BY: PROVIDED BY:

BUTTER OR CHEESE COMPARTMENT

EERE-2006-BT-STD-0126 COMMENT 46
48

hp

h1 (Avg.)

(Avg.) 2 h

Volume Provided by Irregular Shaped Ice Buckets

or Free-standing Containers

FIGURE 6-3

=

either w or d2 (whichever is less)

4 hp

Volume Provided, ft 3 = (h1 . w . d1) + (h 2 . w . d2) +

hp . w . d 2

3

1728

d1

d2

(Avg. inside)

w

(Avg. inside)

EERE-2006-BT-STD-0126 COMMENT 46
49

FIGURE 6-3 (Continued)

or Free-standing Containers

Volume Provided by Irregular Shaped Ice Buckets

TOP OF BUCKET

p h

d

(Avg. Inside)

w

(Avg. Inside)

h

(Avg. Inside)

 . w . d) p (h

3 h . w . d + Volume Provided, ft3 = 1728 = either w or d (whichever is less) 4 hp

EERE-2006-BT-STD-0126 COMMENT 46
50

FIGURE 6-3 (Continued)

Volume Provided by Irregular Shaped Ice Buckets

or Free-standing Containers

h4

h1

d (Avg. inside)

w (Avg. inside)

3 h

Avg. h

2 h

Volume Provided, ft 3 = 1728

(hAvg. . w . d) + (hp . w . d) 3

=

either w or d (whichever is less)

4 hp

hAvg.= (h1 . d) + (h2 . d) + (h3 . w) + (h4 . w) 2(w + d)

EERE-2006-BT-STD-0126 COMMENT 46
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7. PERFORMANCE TEST PROCEDURES AND RECOMMENDED LEVELS OF PERFORMANCE 

FOR HOUSEHOLD REFRIGERATORS, HOUSEHOLD WINE CHILLERS AND HOUSEHOLD

FREEZERS

7.1 Scope of Section 7. This section describes uniform procedures for determining the performances of 

household refrigerators and household freezers under specified laboratory test conditions and establishes 

recommended levels of performance.

The performance test procedures in this section are:

7.5 No-load pull-down test.

7.6 Simulated load test (household refrigerators).

7.7 Simulated load test (household freezers).

7.8 Ice-making test.

7.9 Temperature rise test (household freezers).

7.2 Test Room

7.2.1 Ambient Temperature. The vertical ambient temperature gradient in any foot of vertical distance 

from 2 inches (5.1 cm) above the floor or supporting platform to a height 1 ft. (30.5 cm) above the top of 

the cabinet is not to exceed 0.5°F per ft. (0.9°C per m).

If a platform is used, it is to have a solid top with all sides open for air circulation underneath, and its top 

shall extend at least 1 ft. (30.5 cm) beyond each side and front of the cabinet and extend to the wall in the 

rear.

This platform must be used if the floor temperature is not within 3°F (1.7°C) of the specified ambient 

temperature (see Paragraph 7.4.3.1).

7.2.2 Ambient Relative Humidity. Wet bulb and dry bulb readings or equivalent are to be taken to 

determine ambient relative humidity when required. Except when specified for particular tests, the 

ambient relative humidity need not be controlled.

7.2.3 Air Circulation. The cabinet under test is to be shielded from forced air currents having a velocity 

of more than 50ft./minute (0.254) m/second).

7.2.4 Radiation. Shields are to be provided to prevent direct radiation from or to any heated or cooled 

surfaces whose temperature differs from the air temperature by more than 10°F (5.6°C).

7.3 Instruments

7.3.1 Temperature. The temperature measurements are to be made with one or more of the following 

instruments or their equivalents.

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(a) Glass thermometers (ambient measurements only).

(b) Thermocouples.

(c) Electric resistance thermometers and/or thermistors.

If a mass is used to increase the heat capacity of a temperature sensor, the total heat capacity of the mass is 

not to exceed that of 20 g of water.

Temperature readings are to be accurate to ± 1°F (± 0.6°C).

For analog measuring instruments the smallest scale division must not exceed 2°F (1.0°C). For digital 

measuring instruments the resolution must be 0.1°F (0.1°C) or better.

7.3.2 Electrical. Electrical measurements are to be made with the following instruments or their 

equivalents:

(a) Watt-hour meters. Analog Watt-hour meters are to be graduated in intervals no greater than 

0.01 kWh. Digital instruments must have a resolution of 0.001 kWh or better.

(b) Voltmeters. For analog measuring instruments the smallest scale division must not exceed 1 V. 

For digital measuring instruments, the resolution must be 0.1 V or better.

(c) Microammeters. The microammeters used for measuring current leakage is to be accurate to 

within ± 0.5% at an indication of 0.5 milliamperes, the meter terminal impedance -- 1,500 ohms 

shunted by a 0.15 μF capacitance.

Instruments used for measuring voltage and energy are to be accurate to within ± 0.5% of the 

quantity measured.

7.3.3 Time. Time measurements are to be made with a synchronous self-starting electric clock or a 

similar time-integrator.

7.3.4 Relative Humidity. The relative humidity is to be determined by use of a psychrometric chart and 

wet and dry bulb temperature readings taken with suitable psychrometric instrumentation having an 

accuracy of ± 0.5°F (0.3°C) or equivalent direct reading instrumentation with an accuracy of ± 2% RH.

7.3.5 Weight. Weight is to be determined by use of scales accurate to within 0.01 lb. (4.5 g).

7.4 General Test Requirements. For each test the cabinet is to be operated at the specified test conditions 

for a sufficient length of time to establish steady state condition (see Paragraph 3.19).

7.4.1 Power Supply. Unless otherwise specified, the electrical power supply is to be 115 ± 1 V, 60 Hz at 

the product service connection. The actual voltage is to be recorded as measured at the product service 

connection with the compressor motor operating.

EERE-2006-BT-STD-0126 COMMENT 46
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7.4.2 Test Sample. The cabinet with its refrigerating mechanism is to be assembled and set up as nearly as 

practicable in accordance with the printed instructions supplied with the cabinet. All packing materials and 

skid boards are to be removed. Chiller or drip trays are to be in their proper places during all tests. Outer door 

gaskets are to be checked for adequacy of seal to the cabinet and adjusted, if required. Containers and covers, 

and food shelves are not to be removed. Unless otherwise specified:

Baffles are to be open unless otherwise specified in the manufacturer's instructions;

Automatic icemakers are to be inoperative during the test;

Butter conditioners are set in the lowest energy usage position when adjustment is provided;

Convenience lights, radios, clocks, hygienic lamps, and the like are set at their lowest energy usage 

positions when adjustment is provided;

The anti-sweat heater switch is set at its highest energy consuming position;

Features which are electrically powered, manually initiated, and automatically terminated (such as 

customer operated dispensers, fast chill compartments, electric door openers, etc.) are operated at their 

lowest energy usage position;

Compartments which are convertible from refrigerator to freezer are operated in the highest energy usage 

position;

Other temperature controllable compartments (such as crispers convertible to meat keepers) are considered 

special compartments and are tested with controls set to provide the coldest temperature;

The evaporator in manual defrost models need not be defrosted prior to each test unless frost accumulation 

exceeds 1⁄4 inch (6 mm) in average thickness. Chiller and drip trays and interior of cabinet are to be dried 

prior to start of test after evaporator has been manually defrosted;

Ice trays and ice buckets related to non-automatic ice making are removed from the freezer section and the 

space vacated is loaded to 75% of its capacity with frozen food packages. Ice storage bins of automatic 

icemakers are to be full of frozen food packages;

Storage baskets in chest freezers are removed if they are removable without the use of tools;

Defrost controls are not to be operative during the tests.

Before the cabinet is tested, it shall be given a "run-in" period sufficient to assure a thorough working-in of 

mechanical parts, including operating controls. A "run-in" period of one week is recommended and, in no case, 

shall it be less than 24 hours of compressor run time. The "run-in" may be made at any convenient room 

temperature.

Unless otherwise specified, the cabinet shall be installed with all of its sides, except the back, more than 10 

inches (25.4 cm) from walls or ceiling to insure free air circulation. The space between the back and the test 

room wall or simulated wall shall be the minimum distance in accordance with the manufacturer's instructions 

or as determined by mechanical stops on the back of the cabinet.

Unless otherwise specified, cabinet doors shall be kept closed during all tests.

EERE-2006-BT-STD-0126 COMMENT 46
54

All leads from all measuring devices shall be brought outside of the cabinet in such a manner as to prevent air 

leakage.

7.4.3 Temperature Measurement.

7.4.3.1 Ambient Temperature. The ambient temperature is to be recorded at points located 3 ft. (91.5 cm) 

above the floor line and 10 inches (25.4 cm) from the center of the two sides of the cabinet. The temperature 

at each point is to be maintained within ±1°F (0.6°C) of the specified value and is to be maintained during 

stabilization periods as well as during actual test runs.

Temperature measuring devices are to be located or shielded so that indicated temperature will not be 

affected by the operation of the condensing unit.

Ambient air temperature is to be recorded at each of the specified positions at intervals not greater than 30 

minutes during the test periods.

7.4.3.2 Fresh Food Compartment Temperature (Household Refrigerators). Temperatures are to be 

recorded at three locations as shown in Figure 7-1. All temperature-measuring devices are to be supported in 

such a manner that there will be at least 1 inch (2.5 cm) of air space separating the thermal mass from contact 

with any surface. In case of interference with hardware at these locations, the temperature measurements are 

to be taken at the nearest adjacent location such that there will be 1 inch (2.5 cm) air space separating the 

thermal mass from the hardware.

If the interior arrangements of the cabinet do not conform with those shown in Figure 7-1, measurements are 

to be taken at selected locations chosen to approximately represent the entire fresh food compartment. The 

locations selected are to be recorded.

The recorded temperature at any given point is to be the average temperature at that point during a cycle of 

operation with the temperatures being read at regular intervals not exceeding 4 minutes.

For no-load pull-down and simulated load tests where one or more special compartments are provided for 

temperatures and humidities higher or lower than that of the fresh food compartment, a temperature 

measuring device is to be located at the geometric center of each compartment and the average temperatures 

recorded as determined above.

The recorded temperature of the fresh food compartment is to be the average of the temperatures recorded at 

the three locations shown in Figure 7-1.

7.4.3.3 Freezer Compartment Temperature (Household Refrigerators and Household Freezers). 

Freezer compartment temperatures are to be measured at the geometric center of the filled packages described 

below, with the packages located so the temperature measurement stations approximate the locations shown 

in Figure 7-2.

Temperatures are to be measured by unweighted thermocouples, located in the geometric center of packages, 

measuring approximately 5 x 4 x 11⁄2 inches (approximately 13 x 10 x 4 cm).

The packages are to be sealed and are to contain a liner or wrapper that makes them moisture and vaporproof. The packages are to be filled to a density of 35 ± 5 lbs. per cu. ft. (560 ± 80 kg/m3) with hardwood 

sawdust that has been water-soaked or alternately is to be an equivalent package of frozen food such as 

chopped spinach.

EERE-2006-BT-STD-0126 COMMENT 46
55

The freezer compartment is to be loaded with 75% of the maximum number of filled packages that can be 

fitted into the compartment. The 75% load is to be fitted into the compartment(s) so as to permit air 

circulation around and above the load.

The air gap around the freezer compartment load is to be 1⁄2 to 11⁄2 inches (1.5 to 4 cm) with the packages in a 

pyramid or tiered form if necessary to properly locate the thermocouples. Packages shall rest on the bottom of 

the liner or on top of a trivet if furnished.

NOTE: In order to keep packages from shifting and destroying the air gap, a wire grid with small, nonthermally conductive spacers for contact with freezer liner may be used.

Each shelf of freezers and freezer sections of combination refrigerator-freezers, where applicable, is to be 

loaded to 75% of its capacity in pyramid or tiered form, as necessary, for the proper location of the 

thermocoupled frozen food package.

Freezer door shelves are to be loaded with the maximum number of filled packages that can be retained on 

each shelf without added restraints. A thermocouple is to be placed at the geometric center of a package 

located at the vertical centerline of each shelf so that it will be approximately 2 inches (5.1 cm) from the 

surface of the inner door liner and 21⁄2 inches (6.4 cm) from the shelf surface as indicated in Figure 7-3.

If the interior arrangements of the freezer compartment shelves do not conform with those shown in Figure 7-

2, measurements are to be taken at locations selected to represent the intent of the standard. The locations 

selected are to be recorded. The recorded temperature at any given point during a cycle of operation with the 

temperature being read at regular intervals not exceeding 4 minutes.

The recorded temperature of the freezer compartment is to be the average of the temperatures recorded at the 

locations shown in Figure 7-2.

7.4.3.4 Wine Storage Compartment Temperature (Household Wine Chillers). Temperatures are to be 

recorded and recorded as in 7.4.3.2.

The recorded temperature of the wine storage compartment is to be the average of the temperatures recorded 

at the three locations shown in Figure 7-1.

7.5 No-Load Pull-Down Test (Household Refrigerators and Household Freezers)

7.5.1 Purpose. The purposes of this test are to establish that the cabinet temperature will be reduced from 

ambient to food storage temperature, to determine the rate at which this change takes place and to observe the 

lowest steady state temperatures attained in the storage compartments.

7.5.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4 

except as stated below.

The ambient temperature is to be:

(a) 110°F (43.3°C) for the test procedure 7.5.3 (a),

(b) 90°F (32.2°C) for the test procedures 7.5.3 (b) and (c).

EERE-2006-BT-STD-0126 COMMENT 46
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The cabinet is to be prepared with its shelves and accessories in place in accordance with the manufacturer's 

instructions, but without a freezer compartment simulated food and ice load.

Freezer compartment temperatures are to be recorded at the locations shown in Figure 7-2. All temperature 

measuring devices are to be supported in such a manner that there will be at least 1⁄2 inch (1.5 cm) of air space 

separating the thermal mass from contact with any surface. In case of interference with hardware at these 

locations, the temperature measurements are to be taken at the nearest adjacent location such that there will be 

1⁄2 inch (1.5 cm) air space separating the thermal mass from the hardware.

During the test, all refrigeration system controls (thermostats, automatic defrost controls, etc.) are to be 

electrically disconnected or inactivated to insure continuous operation of the refrigerant motor compressor, but 

the motor overload protector, if provided, is not to be disconnected or inactivated.

7.5.3 Test Procedure. The cabinet, with all compartment doors open, is to have been electrically 

disconnected for at least 8 hours in the appropriate ambient temperature immediately preceding the start of the 

test at each of the following three conditions:

(a) The cabinet door(s) is to be closed and the cabinet operated continuously until steady state condition has

been reached or until it is evident that the unit will continue to cycle on the overload protector.

(b) The electrical power supply is to be adjusted to 90% of voltage specified in 7.4.1. The cabinet door(s) is to 

be closed and the cabinet operated continuously for 4 hours or until it is evident that the unit will continue to 

cycle on the overload protector.

(c) The electrical power supply is to be adjusted to 110% of voltage specified in 7.4.1. The cabinet door(s) is 

to be closed and the cabinet operated continuously for 4 hours or until it is evident that the unit will continue to 

cycle on the overload protector.

7.5.4 Data To Be Recorded

For Test Procedure 7.5.3(a):

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperature.

(c) Voltage and frequency.

(d) Time for fresh food compartment temperature of household refrigerator to reach 41°F (5°C). When this 

temperature cannot be attained, the time to reach steady state condition when the unit is running 

continuously, or test termination when the unit is cycling on the overload protector is to be recorded.

(e) Time for low temperature compartment temperature to reach 32°F (0°C) for basic refrigerators and for 

freezer compartment to reach 5°F (-15°C) for combination refrigerator-freezers and freezers. When these 

temperatures cannot be attained, the time to reach steady state condition when the unit is running 

continuously, or test termination when the unit is cycling on the overload protector, is to be recorded.

(f) Steady state condition temperature(s), except when the test is terminated when cycling on the overload 

protector.

(g) Number of times the overload protector cycled.

EERE-2006-BT-STD-0126 COMMENT 46
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For Test Procedures 7.5.3(b), (c):

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperature.

(c) Voltage and frequency.

(d) Average temperature attained in the fresh food compartment measured at 4 hours.

(e) Average temperature attained in the low temperature compartment for basic refrigerators and freezer 

compartment for combination refrigerator-freezers and freezers measured at 4 hours.

(f) Number of times the overload protector cycled.

7.6 Simulated Load Test (Household Refrigerators)

7.6.1 Purpose. The purpose of this test is to determine thermal performance under varying ambient 

conditions (temperature averages, maximum differentials, etc.) and the comparative electrical energy consumed 

at these varying conditions.

7.6.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4.

The data to be recorded is to be obtained at the ambient and average fresh food compartment temperatures 

specified in Table I for basic refrigerators and all-refrigerators.

TABLE I

Ambient Temperature Fresh Food Compartment Temperature

55°F (12.8°C)

70°F (21.1°C)

90°F (32.2°C)

110°F (43.3°C)

34°F (1.1°C)

36°F (2.2°C)

38°F (3.3°C)

41°F (5.0°C)

Household refrigerators with fixed temperature controls are tested at the fixed control position.

For combination refrigerator-freezers with separate controls for the fresh food compartment and the freezer 

compartment, the data to be recorded is to be obtained with an average freezer compartment temperature of 5°F 

(-15°C) and the fresh food compartment temperatures and ambient temperatures specified in Table I.

For combination refrigerator-freezers with single controls, the data to be recorded is to be obtained at the 

ambient temperatures specified in Table I with an average freezer compartment temperature of 5°F (-15°C) and 

whatever average fresh food compartment temperatures exist with these control settings.

7.6.3 Test Procedure. For convenience, either of the following two procedures may be used for either single

or multiple control cabinets.

EERE-2006-BT-STD-0126 COMMENT 46
58

7.6.3.1 Interpolation Procedure. The cabinet is to be operated at each of the ambient temperatures (see 

Table I) and at least each of the following control positions.

CONTROL POSITIONS

Multiple Control 

Single Control Primary Control Secondary Control

Warmest Warmest

Warmest

Warmest

Coldest

Coldest Coldest

Coldest

Coldest

Warmest

Intermediate Warmest

Coldest

Intermediate

Intermediate

NOTE: The primary control is that device which initiates compressor operation.

At one or more of the intermediate control(s) positions the tests in the ambient temperature of 70°F (21.1°C) 

and 90°F (32.2°C) are to be run without resetting the control(s).

Fixed control refrigerators are tested at the fixed control position.

Each test period is to be at least two whole cycles, i.e., an equal number of off and on periods of the compressor 

motor, if cycling occurs, and not less than 3 hours at steady state conditions.

From the data obtained at each of the settings of the temperature control(s), curves are to be plotted (show 

actual data points when plotting) for the average fresh food compartment temperature versus:

(a) Average freezer compartment temperature,

(b) Average temperature of each special compartment, if applicable,

(c) Warmest freezer door-shelf frozen food package temperature, if applicable,

(d) Energy (kWh) consumed during a 24-hour period,

(e) Percent operating time of the compressor motor, and 

(f) The number of cycles for a 24-hour period.

The recorded average compartment temperature is to be the average of the temperature readings taken during a 

complete cycle of the temperature controller for that compartment. The data for the specified compartment(s) 

temperatures for each of the four ambient temperatures is to be obtained from these curves (see Figures 7-4 and 7-5 

for examples). 

If the curve does not reach the specified compartment temperature(s), the data for the point at the extreme end 

of the curve closest to the specified temperature(s) is to be used. This condition shall be clearly described in 

reporting on the cabinet under test.

EERE-2006-BT-STD-0126 COMMENT 46
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7.6.3.2 Specific Control(s) Setting Procedure. The cabinet is to be operated at each of the ambient 

temperatures and at control positions as required to obtain the compartment(s) temperatures stated in Table I 

within the tolerances stated in Table II.

TABLE II

Tolerances on Controlled Temperatures

Fresh Food

Compartment 

Freezer

Compartment 

Basic Refrigerator

and 

All-Refrigerator

±1°F (0.6°C) — 

Combination 

RefrigeratorFreezer, 

Single Control

— ±0.5°F (0.3°C) 

Combination 

RefrigeratorFreezer

Multiple Control

±1°F (0.6 C) ±0.5°F (0.3°C) 

Each test period is to be at least 2 hours if no cycling occurs or if cycling occurs, an integral number of whole 

cycles (i.e., an equal number of off and on periods of the compressor motor) of at least 2 hours duration at steady 

state conditions. In the event that the 5°F (-15°C) freezer compartment temperature or the specified fresh food 

compartment temperature cannot be achieved in any of the standard test ambients, then the test is to be conducted 

and the data recorded at compartment temperatures as close to the specified values as may be achieved.

In addition, a test to demonstrate control response is to follow the simulated load test run at either 70°F (21.1°C) or 

90°F (32.2°C) ambient temperature, and to consist of a repeat of that test in the other of the two ambient 

temperatures 70°F (21.1°C) or 90°F (32.2°C) without changing any control setting(s). The data to be recorded is to 

include results for at least five tests, a simulated load test at 55°F (12.8°C), 70°F (21.1°C), 90°F (32.2°C) and 

110°F (43.3°C) ambient temperature, and the control response test made following either the 70°F (21.1°C) or 90°F 

(32.2°C) ambient temperature simulated load test.

7.6.4 Data To Be Recorded

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperature.

(c) Voltage and frequency.

(d) Plot observed data; see Figures 7-4 and 7-5 for examples. Not required for Specific Control(s) Setting 

Procedure (see Paragraph 7.6.3.2).

(e) Average fresh food compartment temperature.

(f) Average freezer compartment temperature.

(g) Average special compartment(s) temperatures(s).

(h) Warmest freezer door-shelf frozen-food package temperature.

EERE-2006-BT-STD-0126 COMMENT 46
60

(i) For each control(s) position in the 70°F (21.1°C) and 90°F (32.2°C) ambients, tabulate the maximum and 

minimum temperature values observed for the warmest and coldest fresh food compartment temperature 

recording locations (see sample Table, Figures 7-7 and 7-7A).

(j) Energy (kWh) consumed during a 24-hour period.

(k) Percent operating time of the compressor motor.

(l) Number of cycles during a 24-hour period.

7.6.5 Recommended Levels of Performance

7.6.5.1 It is recommended that in the fresh food compartment of household refrigerators, an average 

temperature within the range of 34°F and 41°F (1.1°C and 5°C) be attainable between the warmest and coldest 

setting(s) of the control(s) when tested in ambients of 55°F (12.8°C), 70°F (21.1°C), 90°F (32.2°C) and 110°F 

(43.3°C). The control setting(s) may be adjusted for each ambient.

The period of time that most fresh food used in today's household can be safely stored is dependent upon 

temperature -- the lower the temperature the longer most foods can be safely stored.

34°F (1.1°C) is as close to freezing as is practical in order that no section of the fresh food compartment 

permits freezing.

41°F (5°C) is not quite so limiting. It is chosen as a guide based on experience. Higher temperatures will 

shorten safe storage periods. Refrigerator-freezer design and development engineers believe 41°F (5°C) to be a 

very practical but not absolute upper limit.

7.6.5.2 It is recommended that in the freezer compartment the average temperature be less than or equal to 

15°F (-9.4°C) for basic refrigerators and less than or equal to 5°F (-15°C) for combination refrigerator-freezers 

when tested in 90°F (32.2°C) ambient.

Although it is not necessary for the recommended freezer and fresh food compartment temperatures (Paragraph 

7.6.5.1) to occur simultaneously, it is recommended that the freezer compartment temperatures be attainable 

with average fresh food compartment temperatures higher than 34°F (1.1°C).

By definition a basic refrigerator is intended for the short-term storage of frozen foods; most frozen foods will 

not freeze or remain frozen above 15°F (-9.4°C) for any reasonable time, based on the sugar content, water 

content, etc., of the frozen food stored.

5°F (-15°C) for the freezer compartment of a combination refrigerator-freezer is an extension of the definition 

of a refrigerator-freezer which limits freezer compartment temperatures to 8°F (-13.3°C). While 8°F (-13.3°C) 

provides definition, 5°F (-15°C) is the suggested temperature based on the long term economical storage of 

most frozen foods. The lower the temperature, the longer frozen foods can be safely stored. 0°F (-17.8°C) 

would provide longer safe storage.

7.7 Simulated Load Test (Household Freezers)

7.7.1 Purpose. The purpose of this test is to determine thermal performance under a varying range of control 

settings and the comparative electrical energy consumed at these settings.

7.7.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4.

EERE-2006-BT-STD-0126 COMMENT 46
61

The data to be recorded is to be obtained at the following ambient and average freezer compartment 

temperatures:

Ambient 

Temperature

Average Freezer

Compartment Temperature

90°F (32.2°C) 0°F (-17.8°C)

If the door shelves are adjustable, locate the top shelf at the highest provided position that will accommodate a 

filled package (see Figure 7-3), and locate the bottom shelf at the lowest provided position. The packages 

containing thermocouples are to be located in accordance with Figures 7-2 and 7-3.

7.7.3 Test Procedure. The cabinet is to be operated at an ambient temperature of 90°F (32.2°C) at each of 

the three following control positions:

(a) The warmest position (not defrosting).

(b) The coldest position (control not short-circuited).

(c) An intermediate position(s).

Household freezers with a fixed temperature control are tested at the fixed control position.

Each test period is to be at least 2 hours if no cycling occurs or if cycling occurs, an integral number of whole 

cycles (i.e., an equal number of off and on periods of the compressor motor) of at least 2 hours duration at 

steady state conditions.

From the data obtained at each of the settings of the temperature control, curves are to be plotted (show actual 

data points when plotting) for cabinet frozen food temperature (see Figure 7-6), versus:

(a) Warmest cabinet food package temperature,

(b) Average door-shelf frozen food package temperature (if applicable),

(c) Warmest door-shelf frozen food package temperature if applicable,

(d) Energy (kWh) consumed during a 24-hour period,

(e) Percent operating time of compressor motor,

(f) The number of cycles for a 24-hour period (if applicable) (see Figure 7-6).

If the cabinet does not reach the specified freezer compartment temperature, the data for the point at the 

extreme end of the curve closest to the specified temperatures is to be recorded. This condition is to be clearly 

described in reporting on the cabinet under test.

7.7.4 Data To Be Recorded

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperature.

EERE-2006-BT-STD-0126 COMMENT 46
62

(c) Voltage and frequency.

(d) Plot of observed data (Figure 7-6).

(e) Average freezer compartment temperature.

(f) Warmest cabinet frozen food package temperature.

(g) Average door-shelf frozen food package temperature.

(h) Warmest door-shelf frozen food package temperature.

(i) For each control position, tabulate the maximum and minimum temperature values observed for the 

warmest and coldest freezer compartment frozen food package. Use freezer compartment portion of table 

format shown in Figure 7-7.

(j) Energy (kWh) consumed during a 24-hour period.

(k) Percent operating time of compressor motor.

(l) Number of cycles during a 24-hour period.

7.7.5 Recommended Level of Performance. It is recommended that a 0°F (-17.8°C) average freezer 

compartment temperature be attainable through control adjustment in a 90°F (32.2°C) ambient temperature.

By definition a freezer is designed for the extended storage of frozen food. The 0°F (-17.8°C) average freezer 

temperature is intended to extend safe storage time beyond that of the freezer compartment of a household 

refrigerator.

0°F (-17.8°C) has long been recognized as the datum for long-term safe storage of all frozen foods and has 

proven over the years to serve the consumers' needs and expectations.

7.8 Ice-Making Test (Household Refrigerators and Household Freezers) if there is provision for making ice.

7.8.1 Purpose. The purpose of this test is to determine the rate of making ice, using ice trays or other icemaking equipment furnished with the cabinet.

7.8.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4.

Ice trays and ice buckets related to non-automatic ice-making are to be installed in accordance with 

manufacturer's instructions removing frozen food packages as required.

Do not put frozen food packages in ice storage bins of automatic icemakers.

The ambient temperature is to be 90°F (32.2°C).

The test period is to begin after the cabinet has reached steady state condition with the control(s) and/or baffles 

set to maintain the following compartment(s) temperatures. The control(s) settings are not to be changed 

during the test.

EERE-2006-BT-STD-0126 COMMENT 46
63

Basic refrigerator and all-refrigerator, where applicable, average fresh food compartment temperature 

35 ± 2°F (1.7 ± 1.1°C).

Combination refrigerator-freezer --single control, average fresh food compartment temperature 35 ± 2°F (1.7 ± 

1.1°C).

Combination refrigerator-freezer --multiple control, average fresh food compartment temperature 38 ± 2°F (3.3 

± 1.1°C); freezer control set to coldest position possible without shorting out the control and still maintaining 

specified fresh food compartment temperatures.

Household freezer, freezer control set to coldest position (control not short-circuited).

Household refrigerators and household freezers with fixed controls are tested at the fixed control position.

The cabinet door(s) is to be kept closed except when visual inspection of the ice storage bin (for automatic 

icemakers) is necessary. During such visual inspection the door(s) is to be opened for not more than 15 

seconds at a time.

7.8.3 Test Procedure

7.8.3.1 Ice Tray(s)-- including those with automatic fill. The ice tray(s) is to be filled to within 1/8 inch 

(within 3 mm) of the top, or as recommended by the manufacturer, with drinking water having temperature of 

90 ± 2°F (32.2 ± 1.1°C). Trays having removable grids are to have the grids in place for this test. Automatic 

tray fill devices are to be connected, in accordance with manufacturer's recommendations, to a water supply 

having a temperature of 90 ± 2°F (32.2 ± 1.1°C) at the point of connection or entrance to the cabinet. The 

tray(s) is to be inserted into the cabinet and positioned as recommended by the manufacturer with a minimum 

door opening time. If the manufacturer recommends that a surface of the cooling unit on which the ice tray(s) 

rest be wetted to insure good thermal contact, this should be done at the time that the trays are inserted. Each 

tray is to contain at least one unweighted thermocouple positioned in the location predetermined to be the last 

in that particular tray to freeze. The thermocouple wires are not to be larger than 0.032 inch (20 AWG).

After the temperature, as indicated by all thermocouples in the ice trays, has reached 28°F (-2.2°C) a visual 

inspection is to be made to determine that the water is completely frozen. If the water in any tray is not 

completely frozen, relocate the thermocouples and repeat the test.

Each test is to be continued until the water in all trays is frozen or for a period of 24 hours. If the water in any 

tray is not completely frozen within 24 hours, the test is to be stopped and the findings recorded in the report.

7.8.3.2 Automatic Icemaker(s). The automatic icemaker(s) is to be connected in accordance with 

manufacturer's recommendations, to a water supply having a temperature of 90 ± 2°F (32.2 ± 1.1°C) at the 

point of connection of entrance to the cabinet during the test.

Prior to the initiation of the ice-making test, the automatic icemaker is to have been operating a sufficient time 

to assure proper operation. There is to be no evidence of free water having entered the storage bin.

For cyclic icemakers the test is to begin at the completion of the water-fill portion of a cycle. For continuous 

(non-cyclic) ice-making devices, the test may be started at any time after steady state condition has been 

established. The ice storage bin is to be emptied and repositioned at the time the test is started.

The test is to continue uninterrupted for a minimum of 4 hours for continuous icemakers and for additional time 

required to complete a whole number of cycles for cyclic icemakers. The ice storage bin shall not be emptied 

EERE-2006-BT-STD-0126 COMMENT 46
64

during the test unless necessary to assure uninterrupted operation. If the ice is removed for this reason, it is to 

be weighed and this amount added to the weight of the ice in the storage bin at the termination of the test.

At the completion of the test the ice in the storage bin is to be weighed. If there is evidence of free water 

having entered the storage bin, the test is to be repeated at least once. If this condition continues, the test is to 

be stopped and the condition recorded.

The time duration of the test is to be recorded for use in calculating the ice-making rate for 24 hours.

7.8.4 Data To Be Recorded

7.8.4.1 Ice Tray(s)-- including those with automatic fill.

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperature.

(c) Average fresh food compartment temperature (if applicable) at the beginning of the test.

(d) Average freezer compartment temperature (if applicable) at the beginning of the test.

(e) Voltage and frequency.

(f) The time required for the temperature to reach 28°F (-2.2°C) in each tray.

(g) The material of each tray and grid (plastic, steel, aluminum, etc.).

(h) The weight of ice per tray.

(i) The total weight of ice per freezing.

(j) The position of each tray in the evaporator or freezer compartment.

7.8.4.2 Automatic Icemaker(s)

(a) Type, model number, serial number, if any, and manufacturer or brand name of the icemaker.

(b) Ambient temperature.

(c) Average fresh food compartment temperature (if applicable) at the beginning of the test.

(d) Average freezer compartment temperature (if applicable) at the beginning of the test.

(e) Voltage and frequency.

(f) The ice-making rate in pounds per 24 hours.

7.9 Temperature Rise Test (Household Freezers)

7.9.1 Purpose. The purpose of this test is to determine the thermal characteristics of a freezer during a 

simulated power failure.

EERE-2006-BT-STD-0126 COMMENT 46
65

7.9.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4.

The cabinet is to be prepared and loaded as per the Simulated Load Test (see Section 7.7).

7.9.3 Test Procedure. The cabinet is to be operated at an ambient temperature of 90°F (32.2°C) with the 

temperature control set at a position such that the average of the temperatures recorded at the locations in 

Figure 7-2 is below 0°F (-17.8°C). If necessary the temperature control may be short-circuited.

If the cabinet does not reach the specified freezer compartment temperature, the lowest attainable average 

freezer compartment temperature is to be recorded. This condition is to be clearly described in reporting on the 

cabinet under test.

After steady state condition has been reached, the power supply shall be switched off.

7.9.4 Data To Be Recorded

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperature.

(c) The period of time from the moment when the average freezer compartment temperature reaches 0°F 

(-17.8°C) to the moment when any one of the recorded frozen food packages reaches a temperature of 23°F 

(-5.0°C). When the 0°F (-17.8°C) starting temperature cannot be attained, the period of time from the 

moment when the power supply is switched off to the moment when any one of the recorded frozen food 

packages reaches a temperature of 23°F (-5.0°C) is to be recorded.

EERE-2006-BT-STD-0126 COMMENT 46
66

1

2

T2 T3

CL

CL

A

A

2

E

T1

E

2

a

V

V

2

T2

E

E

2 A

A

CL 2

T1

W

W

2

A

1

E

T

V

V

E

2

2

2

CL

A

T

2

b

T3

T3

C

1

E

2

T2

V

T3

E

A

CL

A

T

2

V2

W

W

2

d

T1

T2

T3

CL

e

V

T1

T2

W

CL

2

W

T3

f

V

T

T2

T3

g

CL

T2

T1

v

T3

CL

D

D

2

T3

D

D

2

T2

T1

CL

h TYPICAL SIDE

SECTION

Fig. 7-1

Thermocouple Locations for Determination of Fresh Food Compartment Temperatures 5"5" 5"

V

V

1"

1"

V

V4

V

4

V4

V4

V3

V3

V3

V3

1"

V3

1"

V3

"A", "D", "E", "W" and "V" are arbitrary designations for determining location at which temperatures are to be measured. The depth

dimension shall be measured from the back of the liner to a plane defining the gasket sealing surface. T1, T2 and T3 indicate

thermocouple locations.

EERE-2006-BT-STD-0126 COMMENT 46
67

FIGURE 7-2

TYPE 1 TYPE 2 TYPE 2A

PLAN PLAN PLAN

Thermocouple Locations for Determination of Freezer Compartment Temperatures

of Household Refrigerators and Household Freezers

TYPE 3 TYPE 4

PLAN PLAN

ELEVATION ELEVATION

Type 1, 2 and 3

Type 4

Type 5

Type 6

Chest Freezer (lift cover) with refrigerated walls

Chest Freezer (lift cover) with refrigerated plates

Vertical Freezer (front door) with refrigerated shelves (door located at left)

Evaporator or freezer compartment of Household refrigerators (except All-Refrigerators)

or Vertical Freezers (front door) with refrigerated walls or with concealed evaporator

(door located at left)

PLATES

MACHINE

COMPARTMENT

T3

T1 T2

D D

D/2 D/2

T3

T4 T1 T2 T5

D

D/2

T1 T2

T5 T3 T4

H

H/2 T5 T1

T2

W/4

T3 T4

W > 36"

ELEVATION

W > 36"

ELEVATION

3⁄4"

11⁄4"

T1

T2

T3

W/2

W = OR < 36"

ELEVATION

T1 T5

T2

T4 T3

H

H/2

H/2

W/4 W/4

W/4 W/4 W/4 3⁄4"

D

T3

T1 T2

D/2

3" T1

T2 T3

D

T T

T7

8 9

T1

T

T2

3

3⁄4"

2

W2 W1

W /2

1

3⁄4"

H1

W /2

H1/2

11⁄4"

T6

T4

T4

T5

T5

T6

H/2

H

11⁄4" 11⁄4"

3⁄4"

W2/2

T6

T4 T5

T6

T5

T4 T7

T8

T9

T1

T2

T3

21⁄2" 21⁄2"

W1 /2 W3/2

H

H2

21⁄2" 21⁄2"

11⁄4"

D/2

W1 W2 W3

EERE-2006-BT-STD-0126 COMMENT 46
68

W

W/2

PLAN

D/2

D

21⁄2"

21⁄2"

3⁄4"

SIDE ELEVATION

W

W/2

PLAN

D/2

21⁄2"

3⁄4"

D

SIDE ELEVATION

11⁄4"

11⁄4"

11⁄4"

11⁄4"

H4

H3

H2

H1

3⁄4"

3⁄4"

3⁄4"

H1/2

H2

/2

H3 /2

H4/2 T1

T

T

T

T

T

T

T

T

4

7

10

11

12

9

6

8

11⁄4"

H > 36"

H/4

H/4

H/2

*If a projection on the inner door interferes with these thermocouple locations, move them rearward to clear the projection.

For types 1, 2, 3 and 4; the height dimension shall be measured from the bottom of the liner (or from the top of a trivet, if furnished) to a plane defining 

the gasket sealing surface.

For types 5 and 6; the height dimension shall be measured from the bottom of the liner (or from the top of a trivet, if furnished).

For types 5 and 6; the depth dimension shall be measured from the back of the liner to a plane defining the gasket sealing surface.

For type 5; non-refrigerated shelves are treated as if they were not there.

NOTE: For load tests, the thermocouple location designates the approximate geometric center of a 5 x 4 x 11⁄2" frozen food package.

T2

T2

T3

T3

T2

T4

T5

T1

T2 T1

12

9

6

T3

11

8

5

T2

10

7

4

T1

W = width

D = depth

H = height

NOTE:

TYPE 5 TYPE 6

Thermocouple Locations For Determination of Freezer Compartment Temperatures

of Household Refrigerators (Except All-Refrigerators) and Household Freezers

from back of liner from back of liner

from gasket sealing

surface

21⁄2" from gasket sealing

surface

Back of liner

Back of liner

Gasket sealing

surface

Gasket sealing

surface

FIGURE 7-2 (Continued)

For type 6; in case of evaporator or freezer compartment of household refrigerators (except all-refrigerators), the width, height and depth dimensions 

shall be measured in the same manner as refrigerated volume computation described in Section 4.

T5

T3

*

*

*

*

*

*

THERMOCOUPLES

USE THREE

THERMOCOUPLES

USE FIVE

H < 36"

WHEN H < 36"

T5 T2 T1

3

T3

4

WHEN H > 36"

*

* *

EERE-2006-BT-STD-0126 COMMENT 46
69

2"

2"

W

FIGURE 7-3

Thermocouple Locations For Door Shelves Of Vertical Freezer And

Door Shelves Of Freezer Compartment In Combination Refrigerator-Freezer

OPEN DOOR FRONT VIEW SIDE VIEW

DOTS ARE

THERMOCOUPLE

LOCATIONS

INNER DOOR PANEL

21⁄2"

21⁄2"

21⁄2"

21⁄2"

W/2 PANEL

OUTER DOOR 

EERE-2006-BT-STD-0126 COMMENT 46
70

Format for Plotting Simulated Load Test Results For

FIGURE 7-4

Single Control Cabinets

0 1 2 3 4 0

28

32

36

40

44

48

52

20 40 60 80 100

28

32

36

40

44

48

52

LEGEND

-10 0 10 20 30 40

Warmest Freezer Compartment

Door Shelf Frozen Food

Temperature - °F

 28 32 36 40 44 48 52 56

Average Fresh Food Special

Compartment Temperature - °F

Cycles in 24 Hours

0 20 40 60 80 100 120 140

Energy (kWh) Consumed

in 24 hours Operating Time - Percent Average Freezer Compartment

Temperature - °F

-10 0 10 20 30

NOTE: Connecting lines between test points in the 70°F and 90°F ambients

indicates they were run without resetting the control.

70°F Ambient

90°F Ambient

110°F Ambient

Average Fresh Food

Compartment Temperature - °F

Average Fresh Food

Compartment Temperature - °F

EERE-2006-BT-STD-0126 COMMENT 46
71

FIGURE 7-5

Format for plotting points and reading results for simulated load test.

Multiple Control Cabinets Example shown is for 70°F ambient.

70° SIMULATED LOAD TEST

C/C

C/W

M/C

M/M

M/W

W/C

W/W

70

60

50

40

% RUNNING TIME

W/C

C/W

M/W

M/M

W/W

C/C

M/C

3.5

4.0

4.5

KWH PER 24 HOURS

5.0

AVERAGE FREEZER COMPT. TEMP °F

5

0

10

15

AVERAGE FRESH FOOD COMPARTMENT TEMP. °F

20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50

W/C

M/W

M/M

M/C

C/W

C/C

Example of Interpolation:

Fresh

Food

36.0

FRZ

5.0

KWH

4.17

%

53.5

Legend:

= Coldest

= Medium

= Warmest

C/W = 

C

M

W

Coldest Fresh Food Compartment

Control Setting and Warmest

Freezer Compartment

Control Setting

EERE-2006-BT-STD-0126 COMMENT 46
72

Format For Plotting Simulated Load Test Results For Freezers (90F Ambient)

Temperature - F

Energy Consumed (kwh)

in 24 hours

0 1 2 3 4 5 6

-10

0

10

20

Temperature - F

Operating Time - Percent

0 20 40 60

-10

0

80 100

10

20

Temperature - F

Cycles in 24 Hours

0 20 40 60 80 100

-10

0

10

20

-10

Temperature - F

0

10

20

-10 0 10 20 30

Frozen Food Temperatures - F

Warmest Door Shelf Package

Warmest Cabinet Package

Average Door Shelf Package

FIGURE 7-6

EERE-2006-BT-STD-0126 COMMENT 46
73

MAXIMUM/MINIMUM TEMPERATURE VALUES

CONTROL POSITION

Freezer

Compartment Compartment

Fresh Food Compartment

Fresh Food Freezer

Compartment Compartment

Fresh Food

Compartment

Freezer

None Warmest

Coldest

Intermediate

70°F Ambient 90°F Ambient

MAX.

MIN. 51.5

53.1

47.2

50.6

28.5

32.0 27.6

23.0

54.8

52.1

48.9

46.1 14.2

18.6

9.0

12.3

MIN.

MAX.

45.3

47.3

41.6

44.8 29.5

28.3

26.2

21.5

46.3

43.1

42.2

38.9 10.6

13.4 8.8

5.4

MAX.

MIN.

Intermediate

(Optional) 36.6

39.1

33.4

37.2 18.7

14.5

12.4

8.5

36.6

33.4 29.1

32.0 4.4

1.2

-5.1

-8.2

None

None

None

MIN.

MAX.

28.7

32.3 30.1

26.5

8.2

3.9 -6.3

-2.4 34.2

31.3

30.4

27.3 -7.2

-4.6

-14.1

-12.2

Fig 7-7

Format with Sample Data for Tabulating Simulated Load Test

Temperature Values for Single Control Refrigerators

for Multiple Control Refrigerators

Format for Tabulating Simulated Load Test Temperature Values

Fig 7-7A

CONTROL POSITION

Freezer

Compartment

Fresh Food

Compartment

Freezer

Compartment

70°F Ambient

Fresh Food

Compartment Compartment

Freezer

90°F Ambient

Compartment

Fresh Food

MAXIMUM/MINIMUM TEMPERATURE VALUES

Warmest Warmest

MIN.

MAX.

Warmest Coldest MAX.

MIN.

Coldest

MIN.

Coldest MAX.

MIN.

Coldest Warmest MAX.

Warmest MAX.

MIN.

Intermediate

Coldest

MIN.

Intermediate MAX.

Warmest Coldest Warmest Coldest Warmest Coldest Warmest Coldest

Warmest Coldest Warmest Coldest Warmest Coldest Warmest Coldest

EERE-2006-BT-STD-0126 COMMENT 46
74

8. METHOD FOR DETERMINING THE ENERGY CONSUMPTION OF HOUSEHOLD 

REFRIGERATORS, HOUSEHOLD WINE CHILLERS AND HOUSEHOLD FREEZERS

8.1 Scope of Section 8. This section describes a standard method for determining the electrical energy 

consumption for household refrigerators, household wine chillers and household freezers.

8.2 Purpose. The purpose of this test method is to establish a uniform and repeatable procedure for measuring 

electrical energy consumption at various control positions and provide a standard procedure for determining and 

reporting energy consumption.

8.3 Definitions. The definitions of Section 3 are supplemented for this test method as follows:

8.3.1 Cycle. The period of 24 hours for which the energy use of a household refrigerator or household 

freezer is calculated as though the consumer activated compartment temperature controls were set so that the 

desired compartment temperatures were maintained.

8.3.2 Cycle Type. The set of test conditions having the calculated effect of operating a household refrigerator 

or freezer for a period of 24 hours, with the consumer activated controls other than those that control 

compartment temperatures set to establish various operating characteristics.

8.3.3 Standard Cycle. The cycle type in which the anti-sweat heater control, when provided, is set in the 

highest energy consuming position.

8.3.4 Long-Time Automatic Defrost. An automatic defrost system where successive defrost cycles are 

separated by 14 hours or more of compressor-operating time.

8.3.5 Variable Defrost Control. Variable defrost control means a long- time automatic defrost system 

(except the 14-hour defrost qualification does not apply) where successive defrost cycles are determined by an 

operating condition variable or variables other than solely compressor operating time. This includes any 

electrical or mechanical device. Demand defrost is a type of variable defrost control.

8.3.6 Stabilization Period. The total period of time during which steady state conditions are being attained or 

evaluated.

8.3.7 Quick Freeze. Quick freeze means an optional feature on freezers that is initiated manually and shut off 

manually. It bypasses the thermostat control and places the compressor in a steady-state operating condition 

until it is shut off.

8.4 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4 with 

additions or exceptions described in this Section and Section 8.7.1.

8.4.1 Ambient Temperature. The ambient temperature shall be 90 ± 1°F (32.2 ± 0.6°C) during the 

stabilization period and during the test period.

The vertical ambient temperature gradient at locations 10 inches (25.4 cm) out from the centers of the two sides 

of the unit being tested is to be maintained during the test. Unless the area is obstructed by shields or baffles, 

the gradient is to be maintained from 2 inches (5.1 cm) above the floor or supporting platform to a height 1 ft. 

(30.5 cm) above the unit under test.

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8.4.2 Product Test Conditions

8.4.2.1 General. Defrost controls are to be operative for all tests.

Tests are to be run with the anti-sweat heater switch in both the on and off positions for each temperature 

control setting if the product is to be shipped with the switch in the off position. Otherwise, it is to be run 

only in the on position for each temperature control setting. The quick freeze option shall be switched off 

unless specified.

8.4.2.2 Load Conditions for Automatic Defrost Refrigerator-Freezers and All-Refrigerators. There are 

to be no loads in the freezer compartments of automatic defrost refrigerator-freezers and all-refrigerators.

8.4.2.3 Temperature Measurement. The wine storage compartment temperatures of household wine 

chillers, fresh food compartment temperatures of household refrigerators and freezer compartment 

temperatures of automatic defrost refrigerator-freezers are to be measured using weighted temperature 

sensors. Weighting is to be a cylindrical metallic mass 1.12 ± 0.25 inches (2.9 ± 0.6 cm) in diameter and 

height, in good thermal contact with each temperature sensor. All temperature measuring sensor masses are 

to be supported by low-thermally conductive material in such a manner that there will be at least 1 inch (2.5 

cm) of air space separating the thermal mass from contact with any surface. In case of interference with 

hardware at the sensor locations specified in 8.7.1, place the sensors at the nearest adjacent location such that 

there will be a 1 inch (2.5 cm) air space separating the sensor mass from the hardware.

8.5 Temperature Control Settings

8.5.1 Model with No User Operable Temperature Control. Compartment temperature and energy 

consumption are to be measured (1) with the temperature control operating and (2) with the temperature control 

electrically short-circuited to cause the compressor to run continuously. If the model has the quick freeze 

option, it is to be used to bypass the temperature control.

8.5.2 Model with User Operable Temperature Control. Testing is to be performed in accordance with one 

of the following sections using the appropriate standardized reference temperatures:

All-refrigerator 38°F (3.3°C) fresh food compartment temperature.

Basic refrigerator 15°F (-9.4°C) freezer compartment temperature.

Refrigerator-freezer 5°F (-15°C) freezer compartment temperature.

Freezer 0°F (-17.8°C).

Wine Chiller 55°F (12.8°C) wine storage compartment temperature.

8.5.2.1 Perform the following two tests:

(1) Set all compartment temperature controls at their median position midway between their warmest and 

coldest setting. Knob detents are to be mechanically defeated if necessary to attain a median setting.

(2) Set all controls at their warmest or their coldest setting (not electrically or mechanically bypassed), 

whichever is appropriate, to attempt to achieve compartment temperatures measured during the two tests 

which bound (i.e., one is above and one is below) the standardized temperature for the type of product being 

tested.

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If the compartment temperatures measured during these two tests bound the appropriate standardized 

temperature, then these test results are to be used to determine energy consumption for a given setting of the 

anti-sweat heater switch.

If the compartment temperature measured with all controls set at their warmest setting is below the 

standardized temperature and the fresh food compartment is below 45°F (7.2°C) in the case of a basic 

refrigerator or refrigerator-freezer, excluding an all-refrigerator, wine chiller and freezer, then use the result 

of this test alone to determine energy consumption for a given setting of the anti-sweat heater switch.

If the compartment temperature measured with all controls set at their coldest setting is above the 

standardized temperature, perform the following additional test:

(3) Set all controls at their warmest setting. Use the result of this test with the result of the test performed 

with all controls set at their coldest setting to determine energy consumption.

8.5.2.2 As an alternate to 8.5.2.1 above, a first test may be performed as follows:

Set all temperature controls at their warmest setting.

For freezers: if the compartment temperature is below the appropriate standardized temperature, then the 

result of this test alone is to be used to determine energy consumption.

For basic refrigerators or refrigerator-freezers (excluding all-refrigerators and wine chillers): if the 

compartment temperature is below the appropriate standardized temperature and the fresh food compartment 

temperature is below 45°F (7.2°C), then the result of this test alone will be used to determine energy 

consumption.

If the above conditions are not met, then the unit is to be tested in accordance with 8.5.2.1 above.

8.5.2.3 As an additional alternative:

Perform a first test with all temperature controls set at their coldest setting. If the compartment temperature is 

above the appropriate standardized temperature, perform a second test with all controls set at their warmest 

control setting and the results of these two tests are to be used to determine energy consumption.

If the above condition is not met, then the unit is to be tested in accordance with 8.5.2.1 above.

8.5.2.4 Variable Defrost Control Optional Test. The ambient temperature shall be 80 ± 2°F (26.7 ± 1.1°C) 

dry bulb and 67°F (19.4°C ) wet bulb during the stabilization period and during the test period. 

8.5.2.4.1 Variable Defrost Control Refrigerator-Freezers. Steady-state temperatures shall be 5°F 

(-15°C) freezer compartment temperature and 38 ± 2°F (3.3 ± 1.1°C) fresh food compartment temperature 

with no door-openings. If both settings cannot be obtained, then test with the fresh food compartment 

temperature at 38 ± 2°F (3.3 ± 1.1°C) and the freezer compartment as close to 5°F (-15°C) as possible.

After a steady-state refrigerator-freezer condition is achieved, the optional test requires door-openings for 

12 ± 2 seconds every 60 minutes on the fresh food compartment door and a simultaneous 12 ± 2 second 

freezer compartment door-opening occurring every fourth time, to obta in 24 fresh food and six freezer 

compartment door-openings per 24-hour period. The first freezer door-opening shall be simultaneous with 

the fourth fresh food door-opening.

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The doors are to be opened 60° to 90° with an average velocity for the leading edge of the door of 

approximately 2 ft./sec. Prior to the initiation of the door-opening sequence, the refrigerator defrost control 

mechanism may be re- initiated in order to minimize the test duration.

8.5.2.4.2 Variable Defrost Control Freezers. Models shall achieve 0 ± 2°F (-17.8 ± 1.1°C) during the 

steady-state conditions prior to the optional test with no door openings.

After a steady-state freezer condition is achieved, the door-opening sequence is initiated with an 18 ± 2 

second freezer door-opening occurring every eight hours to obtain three door-openings per 24-hour period. 

The first freezer door- opening shall occur at the initiation of the test period.

The doors are to be opened 60° to 90° with an average velocity for the leading edge of the door of 

approximately 2 ft./sec. Prior to the initiation of the door-opening sequence, the refrigerator defrost control 

mechanism may be re-initiated in order to minimize the test duration.

8.6 Test Period. Perform tests by establishing the conditions set forth in 8.4, and using control settings as set 

forth in 8.5 above.

8.6.1 Non-Automatic Defrost. Start the test time period after steady state conditions have been achieved 

and continue it for at least 3 hours.

During the test period, the compressor motor is to complete two or more whole compressor cycles (a 

compressor cycle is a complete "on" and a complete "off" period of the motor). If no "off" cycle will occur, 

as determined during the stabilization period, the test period is to be 3 hours.

If incomplete cycling (less than two compressor cycles) occurs during a 24-hour period, the results of the 24-

hour period are to be used.

8.6.2 Automatic Defrost. If the model being tested has an automatic defrost system, the test time period is 

to be started after steady state conditions have been achieved, and is to be from one point during a defrost 

period to the same point during the next defrost period.

8.6.2.1 Long-Time Automatic Defrost. If the model being tested has a long-time automatic defrost

system, the test period may consist of two parts:

A first part would be the same as the test for a unit having no defrost provisions (section 8.6.1).

The second part would start when a defrost is initiated when the compressor “on” cycle is terminated prior 

to start of the defrost heater and terminates at the second turn “on” of the compressor, or four hours from 

the initiation of the defrost heater, whichever comes first (see Figure 8-1).

8.6.2.2 Variable Defrost Control. If the model being tested has a variable defrost control system, the test 

shall consist of three parts. Two parts shall be the same as the test for long-time automatic defrost (section 

8.6.2.1). The third part is the optional test to determine the time between defrosts (section 8.6.2.3). The 

third part is used by manufacturers that choose not to accept the default value of F of 0.20, to calculate CT.

8.6.2.3 Variable Defrost Control Optional Test. After steady-state conditions with no door openings 

are achieved in accordance with section 8.5.2 above, the test is continued using the daily door-opening 

sequence specified in 8.5.2.4.1 or 8.5.2.4.2 as appropriate until stabilized operation is achieved.

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Stabilization is defined as a minimum of three consecutive defrost cycles with times between defrosts that 

will allow the calculation of a Mean Time Between Defrosts (MTBD1) that satisfies the statistical 

relationship of 90 percent confidence. The test is repeated on at least one more unit of the model and until 

the Mean Time Between Defrosts for the multiple unit tests (MTBD2) satisfies the statistical relationship. 

If the time between defrosts is greater than 96 hours (compressor "on" time) and this defrost period can be 

repeated on a second unit, the test may be terminated at 96 hours (CT) and the absolute time value used for 

MTBD for each unit.

8.6.2.4 Dual Compressor Systems With Automatic Defrost. If the model being tested has separate 

compressor systems for the refrigerator and freezer sections, each with its own automatic defrost system, 

then the two-part method in 8.6.2.1 shall be used. The second part of the method will be conducted 

separately for each automatic defrost system. The auxiliary components (fan motors, anti- sweat heaters, 

etc.) will be identified for each system and the energy consumption measured during each test.

8.7 Test Measurements

8.7.1 Temperature Measurements. Record temperature measurements at the locations prescribed in Figures 

7-1 and 7-2. Temperature measurements are to be accurate to within ± 0.5°F (0.3°C) of true value. No freezer 

temperature measurements need be taken in an all-refrigerator model.

For wine chillers, basic refrigerators and refrigerator-freezers, if the interior arrangements of the cabinet do not 

conform to those shown in Figures 7-1 and 7-2, take measurements at selected locations chosen to represent 

approximately the entire refrigerated compartment. Record the locations selected.

8.7.1.1 Measured Temperature. The measured temperature of a compartment is to be the average of all 

sensor temperature readings taken in that compartment at a particular time. Take measurements at regular 

intervals not to exceed 4 minutes.

8.7.1.2 Compartment Temperature. The compartment temperature for each test period is to be an average 

of the measured temperatures taken in a compartment during a complete cycle or several complete cycles of 

the compressor motor (one compressor cycle is one complete motor "on" and one complete motor "off" 

period).

For long-time automatic defrost models, compartment temperatures are to be those measured in the first part 

of the test period specified in 8.6.2.1.

8.7.1.2.1 The number of complete compressor motor cycles over which the measured temperatures in a 

compartment are to be averaged to determine compartment temperature is to be equal to the number of 

minutes between measured temperature readings, rounded up to the next whole minute or a number of 

complete cycles over a time period exceeding 1 hour.

The set of complete cycles shall include the last complete compressor motor cycle during the test period.

8.7.1.2.2 If no compressor motor cycling occurs, the compartment temperature is to be the average of the 

measured temperatures taken during the last 32 minutes of the test period.

8.7.1.2.3 If incomplete cycling occurs (less than one cycle), the compartment temperatures shall be the 

average of the measured temperatures taken during the last 3 hours of the last complete "on" period.

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8.7.2 Energy Consumption

8.7.2.1 Per-Day Energy Consumption. The energy consumption in kWh/day for each test period is to be 

the energy expended during the test period as specified in section 8.6 adjusted to a 24-hour period. This 

adjustment is to be determined as follows:

8.7.2.1.1 Non-Automatic and Automatic Defrost Models. The energy consumption in kWh/day is to be 

calculated equivalent to:

ET = (EP x 1440 x K)/T, where:

ET = test cycle energy expended in kWh/day.

EP = energy expended in kWh during the test period.

T = length of time on the test period in minutes.

1440 = conversion factor to adjust to a 24-hour period in minutes per day, and

K = correction factor of 0.7 for chest freezers and 0.85 for upright freezers and wine chillers 

(1.0 for all other models) to adjust for average household usage, dimensionless.

8.7.2.1.2 Long-Time Automatic Defrost. If the two-part test method is used, the energy consumption in 

kWh/day is to be calculated equivalent to:

ET = (1440 x K x EP1/T1) + [EP2 – (EP1 x T2/T1)] x K x (12/CT)

where:

ET, 1440 and K are defined in 8.7.2.1.1.

EP1 = energy expended in kWh during the first part of the test.

EP2 = energy expended in kWh during the second part of the test.

T1 and T2 = length of time in minutes of the first and second test parts respectively.

CT = defrost timer run time in hours required to cause it to go through a complete cycle, 

to the nearest tenth hour per cycle.

12 = conversion factor to adjust for a 50% run time of the compressor in hours per day.

8.7.2.1.3 Variable Defrost Control. The energy consumption in kilowatt-hours per day shall be 

calculated equivalent to:

ET = (1440 x EP1/T1) x K + [EP2 - (EP1 x T2/T1)] x K x (12/CT)

where 1440 is defined in 8.7.2.1.1 and EP1, EP2, T1, T2, and 12 are defined in 8.7.2.1.2.

CT = (CTL x CTM)/[F x (CTM - CTL) + CTL] 

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where:

CTL = least or shortest time between defrost in tenths of an hour (greater than or equal to 

6 hours but less than or equal to 12 hours).

CTM = maximum time between defrost cycles in tenths of an hour (greater than CTL but 

not more than 96 hours).

F = ratio of per day energy consumption in excess of the least energy and the 

maximum difference in per day energy consumption and is equal to:

F = (1/CT - 1/CTM) / (1/CTL - 1/CTM) = (ET - ETL) / (ETM - ETL)

or 0.20 in lieu of testing to find CT.

ETL = least electrical energy consumed, in kiloWatt-hours.

ETM = maximum electrical energy consumed, in kiloWatt-hours.

For demand defrost models with no values for CTL and CTM in the algorithm the default values of 12 and 

84 shall be used, respectively.

8.7.2.1.4 Variable Defrost Control Optional Test. Perform the optional test for variable defrost control 

models to find CT.

CT = MTBD x 0.5

MTBD = mean time between defrost.

N

X

MTBD = ∑

X = time between defrost cycles.

N = number of defrost cycles.

8.7.2.1.5 Dual Compressor Systems With Dual Automatic Defrost. The two-part test method in 

section 8.6.2.2 must be used, the energy consumption in kilowatt per day shall be calculated equivalent to:

ET = (1440 x EP1/T1) + [EP2F - (EPF x T2/T1)] x 12/CTF + [EP2R - (EPR x T3/T1)] x 12/CTR

where 1440, EP1, T1, EP2, 12, and CT are defined in 8.7.2.1.2.

EPF = energy expended in kilowatt-hours during the second part of the test for the freezer 

system by the freezer system.

EP2F = total energy expended during the second part of the test for the freezer system.

EPR = energy expended in kilowatt-hours during the second part of the test for the 

refrigerator system by the refrigerator system.

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EP2R = total energy expended during the second part of the test for the refrigerator system.

T2 and T3 = length of time in minutes of the second part for the freezer and refrigerator, 

respectively.

CTF = compressor “on” time between freezer defrosts (tenths of an hour).

CTR = compressor “on” time between refrigerator defrosts (tenths of an hour).

8.8 Determination of Results of Average Per-Cycle Energy Consumption

8.8.1 All-Refrigerator Models. The average per-cycle energy consumption for a cycle type is expressed in 

kWh per cycle to the nearest one hundredth (0.01) kWh and is to depend upon the temperature attainable in the 

fresh food compartment as shown below.

8.8.1.1 If the fresh food compartment temperature is always below 38°F (3.3°C), the average per-cycle 

energy consumption is to be equivalent to:

E = ET1.

where:

E = total per-cycle energy consumption in kWh/day

ET is defined in 8.7.2.1.1, and Number 1 indicates the test period during which the highest fresh 

food compartment temperature is measured.

8.8.1.2 If the average fresh food compartment temperature measured for a test period is greater than 38°F 

(3.3°C), the average per-cycle energy consumption is to be equivalent to:

E = ET1 + (ET2 - ET1) x (38.0 - TR1) / (TR2 - TR1)

where E is defined in 8.8.1.1.

ET is defined in 8.7.2.l.l.

38.0 = standardized fresh food compartment temperature in °F.

TR = fresh food compartment temperature determined according to 8.7.1.2 in °F

Number 1 and 2 indicate measurements taken during the first and second test period as appropriate.

8.8.2 Basic Refrigerators and Refrigerator Freezers. The average per-cycle energy consumption for a 

cycle type is expressed in kWh per cycle to the nearest one hundredth (0.01) kWh and is defined in the 

applicable following manner.

8.8.2.1 If the fresh food compartment temperature is always at or below 45°F (7.2°C) in both of the tests and 

the freezer compartment temperature is always at or below 15°F (-9.4°C) in both tests of a refrigerator or at 

or below 5°F (-15°C) in both tests of a refrigerator-freezer, the per-cycle energy consumption shall be:

E = ET1.

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where:E is defined in 8.8.1.1.

ET is defined in 8.7.2.1.1.

Number 1 indicates the test period during which the highest freezer compartment temperature was 

measured.

8.8.2.2 If the conditions of 8.8.2.1 do not exist, the per-cycle energy consumption is defined by the higher of 

the two values calculated by the following two formulas:

E = ET1 + (ET2 - ET1) x (45.0 - TR1) / (TR2 - TR1), and,

E = ET1 + (ET2 - ET1) x (K - TF1) / (TF2 - TF1) 

where:

E is defined in 8.8.1.1.

ET is defined in 8.7.2.1.1.

TR and Numbers 1 and 2 are defined in 8.8.1.2.

TF = freezer compartment temperature determined according to 8.7.1.2 in °F.

45.0 is a specified fresh food compartment temperature in °F.

K is a constant 15.0 for refrigerators or 5.0 for refrigerator-freezers each being standardized freezer 

compartment temperature in °F.

8.8.3 Upright and Chest Freezers. The average per-cycle energy consumption for a cycle type is expressed 

in kWh per cycle to the nearest one hundredth (0.01) kWh and will depend upon the compartment temperature 

attainable as shown below.

8.8.3.1 If the compartment temperature is always below 0°F (-17.8°C), the average per-cycle energy 

consumption is to be equivalent to, where:

E = ET1.

E = total per-cycle energy consumption in kWh/day.

ET is defined in 8.7.2.1.1.

Number 1 indicates the test period during which the highest compartment temperature is measured.

8.8.3.2 If one of the compartment temperatures measured for a test period is greater than 0°F (-17.8°C), the 

average per-cycle energy consumption is to be the equivalent to:

E = ET1 + (ET2 - ET1) x (0.0 - TF1) / (TF2 - TF1)

where:E is defined in 8.8.3.1.

ET is defined in 8.7.2.1.1.

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TF = freezer compartment temperature determined according to 8.7.1.2 in °F.

Numbers 1 & 2 indicate measurements taken during the first and second test period as appropriate.

0.0 = standardized compartment temperature in °F.

8.8.4 Wine Chillers. The average per-cycle energy consumption for a cycle type is expressed in kWh per 

cycle to the nearest one hundredth (0.01) kWh and is to depend upon the temperature attainable in the wine 

storage compartment as shown below.

8.8.4.1 If the wine storage compartment temperature is always at or below 55°F (12.8°C) in both of the tests, 

the per-cycle energy consumption shall be:

E = ET1, where:

E = total per-cycle energy consumption in kWh/day

ET is defined in 8.7.2.1.1, and Number 1 indicates the test period during which the highest wine storage

compartment temperature is measured.

8.8.4.2 If the average wine storage compartment temperature measured for a test period is greater than 55°F 

(12.8°C), the average per-cycle energy consumption is to be equivalent to:

E = ET1 + (ET2 - ET1) x (55.0 - TW1) / (TW2 - TW1).

where:

E is defined in 8.8.1.1.

ET is defined in 8.7.2.1.1.

TW = wine storage compartment temperature determined according to 8.7.1.2 in °F

55.0 is a standardized wine storage compartment temperature in °F.

8.8.5 Data To Be Recorded

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperature.

(c) Voltage and frequency.

(d) Total per cycle energy consumption in kWh/day.

(e) Compartment temperatures at which (d) was determined.

 (If model has an anti-sweat heater switch, use the average value of the two test runs -- see 8.4.2.1.)

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FIGURE 8-1

LONG TIME AUTOMATIC DEFROST DIAGRAM

4 hours maximum

T2

Time

Energy

Start defrost

part of test

End defrost

part of test

Regular compressor cycle

Defrost heater

Compressor recovery

cycle after defrost

Regular compressor cycle

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9. METHOD FOR COMPUTING ADJUSTED VOLUME AND ENERGY FACTOR OF HOUSEHOLD 

REFRIGERATORS, HOUSEHOLD WINE CHILLERS, AND HOUSEHOLD FREEZERS

9.1 Scope of Section 9. This section provides a standard method for calculating the energy factor of various 

types of household refrigerators, household wine chillers, and household freezers.

9.2 Purpose. The purpose for calculating the energy factor is to provide a uniform means of comparing the 

relative energy efficiency between different products by relating all products to a common base.

9.3 Adjusted Volume. The adjusted volume is calculated as follows:

Adjusted Volume (AV) = VFresh Food + (VFreezer x Adjustment Factor)

VFresh Food = Volume of the fresh food compartment of household refrigerators as determined by 

Section 4.

VFreezer = Volume of the freezer compartment of household refrigerators as determined by 

Section 4 or household freezers as determined by Section 5.

9.3.1 Adjustment Factor For Basic Refrigerator Type Household Refrigerators

(90 - 15) / (90 - 38) = 1.44

9.3.2 Adjustment Factor For All-Refrigerator Type Household Refrigerators

(90 - 38) / (90 - 38) = 1.00

9.3.3 Adjustment Factor For Combination Refrigerator-Freezer Type Household Refrigerators

(90 - 5) / (90 - 38) = 1.63

9.3.4 Adjustment Factor For Household Freezers

(90 - 0) / (90 - 38) = 1.73

 9.3.5 Adjustment Factor for Household Wine Chillers

 (90 - 55) / (90 - 55) = 1.00

9.4 Calculation of Energy Factor:

EF = AV/E, where:

EF = Energy Factor.

AV = Adjustment volume as determined in 9.3.

E = Total per cycle energy consumption expressed as kWh consumed per 24 hours. 

This value is obtained as follows:

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 (1) for all-refrigerators: 8.8.1;

(2) for basic refrigerators and refrigerator-freezers: 8.8.2;

(3) for upright and chest freezers: 8.8.3.

(4) for wine chillers: 8.8.4

10. DURABILITY AND CONDENSATE TEST PROCEDURES FOR HOUSEHOLD REFRIGERATORS 

AND HOUSEHOLD FREEZERS

10.1 Scope of Section 10. This section describes uniform procedures for determining the durability of various 

components of mechanically-operated household refrigerators and household freezers as affected by use or 

environmental conditions.

The durability test procedures in this section are:

10.2 Handling and Storage Test.

10.3 External Surface Condensation Test.

10.4 Internal Moisture Accumulation Test.

10.5 Environmental Cracking Resistance Test.

10.6 Bottom Breaker Strip(s) Impact Test.

10.2 Handling and Storage Test (Household Refrigerators and Household Freezers)

10.2.1 Purpose. The purpose of this test is to determine the ability of the cabinet, when packaged for 

shipment, to withstand handling and storage conditions in extreme (high and low ambient) temperatures. It is 

intended to provide greater assurance that a cabinet packaged for shipment is so designed that a consumer will 

receive undamaged merchandise by exposing it to the extreme temperatures and mechanical shock of the type 

to which it might be exposed during alternate storage and movement in the various stages of distribution.

10.2.2 Test Conditions. The test ambient(s) shall be maintained at temperatures of 140 ± 5°F (60 ± 2.8°C) 

and 0 ± 5°F (-17.8 ± 2.8°C).

The floor used for the drop test may be of masonry, metal or other construction with low cushioning effect.

The cabinet(s) is to be packed and crated in accordance with the manufacturer's instructions.

10.2.3 Test Procedure. The crated cabinet is to be placed in an ambient temperature of 70 - 90°F 

(21.1 - 32.2°C) for a minimum of 24 hours and then is to be placed in one of the test ambients for at least 12 

hours. At the end of this test period the cabinet is to be placed on the test floor and subjected to the following 

test to be conducted during the next hour. The cabinet is to again be placed in an ambient temperature of 

70 - 90°F (21.1 - 32.2°C) for a minimum of 24 hours and then is to be placed in the other test ambient for at 

least 12 hours and the tests repeated. If desired, a separate cabinet may be used at each ambient temperature.

10.2.3.1 One side of the crated cabinet(s) is to be raised 6 inches (15.2 cm) from the floor and suddenly 

released. This procedure is to be repeated for the other three sides.

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10.2.3.2 The cabinet(s) is then to be unpacked, operated, and all accessible parts examined for damage.

10.2.4 Data To Be Recorded

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperatures.

(c) Damage observed as determined from visual inspection and operation.

10.3 External Surface Condensation Test (Household Refrigerators and Household Freezers)

10.3.1 Purpose. The purpose of this test is to determine the extent of condensation of water on the external 

surface of the cabinet under ambient conditions of high relative humidity.

10.3.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4.

The ambient temperature is to be 90 ± 2°F (32.2 ± 1.1°C) dry bulb and the relative humidity is to be 75 ± 2%.

The cabinet is to be prepared with its shelves and accessories in place in accordance with the manufacturer's 

instructions but without food and ice load. Cabinet surfaces should be free of all soil, tape, dirt, dust, oil and 

other foreign matter.

Anti-condensation heaters, if provided, are to be set at the highest heat position.

The temperature control(s) is to be set to maintain the following temperatures:

Household refrigerator, average fresh food compartment temperature 38 ± 2°F (3.3 ± 1.1°C).

Combination refrigerator-freezer --multiple control, average fresh food compartment temperature 38 ± 2°F

(3.3 ± 1.1°C); average freezer compartment temperature 5 ± 2°F (-15 ± 1.1°C).

Household freezer, average freezer compartment temperature 0 ± 2°F (-17.8 ± 1.1°C).

10.3.3 Test Procedure. The cabinet is to be placed in the test room and operated until the average 

temperatures in the fresh food and freezer compartments have reached steady state condition.

After steady state condition has been attained, carefully wipe dry all exterior surfaces of the cabinet with a 

clean cloth and continue the test period for an additional 4 hours.

During this test period, the surface areas exhibiting fog, droplets, and running water (see Figure 10-1) are to be 

outlined on the exterior surfaces and designated with the letters F, D and R respectively.

10.3.4 Data To Be Recorded

 (a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

 (b) Ambient temperature.

 (c) Ambient relative humidity.

 (d) Voltage and frequency.

EERE-2006-BT-STD-0126 COMMENT 46
88

 (e) Average fresh food compartment temperature (if applicable).

 (f) Average freezer compartment temperature (if applicable).

(g) Coded sketch showing maximum area and degree of condensation (see Figures 10-2a through e) that 

appears during the test period.

NOTE: Surface condensation of the types F (fog) and D (droplets) is generally acceptable to the consumer; running 

droplets are not.

10.4 Internal Moisture Accumulation Test (Household Refrigerators and Household Freezers)

10.4.1 Purpose. The purpose of this test is to determine under severe operating conditions the moisture 

accumulation within the insulation spaces and on the refrigerated surface in the cabinet and the effectiveness of 

defrost water disposal (if applicable).

10.4.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4.

The ambient temperature is to be 90 ± 2°F (32.2 ± 1.1°C) dry bulb, and the relative humidity is to be 75 ± 2%.

The cabinet is to be prepared with its shelves and accessories in place in accordance with the manufacturer's 

instructions but without food and ice load.

All defrost controls are to be operative during the test.

10.4.3 Test Procedure. The test period is to be started after the cabinet has reached steady state conditions 

with the control(s) set to maintain the following temperatures.

The control settings are not to be changed during the test.

Household refrigerator, average fresh food compartment temperature 38 ± 2°F (3.3 ± 1.1°C).

Combination refrigerator-freezer --multiple control, average fresh food compartment temperature 38 ± 2°F 

(3.3 ± 1.1°C); average freezer compartment temperature 5 ± 2°F (-15 ± 1.1°C).

Household freezer, average freezer compartment temperature 0 ± 2°F (-17.8 ± 1.1°C).

The test period is to be 21 days with the following door opening schedule practiced daily:

DAILY DOOR OPENINGS

Type of Cabinet

Fresh Food

Compartment 

Freezer

Compartment 

Basic Refrigerators

and

All Refrigerators

96 — 

Household 

Combination

RefrigeratorFreezers

96 24 

Household Freezers — 24

EERE-2006-BT-STD-0126 COMMENT 46
89

Door openings are to be of 12-second duration each and uniformly spaced over the first 16 hours of each test 

day. The last 8 hours of each test day is to be a recovery period with no door openings. During all door 

openings and closings, the average velocity of the leading edge of the door is to be approximately 2 ft. (60 cm) 

per second. The door(s) is to be opened at least 45° and not more than 90°.

Manual-defrosting and semi-automatic defrosting household refrigerators (not combination refrigeratorfreezers) are to be defrosted on an alternating 3 to 4 day schedule during the 21-day test period with the first 

defrost during the third or fourth 8-hour recovery period, whichever is desired. Combination refrigeratorfreezers, household freezers and partial automatic defrost combination refrigerator-freezers are not to be 

defrosted during the 21-day test period.

If an exterior evaporating drain pan is provided for defrost water disposal, observations are to be made during 

the 21-day test period to determine if the pan overflows.

At the end of the 16-hour door opening period on the 21st day of the test period, the cabinet is to be tested for 

current leakage in accordance with ANSI C101.1.

At the end of the 21 day test period, the accessible refrigerated surfaces are to be immediately examined for the 

presence of ice and frost and description thereof recorded. The cabinet interior is to be wiped dry. The cabinet 

is then to be removed from the test room, disassembled as quickly as possible, and examined for water, and ice 

accumulated in the insulation and insulation spaces and on inaccessible refrigerated surfaces and description 

thereof recorded. Full thickness samples of insulation of at least 1 ft.2 (0.09 m2) are to be taken from each of 

the following parts for determination of the water content in percent dry weight of insulation. If necessary, the 

cabinet is to be cut to obtain the insulation samples.

Insulation is to be taken from:

(a) The bottom of the cabinet.

(b) The back of the cabinet opposite the freezer compartment. If the freezer compartment is at the bottom of 

the cabinet, an additional back sample is to be obtained from within 18 inches (45.7 cm) of the top of the 

cabinet.

(c) One side of the cabinet adjacent to the breaker strip and next to the freezer compartment.

(d) Compartment doors at the bottom (for chest freezers take sample from approximate center of the lid).

(e) Other areas as desired.

10.4.4 Data To Be Recorded

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient relative humidity.

(c) Ambient temperature.

(d) Voltage and frequency.

(e) Fresh food compartment temperature at the start of the test.

EERE-2006-BT-STD-0126 COMMENT 46
90

(f) Freezer compartment temperature at the start of the test.

(g) Amount and location (sketch and/or photograph of ice and/or frost accumulation on refrigerated 

surfaces).

(h) Visible water or ice in insulation location.

(i) Degree and location of water on metallic surfaces, joints and seams that comprise the insulation space.

(j) Water content of each insulation sample, percent of dry weight.

(k) Drain pan overflow, if any.

10.5 Environmental Cracking Resistance Test (Household Refrigerators and Household Freezers)

10.5.1 Purpose. The purpose of this test is to determine the cracking resistance of the plastic compartment 

liners, door liners and breaker strips at operating temperature when coated with 50/50 mixture of oleic acid and 

cotton seed oil.

10.5.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4.

The ambient temperature is to be 70 - 90°F (21.1 - 32.2°C).

The cabinet is to be prepared with its shelves and accessories in place in accordance with the manufacturer's 

instructions but without food and ice load.

The cabinet temperature(s) during the test is to be:

Household refrigerator, average fresh food compartment temperature 38 ± 2°F (3.3 ± 1.1°C).

Combination refrigerator-freezer --multiple control, average fresh food compartment temperature 38 ± 2°F 

(3.3 ± 1.1°C); average freezer compartment temperature 5 ± 2°F (-15 ± 1.1°C).

Household freezer, average freezer compartment temperature 0 ± 2°F (-17.8 ± 1.1°C).

The compartment shelves are to be uniformly loaded as follows:

Compartment shelves - 10 inches (25.4 cm) or more in height: 40 lbs/ft2 (195.5 kg/m2). Maximum per 

shelf: 100 lbs. (45.4 kg).

Compartment shelves - less than 10 inches (25.4 cm) in height: 20 lbs/ft2 (97.8 kg/m2). Maximum per 

shelf: 100 lbs. (45.4 kg).

The door shelves are to be uniformly loaded with standard test loads as follows:

Full width door shelves 10 inches (25.4 cm) or more in height are to be loaded at the extreme right and left 

sides respectively with a load cylinder whose height is 71⁄2 inches (19.1 cm) and whose diameter is the 

largest given in Table 10-1 that will fit on the shelf. Additional 71⁄2 inch (19.05 cm) high load blocks (see 

Table 10-1) equal in weight to the cylindrical end loads are to be added to the shelf to give a total minimum 

loading of 30 lbs/ft2 (146.6 kg/m2).

EERE-2006-BT-STD-0126 COMMENT 46
91

Full width door shelves less than 10 inches (25.4 cm) in height are to be loaded at the extreme right and left 

sides respectively with a load cylinder whose height is a minimum of 50% of the shelf height and whose 

diameter is the largest given in Table 10-1 that will fit on the shelf. Additional load blocks (see Table 10-1) 

equal in weight and height to the cylindrical end loads are to be added to the shelf to give a total minimum 

loading of 15 lbs/ft2 (73.3 kg/m2).

Load cylinder and load block heights to be 71⁄2 inches (19.05 cm) for shelves 10 inches (25.4 cm) or more in 

height.

Load cylinder and load blocks to be a minimum of 50% of the shelf height for shelves less than 10 inches (25.4 

cm) high.

Butter or cheese compartments - 7 lbs/ft2 (34.2 kg/m2).

Egg shelves - 0.20 lb. (0.09 kg) per egg space.

10.5.3 Test Procedure. The cabinet is to be placed in the test room and operated until the average 

temperatures in the fresh food and freezer compartments have reached steady state condition.

After steady state condition has been attained, the normally exposed surfaces of the exterior door liner, 

compartment liner (if plastic), and the breaker strips are to be completely coated with a thin film of 50/50 

mixture of oleic acid and cottonseed oil, and the shelves are then to be loaded. Following this, the load 

cylinders at the extreme right and left of each door shelf are to be raised 2 inches (5.1 cm) and then dropped.

The door(s) is then to be closed and the cabinet continued to be operated.

After 2 hours of cabinet operation, the door(s) is to be slammed 12 times at a rate of about 2 ft. (0.6 m) per 

second at the leading edge of the door.

The door(s) is to be slammed and the load cylinders dropped once each 24 hours as described above.

The compartment(s) and door liner(s) and the breaker strips are to be examined for cracks and crazing daily for 

8 days. The test may be adjusted to normal work schedule.

TABLE 10-1

Load Cylinder

Diameter In

Inches

Load Block

Width x Depth

Inches

Load Cylinder

& Load Block

Lower End

Chamfer 45 x

Weights For

Shelves

Under 10" High

Weights For

Shelves 10" High

Or Greater

1 

2 

3 

4 

5 

6 

1 x 1

2 x 2

3 x 3

4 x 4

5 x 5

6 x 6

1⁄4 

1⁄2 

1⁄2 

1⁄2 

1⁄2 

1⁄2 

.10 Lbs. 

.42 Lbs. 

.94 Lbs. 

1.67 Lbs. 

2.10 Lbs. 

3.75 Lbs. 

.21 Lbs. 

.84 Lbs. 

1.88 Lbs. 

3.34 Lbs. 

5.21 Lbs. 

7.50 Lbs.

EERE-2006-BT-STD-0126 COMMENT 46
92

10.5.4 Data To Be Recorded

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperatures.

(c) Average fresh food compartment temperature (if applicable).

(d) Average freezer compartment temperature (if applicable).

(e) Location and length of cracks and crazing found in door inner liner(s).

(f) Location and length of cracks or crazing found in breaker strips.

(g) Location and length of cracks and crazing found in compartment liner(s).

10.6 Bottom Breaker Strip(s) Impact Test (Household Refrigerators and Household Freezers)

10.6.1 Purpose. The purpose of this test is to determine the impact resistance of the bottom breaker strip(s) at 

operating temperature.

10.6.2 Test Conditions. The general test conditions are to be in accordance with Paragraphs 7.2, 7.3 and 7.4. 

The ambient temperatures are to be 70 - 90°F (21.1 - 32.2°C).

The cabinet is to be prepared with its shelves and accessories in place in accordance with the manufacturer's 

instructions but without food and ice load.

The cabinet temperature(s) during the test is to be:

Household refrigerator, average fresh food compartment temperature 38 ± 2°F (3.3 ± 1.1°C)

Combination refrigerator-freezer --multiple control, average fresh food compartment temperature 38 ± 2°F 

(3.3 ± 1.1°C); average freezer compartment temperature 5 ± 2°F (-15 ± 1.1°C).

Household freezer, average freezer compartment temperature 0 ± 2°F (-17.8 ± 1.1°C).

A 2 lb. (0.91 kg) dart having a 1⁄2 inch (1.3 cm) spherical radius hardened steel point is to be used to impact or 

strike the breaker strip as assembled in the cabinet.

10.6.3 Test Procedure. The cabinet is to be placed in the test room and operated until the average 

temperature in the fresh food and freezer compartments have reached steady state conditions.

After 3 hours of operation at steady state condition, open the door(s) and drop the dart onto the bottom breaker 

strip(s) impacting toward the center of the span and width. Start with a drop of 5 inches (12.7 cm) and then 

increase with successive drops at 5 inch (12.7 cm) increments until failure occurs or the highest shelf level 

(door or compartment), whichever is lesser, is achieved. Move the location of impact for each drop along the 

breaker strip with no impact closer than approximately 2 inches (5.1 cm) to a preceding impact. If the strip 

visibly cracks before maximum drop is achieved, stop the test and report the results.

All drops are to be performed within 1 minute after the door is opened.

EERE-2006-BT-STD-0126 COMMENT 46
93

The dart is to impact the breaker strip only once with each drop.

10.6.4 Data To Be Recorded

(a) Type, model number, serial number, if any, and manufacturer or brand name of cabinet.

(b) Ambient temperature.

(c) Voltage and frequency.

(d) Average fresh food compartment temperature (if applicable).

(e) Average freezer compartment temperature (if applicable).

(f) Location and size of cracks and crazing and impact value in inch-pounds (kilogram-meters).

EERE-2006-BT-STD-0126 COMMENT 46
94

EERE-2006-BT-STD-0126 COMMENT 46
95

(90F and 75% Relative Humidity Ambient)

Back Right Side Front Left Side

Fig. 10-2a

Format For Reporting External Surface Condensation Test Results - Single Door Cabinet

Bottom Top

FDR

EERE-2006-BT-STD-0126 COMMENT 46
96

Format for Reporting External Surface Condensation Test Results -Two Door Cabinet-Top Freezer Compartment

(90F and 75% Relative Humidity Ambient)

Back Right Side Front

Fig. 10-2b

Left side

View "A"

Top

View "B"

View "A" Bottom

F

D

R

View "B"

EERE-2006-BT-STD-0126 COMMENT 46
97

Bottom View "A"

View "B"

Back Left Side

Fig. 10 -2c

Format for Reporting External Surface Condensation Test Results - Two Door Cabinet - Bottom Freezer Compartment

(90F and 75% Relative Humidity Ambient)

Top

Right Side Front

F

D

R

View "A"

View "B"

EERE-2006-BT-STD-0126 COMMENT 46
98

Bottom

Back

Top

Front Right Side Left Side

Format for Reporting External Surface Condensation Test Results - Horizontal Door Cabinet (Chest)

(90F and 75% Relative Humidity Ambient)

F

DR

Fig. 10 - 2d

EERE-2006-BT-STD-0126 COMMENT 46
99

Format for Reporting External Surface Condensation Test Results - Two Door Side by Side Cabinet

Fig. 10-2e

(90F and 75% Relative Humidity Ambient)

FD

R

Top Bottom

Left Side Front Right Side Back

View "A" View "B"

View "A"

View "B"

EERE-2006-BT-STD-0126 COMMENT 46
100

11. SAFETY OF HOUSEHOLD REFRIGERATORS, HOUSEHOLD WINE CHILLERS AND 

HOUSEHOLD FREEZERS

It is recommended that household refrigerators, household wine chillers and household freezers intended 

for installation in the U.S.A. meet the requirements of the latest edition of Underwriters Laboratories Inc., 

"Standard for Safety, Household Refrigerators and Freezers," UL 250/CSA C22.2 No. 63.

Copies are available from Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, Illinois 

60062; 1285 Walt Whitman Road, Melville, L.I., New York 11747; 1655 Scott Boulevard, Santa Clara, 

California 95050; and 12 Laboratory Drive, P.O. Box 13995, Research Triangle Park, North Carolina 

27709 or Canadian Standards Association, 178 Rexdale Blvd., Etobicoke, Ontario, M9W 1R3.

EERE-2006-BT-STD-0126 COMMENT 46
Association of Home Appliance Manufacturers

1111 19th Street, NW • Suite 402 • Washington, DC

EERE-2006-BT-STD-0126 COMMENT 46
EERE-2006-BT-STD-0126 COMMENT 46 

MEMORANDUM FOR THE DEPUTY SECRETARY 

THROUGH: C. H. ALBRIGHT, JR. 

UNDER SECRETARY OF ENERGY 

FROM: JOHN F. MIZROCH 

 ACTING ASSISTANT SECRETARY 

 ENERGY EFFICIENCY AND RENEWABLE ENERGY 

SUBJECT: ACTION: Approval to Publish in the Federal Register a Final Rule for 

Energy Conservation Standards for Commercial Refrigeration Equipment 

(RIN: 1904-AB59) 

ISSUE: The notice requests approval to publish in the Federal Register the attached notice of 

final rule for ice-cream freezers; self-contained commercial refrigerators, freezers, and 

refrigerator-freezers without doors; and remote-condensing commercial refrigerators, freezers, 

and refrigerator-freezers (commercial refrigeration equipment). 

BACKGROUND:

 Commercial refrigeration equipment is used primarily to store and display perishable 

food products for sale in food-sales buildings (e.g., supermarkets and convenience 

stores), some multi-line retail stores, and in some food service applications like 

restaurants, salad bars, and cafeterias. 

 The Energy Policy Act of 2005 (EPACT 2005) amends the Energy Policy and 

Conservation Act to add new subsection 342(c)(4)(A), which directs the Secretary of 

Energy to issue by rule energy conservation standards for the above commercial 

refrigeration equipment. 42 U.S.C. 6313(c)(4)(A). 

 Major interested parties include Hill Phoenix; Hussman; Tyler Refrigeration; Zero Zone; 

Delfield; Structural Concepts; Master-Bilt; Kysor Warren; the Air-Conditioning, Heating, 

and Refrigeration Institute; and the American Council for an Energy Efficient Economy. 

 In this final rule, the U.S. Department of Energy (DOE) is adopting trial standard level 

(TSL) 4 for ice cream freezers; self-contained commercial refrigerators, freezers, and 

refrigerator-freezers without doors; and remote-condensing commercial refrigerators, 

freezers, and refrigerator-freezers. 
EERE-2006-BT-STD-0126 COMMENT 46 

o TSL 4 will result in significant national energy savings and is technologically 

feasible and economically justified. 

o DOE's adoption of TSL 4 represents the maximum efficiency levels that the 

analysis showed to have positive net present value to the Nation for all equipment 

classes. 

 The energy conservation standard would apply to all commercial refrigeration equipment 

manufactured on or after January 1, 2012, and offered for sale in the United States. 

SENSITIVITIES: This rulemaking is one of the scheduled actions described in the 

Department’s report to Congress, which was prepared in response to section 141(a) of EPACT 

2005. 

POLICY IMPACT: This rulemaking supports the implementation of EPACT 2005. 

URGENCY: To meet the deadlines in the report to Congress, this notice should be submitted to 

the Federal Register no later than December 31, 2008. 

RECOMMENDATION: Recommend this notice be approved for publication in the Federal 

Register. 

Attachment 

Approve: __________________________ 

Disapprove: ________________________ 

Date: _____________________________ 

 

CONCURRENCE: GC 

 PI 

 OMB 
EERE-2006-BT-STD-0126 COMMENT 46 

MEMORANDUM FOR: David R. Hill 

 General Counsel 

 Jonathan Shrier 

 Acting Assistant Secretary for Policy 

 and International Affairs 

FROM: John F. Mizroch 

 Acting Assistant Secretary 

 Energy Efficiency and Renewable Energy 

SUBJECT: ACTION: Approval to Publish in the Federal Register a Final 

Rule for Energy Conservation Standards for Commercial 

Refrigeration Equipment (RIN: 1904-AB59) 

ISSUE: The attached notice concerning the above subject is provided 

for your concurrence or nonconcurrence. 

• This rulemaking is one of the scheduled actions described 

in the Department of Energy’s report to Congress, which 

was prepared in response to section 141(a) of the Energy 

Policy Act of 2005. It has a scheduled publication date of 

January 1, 2009 for a final rule. 

• In order to coordinate the response to this request on a 

timely basis, we have forwarded a copy of the package to 

each addressee for concurrence. 

• Please deliver your response to Robbie Dooms, EE 

ESECS Coordinator, EE-12, in Room 5E-042, by 

_______________. 

Attachments 
 EERE-2006-BT-STD-0126 COMMENT 46 **DRAFT** 

[BILLING CODE] 

DEPARTMENT OF ENERGY 

10 CFR Part 431 

[Docket Number: EERE–2006–BT–STD–0126] 

RIN 1904–AB59 

Energy Conservation Program for Commercial and Industrial Equipment: Energy 

Conservation Standards for Commercial Ice-Cream Freezers; Self-Contained 

Commercial Refrigerators, Commercial Freezers, and Commercial RefrigeratorFreezers without Doors; and Remote Condensing Commercial Refrigerators, 

Commercial Freezers, and Commercial Refrigerator-Freezers 

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

 

ACTION: Final rule. 

SUMMARY: The Department of Energy (DOE) is adopting new energy conservation 

standards for commercial ice-cream freezers; self-contained commercial refrigerators, 

commercial freezers, and commercial refrigerator-freezers without doors; and remote 

condensing commercial refrigerators, commercial freezers, and commercial refrigeratorfreezers. DOE has determined that energy conservation standards for these types of 

equipment would result in significant conservation of energy, and are technologically 

feasible and economically justified. 

46Cfinal 

1
 EERE-2006-BT-STD-0126 COMMENT 46 **DRAFT** 

DATES: The effective date of this rule is [INSERT DATE 60 DAYS FROM DATE OF 

PUBLICATION]. The standards established in today’s final rule will be applicable starting 

January 1, 2012. Incorporation by reference of the material listed is approved by the 

Director of the Federal Register on [INSERT DATE 60 DAYS FROM DATE OF 

PUBLICATION]. 

ADDRESSES: For access to the docket to read background documents, the technical 

support document, transcripts of the public meetings in this proceeding, or comments 

received, visit the U.S. Department of Energy, Resource Room of the Building 

Technologies Program, 950 L’Enfant Plaza, SW., 6th Floor, Washington, DC 20024, (202) 

586-2945, between 9 a.m. and 4 p.m., Monday through Friday, except Federal holidays. 

Please call Brenda Edwards at the above telephone number for additional information 

regarding visiting the Resource Room. (Note: DOE’s Freedom of Information Reading 

Room no longer houses rulemaking materials.) You may also obtain copies of certain 

previous rulemaking documents in this proceeding (i.e., framework document, advance 

notice of proposed rulemaking, notice of proposed rulemaking), draft analyses, public 

meeting materials, and related test procedure documents from the Office of Energy 

Efficiency and Renewable Energy’s website at 

www.eere.energy.gov/buildings/appliance_standards/commercial/refrigeration_equipment.h

tml.

FOR FURTHER INFORMATION CONTACT: 

46Cfinal 

2
 EERE-2006-BT-STD-0126 COMMENT 46 **DRAFT** 

Charles Llenza, U.S. Department of Energy, Energy Efficiency and Renewable 

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

Washington, DC 20585-0121, (202) 586-2192, Charles.Llenza@ee.doe.gov. 

Francine Pinto, Esq., U.S. Department of Energy, Office of General Counsel, GC72, 1000 Independence Avenue, SW., Washington, DC 20585-0121, (202) 586-9507, 

Francine.Pinto@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: 

Table of Contents: 

I. Summary of the Final Rule and Its Benefits 

A. The Standard Levels 

B. Benefits to Customers of Commercial Refrigeration Equipment 

C. Impact on Manufacturers 

D. National Benefits 

II. Introduction 

A. Authority 

B. Background 

1. History of Standards Rulemaking for Commercial Refrigeration Equipment 

III. General Discussion 

A. Test Procedures 

B. Technological Feasibility 

1. General 

2. Maximum Technologically Feasible Levels 

C. Energy Savings 

D. Economic Justification 

1. Specific Criteria 

a. Economic Impact on Commercial Customers and Manufacturers 

b. Life-Cycle Costs 

c. Energy Savings 

d. Lessening of Utility or Performance of Equipment 

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 of Comments on Methodology 

A. Market and Technology Assessment 

1. Definitions Related to Commercial Refrigeration Equipment 

46Cfinal 

3
 EERE-2006-BT-STD-0126 COMMENT 46 **DRAFT** 

a. Air-Curtain Angle Definition 

b. Door Angle Definition 

c. Ice-Cream Freezer Definition 

d. Equipment Configuration Definitions 

e. Hybrid and Wedge Case Definitions 

2. Equipment Classes 

B. Engineering Analysis 

1. Approach 

2. Analytical Models 

a. Cost Model 

b. Energy Consumption Model 

3. Equipment Classes Analyzed 

4. Wedge Cases 

5. Ice-Cream Freezers—Temperature Range 

6. Special Application Temperature Cases 

7. Coverage of Remote Condensing Units 

8. Regulating Secondary Cooling Applications 

C. Markups to Determine Equipment Price 

D. Energy Use Characterization 

E. Life-Cycle Cost and Payback Period Analyses 

F. Shipments Analysis 

G. National Impact Analysis 

H. Life-Cycle Cost Sub-Group Analysis 

I. Manufacturer Impact Analysis 

J. Utility Impact Analysis 

K. Employment Impact Analysis 

L. Environmental Assessment 

V. Discussion of Other Comments 

A. Information and Assumptions Used in Analyses 

1. Market and Technology Assessment 

a. Data Sources 

b. Beverage Merchandisers 

2. Engineering Analysis 

a. Design Options 

b. Baseline Models 

c. Consideration of Alternative Refrigerants 

d. Consideration of NSF 7 Type II Equipment 

e. Product Class Extension Factors 

f. TSL Energy Limits 

g. Compressor Selection Oversize Factor 

h. Offset Factors for Self-Contained Equipment 

i. Self-Contained Condensing Coils 

3. Manufacturer Impact Analysis 

VI. Analytical Results and Conclusions 

A. Trial Standard Levels 

1. Miscellaneous Equipment 

46Cfinal 

4
 EERE-2006-BT-STD-0126 COMMENT 46 **DRAFT** 

B. Significance of Energy Savings 

C. Economic Justification 

1. Economic Impact on Commercial Customers 

a. Life-Cycle Costs and Payback Period 

b. Commercial Customer Sub-Group Analysis 

2. Economic Impact on Manufacturers 

a. Industry Cash-Flow Analysis Results 

b. Cumulative Regulatory Burden 

c. Impacts on Employment 

d. Impacts on Manufacturing Capacity 

e. Impacts on Manufacturers That Are Small Businesses 

3. National Net Present Value and Net National Employment 

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 

D. Conclusion 

VII. Procedural Issues and Regulatory Review 

A. Review Under Executive Order 12866 

B. Review Under the Regulatory Flexibility Act 

C. Review Under the Paperwork Reduction Act 

D. Review Under the National Environmental Policy Act 

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 

M. Congressional Notification 

VIII. Approval of the Office of the Secretary 

I. Summary of the Final Rule and Its Benefits 

A. The Standard Levels

The Energy Policy and Conservation Act, as amended (42 U.S.C. 6291 et seq.; 

EPCA), directs the Department of Energy (DOE) to establish mandatory energy 

conservation standards for commercial ice-cream freezers; self-contained commercial 

refrigerators, commercial freezers, and commercial refrigerator-freezers without doors; and 

46Cfinal 

5
 EERE-2006-BT-STD-0126 COMMENT 46 **DRAFT** 

remote condensing commercial refrigerators, commercial freezers, and commercial 

refrigerator-freezers. (42 U.S.C. 6313(c)(4)(A)) These types of equipment are referred to 

collectively hereafter as “commercial refrigeration equipment.” Any such standard must be 

designed to “achieve the maximum improvement in energy efficiency . . . which the 

Secretary determines is technologically feasible and economically justified.” (42 U.S.C. 

6295(o)(2)(A) and 6316(e)(1)) Furthermore, the new standard must “result in significant 

conservation of energy.” (42 U.S.C. 6295(o)(3)(B) and 6316(e)(1)) The standards in today’s 

final rule, which apply to all commercial refrigeration equipment, satisfy these 

requirements.1

Table I-1 shows the standard levels DOE is adopting today. These standards will 

apply to all commercial refrigeration equipment manufactured for sale in the United States, 

or imported to the United States, on or after January 1, 2012. 

 

1

 Currently, no mandatory Federal energy conservation standards exist for the commercial refrigeration 

equipment covered by this rulemaking. 

46Cfinal 

6
 EERE-2006-BT-STD-0126 COMMENT 46 **DRAFT** 

Table I-1 Standard Levels for Commercial Refrigeration Equipment 

Equipment 

Class2

Standard Level *,**

(kWh/day)*** 

Equipment 

Class 

Standard Level *,**

(kWh/day) 

VOP.RC.M 0.82 x TDA + 4.07 VCT.RC.I 0.66 x TDA + 3.05 

SVO.RC.M 0.83 x TDA + 3.18 HCT.RC.M 0.16 x TDA + 0.13 

HZO.RC.M 0.35 x TDA + 2.88 HCT.RC.L 0.34 x TDA + 0.26 

VOP.RC.L 2.27 x TDA + 6.85 HCT.RC.I 0.4 x TDA + 0.31 

HZO.RC.L 0.57 x TDA + 6.88 VCS.RC.M 0.11 x V + 0.26 

VCT.RC.M 0.22 x TDA + 1.95 VCS.RC.L 0.23 x V + 0.54 

VCT.RC.L 0.56 x TDA + 2.61 VCS.RC.I 0.27 x V + 0.63 

SOC.RC.M 0.51 x TDA + 0.11 HCS.RC.M 0.11 x V + 0.26 

VOP.SC.M 1.74 x TDA + 4.71 HCS.RC.L 0.23 x V + 0.54 

SVO.SC.M 1.73 x TDA + 4.59 HCS.RC.I 0.27 x V + 0.63 

HZO.SC.M 0.77 x TDA + 5.55 SOC.RC.L 1.08 x TDA + 0.22 

HZO.SC.L 1.92 x TDA + 7.08 SOC.RC.I 1.26 x TDA + 0.26 

VCT.SC.I 0.67 x TDA + 3.29 VOP.SC.L 4.37 x TDA + 11.82 

VCS.SC.I 0.38 x V + 0.88 VOP.SC.I 5.55 x TDA + 15.02 

HCT.SC.I 0.56 x TDA + 0.43 SVO.SC.L 4.34 x TDA + 11.51 

SVO.RC.L 2.27 x TDA + 6.85 SVO.SC.I 5.52 x TDA + 14.63 

VOP.RC.I 2.89 x TDA + 8.7 HZO.SC.I 2.44 x TDA + 9. 

SVO.RC.I 2.89 x TDA + 8.7 SOC.SC.I 1.76 x TDA + 0.36 

HZO.RC.I 0.72 x TDA + 8.74 HCS.SC.I 0.38 x V + 0.88 *

 TDA is the total display area of the case, as measured in the Air-Conditioning and Refrigeration Institute 

(ARI) Standard 1200-2006, Appendix D. 

** V is the volume of the case, as measured in ARI Standard 1200-2006, Appendix C. 

*** Kilowatt hours per day. 

B. Benefits to Customers of Commercial Refrigeration Equipment

Table I-2 indicates the impacts on commercial customers of today’s standards. 

Table I-2 Implications of New Standards for Commercial Consumers 

Equipment Class Energy Conservation 

Standard 

Total 

Installed 

Cost

($) 

Total 

Installed 

Cost 

Increase

($) 

Life-Cycle 

Cost 

Savings 

($) 

Payback 

Period

(years) 

VOP.RC.M 0.82 x TDA + 4.07 $8,065 $536 1,788 2.0 

 

2

 For this rulemaking, equipment class designations consist of a combination (in sequential order separated by 

periods) of: (1) an equipment family code (VOP=vertical open, SVO=semivertical open, HZO=horizontal 

open, VCT=vertical transparent doors, VCS=vertical solid doors, HCT=horizontal transparent doors, 

HCS=horizontal solid doors, or SOC=service over counter); (2) an operating mode code (RC=remote 

condensing or SC=self-contained); and ( 3) a rating temperature code (M=medium temperature (38 °F), L=low 

temperature (0 °F), or I=ice-cream temperature (-15 °F)). For example, “VOP.RC.M” refers to the “vertical 

open, remote condensing, medium temperature” equipment class. See discussion in section V.A.2 and chapter 

3 of the TSD, market and technology assessment, for a more detailed explanation of the equipment class 

terminology. See for a list Table IV-2 of the equipment classes by category. 

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VOP.RC.L 2.27 x TDA + 6.85 11,222 1,947 3,938 2.8 

VOP.SC.M 1.74 x TDA + 4.71 4,381 633 1,549 2.4 

VCT.RC.M 0.22 x TDA + 1.95 11,654 2,134 2,339 3.9 

VCT.RC.L 0.56 x TDA + 2.61 12,584 2,513 5,419 2.6 

VCT.SC.I 0.67 x TDA + 3.29 6,602 1,385 5,217 1.7 

VCS.SC.I 0.38 x V + 0.88 4,227 326 1,757 1.3 

SVO.RC.M 0.83 x TDA + 3.18 7,470 435 1,274 1.9 

SVO.SC.M 1.73 x TDA + 4.59 3,719 439 1,136 2.3 

SOC.RC.M 0.51 x TDA + 0.11 12,740 240 945 1.7 

HZO.RC.M 0.35 x TDA + 2.88 8,133 248 1,040 1.6 

HZO.RC.L 0.57 x TDA + 6.88 8,194 270 1,102 1.6 

HZO.SC.M 0.77 x TDA + 5.55 3,398 313 826 2.3 

HZO.SC.L 1.92 x TDA + 7.08 3,836 460 1,761 1.7 

HCT.SC.I 0.56 x TDA + 0.43 2,478 238 785 1.9 

The economic impacts on commercial consumers (i.e., the average life-cycle cost 

(LCC) savings) are positive for all equipment classes. For example, currently available 

remote condensing vertical open equipment operating at medium temperatures, semivertical 

equipment with those same characteristics, and vertical closed equipment with transparent 

doors and operating at low temperatures—three of the most common types of commercial 

refrigeration equipment—typically have installed prices of $8,065, $7,470 and $12,584, and 

annual energy costs of $1,879, $1,413, and $2,249, respectively. To meet the new standards, 

DOE estimates that the installed prices of such equipment will be $8,601, $7,905, and 

$15,097, respectively, an increase of $536, $435, and $2,513. This price increase will be 

offset by annual energy savings of about $331, $234, and $977. 

C. Impact on Manufacturers

Using a real corporate discount rate of 11.5 percent, DOE estimates the industry net 

present value (INPV) of the commercial refrigeration equipment industry to be $540 million 

in 2007$. DOE expects the impact of today’s standards on the industry net present value 

(INPV) of manufacturers of commercial refrigeration equipment to be a loss of 7.29 to 

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27.35 percent (-$39 million to -$148 million). Based on DOE’s interviews with 

manufacturers of commercial refrigeration equipment, DOE expects minimal plant closings 

or loss of employment as a result of the standards. 

D. National Benefits

DOE estimates the standards will save approximately 1.035 quads (quadrillion (1015) 

British thermal units (Btu)) of energy over 30 years (2012–2042). This is equivalent to all 

the energy consumed by more than 5 million American households in a single year. 

By 2042, DOE expects the energy savings from the standards to eliminate the need 

for approximately 0.7 new 1,000-megawatt (MW) power plants. These energy savings will 

result in cumulative greenhouse gas emission reductions of approximately 52.6 million tons 

(Mt) of carbon dioxide (CO2), or an amount equal to that produced by approximately 

332,500 cars every year. Additionally, the standards will help alleviate air pollution by 

resulting in between approximately 3.64 and 89.97 kilotons (kt) of cumulative nitrogen 

oxide (NOX) emission reductions and between approximately 0 and 1.38 tons of cumulative 

mercury emission reductions from 2012 through 2042. The estimated net present values of 

these emissions reductions are between $0 and $469 million for CO2, between $394,000 and 

$9.7 million for NOX, and between $0 and $284,000 for mercury at a 7-percent discount rate 

in 2007$, discounted to 2008. At a 3-percent discount rate, the estimated net present values 

of these emissions reductions are between $0 and $955 million for CO2, between $0.8 

million and $20.5 million for NOX, and between $0 and $560,000 for mercury. 

 

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The national NPV of the standards is $1.414 billion using a 7-percent discount rate 

and $3.930 billion using a 3-percent discount rate, cumulative from 2012 to 2062 in 2007$. 

This is the estimated total value of future savings minus the estimated increased equipment 

costs, discounted to 2008. 

The benefits and costs of today’s final rule can also be expressed in terms of 

annualized [2007$] values between 2012 and 2042. Using a 7-percent discount rate for the 

annualized cost analysis, the cost of the standards established in today’s final rule is $95 

million per year in increased equipment and installation costs, while the annualized benefits 

are $229 million per year in reduced equipment operating costs. Using a 3-percent discount 

rate, the cost of the standards established in today’s final rule is $81 million per year, while 

the benefits of today’s standards are $253 million per year. 

II. Introduction 

A. Authority 

Title III of EPCA sets forth a variety of provisions designed to improve energy 

efficiency. Part A of Title III (42 U.S.C. 6291–6309) provides for the Energy Conservation 

Program for Consumer Products Other than Automobiles. Part A-1 of Title III (42 U.S.C. 

6311–6317) establishes a similar program for “Certain Industrial Equipment,” including 

commercial refrigeration equipment, the subject of this rulemaking.3

 DOE publishes today’s 

final rule pursuant to Part A-1 of Title III, which provides for test procedures, labeling, and 

 

3

 This part was originally titled Part C. However, it was redesignated Part A-1 after Part B of Title III of EPCA 

was repealed by Pub. L. 109-58. 

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energy conservation standards for commercial refrigeration equipment and certain other 

equipment; and authorizes DOE to require information and reports from manufacturers. The 

test procedure for commercial refrigeration equipment appears in Title 10 Code of Federal 

Regulations (CFR) part 431.64. 

EPCA provides criteria for prescribing new or amended standards for commercial 

refrigeration equipment. As indicated above, any new or amended standard for this 

equipment must be designed to achieve the maximum improvement in energy efficiency that 

is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and 

6316(e)(1)) Additionally, EPCA provides specific prohibitions on prescribing such 

standards. DOE may not prescribe an amended or new standard for any equipment for 

which DOE has not established a test procedure. (42 U.S.C. 6295(o)(3)(A) and 6316(e)(1)) 

Further, DOE may not prescribe an amended or new standard if DOE determines by rule 

that such standard would not result in “significant conservation of energy” or “is not 

technologically feasible or economically justified.” (42 U.S.C. 6295(o)(3)(B) and 

6316(e)(1)) 

EPCA also provides that in deciding whether such a standard is economically 

justified for equipment such as commercial refrigeration equipment, DOE must, after 

receiving comments on the proposed standard, determine whether the benefits of the 

standard exceed its burdens by considering, to the greatest extent practicable, the following 

seven factors: 

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1. the economic impact of the standard on manufacturers and consumers of the products 

subject to the standard; 

2. the savings in operating costs throughout the estimated average life of products in the 

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

expenses for the covered products that are likely to result from the imposition of the 

standard; 

3. the total projected amount of energy savings likely to result directly from the imposition 

of the standard; 

4. any lessening of the utility or the performance of the products likely to result from the 

imposition of the standard; 

5. the impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard; 

6. the need for national energy conservation; and 

7. other factors the Secretary of Energy (Secretary) considers relevant. 

 (42 U.S.C. 6295(o)(2)(B)(i)-(ii) and 6316(e)(1)) 

In addition, EPCA, as amended (42 U.S.C. 6295(o)(2)(B)(iii) and 6316(e)(1)), 

establishes a rebuttable presumption that a standard for commercial refrigeration equipment 

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 (and as applicable, water) savings during the first year 

that the consumer will receive as a result of the standard,” as calculated under the test 

procedure in place for that standard. 

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EPCA further provides that the Secretary may not 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 in 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 at the time of the Secretary’s finding.” (42 U.S.C. 6295(o)(4) and 6316(e)(1)) 

Section 325(q)(1) of EPCA is applicable to promulgating standards for most types or 

classes of equipment, including commercial refrigeration equipment, that have two or more 

subcategories. (42 U.S.C. 6295(q)(1) and 42 U.S.C. 6316(e)(1)) Under this provision, DOE 

must specify a different standard level than that which applies generally to such type or 

class of equipment for any group of products “which have the same function or intended 

use, if . . . products within such group—(A) consume a different kind of energy from that 

consumed by other covered products within such type (or class); or (B) have a capacity or 

other performance-related feature which other products within such type (or class) do not 

have and such feature justifies a higher or lower standard” than applies or will apply to the 

other products. (42 U.S.C. 6295(q)(1)(A) and (B)) In determining whether a performancerelated feature justifies such a different standard for a group of products, DOE must 

consider “such factors as the utility to the consumer of such a feature” and other factors 

DOE deems appropriate. (42 U.S.C. 6295(q)(1)) Any rule prescribing such a standard must 

include an explanation of the basis on which DOE established such a higher or lower level. 

(See 42 U.S.C. 6295(q)(2)) 

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Federal energy conservation standards for commercial equipment generally 

supersede State laws or regulations concerning energy conservation testing, labeling, and 

standards. (42 U.S.C. 6297(a)–(c); 42 U.S.C. 6316(e)(2)-(3)) DOE can, however, grant 

waivers of preemption for particular State laws or regulations, in accordance with the 

procedures and other provisions of section 327(d) of the Act. (42 U.S.C. 6297(d); 42 U.S.C. 

6316(e)(2)-(3)) 

B. Background 

1. History of Standards Rulemaking for Commercial Refrigeration Equipment 

As discussed in the notice of proposed rulemaking, 73 FR 50072, 50076 (August 25, 

2008) (the August 2008 NOPR), the EPACT 2005 amendments to EPCA require that DOE 

issue energy conservation standards for the equipment covered by this rulemaking. (42 

U.S.C. 6313(c)(4)(A)) The amendments also include definitions for terms relevant to this 

equipment (42 U.S.C. 6311(9)). These definitions provide that commercial refrigeration 

equipment is connected to either a self-contained condensing unit or to a remote condensing 

unit (42 U.S.C. 6311 (9)(A)(vii)), the two condenser configurations of equipment covered 

by this rulemaking, and include definitions of a remote condensing unit and self-contained 

condensing unit (42 U.S.C. 6311 (9)(E)-(F)). 

DOE commenced this rulemaking on April 25, 2006, by publishing a notice of a 

public meeting and of the availability of its framework document for the rulemaking. 71 FR 

23876. The framework document described the approaches DOE anticipated using and 

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issues to be resolved in the rulemaking. DOE held a public meeting on May 16, 2006, to 

present the contents of the framework document, describe the analyses DOE planned to 

conduct during the rulemaking, obtain public comment on these subjects, and facilitate the 

public’s involvement in the rulemaking. DOE also allowed the submission of written 

statements, after the public meeting, in response to the framework document. 

On July 26, 2007, DOE published an advance notice of proposed rulemaking 

(ANOPR) in this proceeding. 72 FR 41161 (the July 2007 ANOPR). In the July 2007 

ANOPR, DOE sought comment on its proposed equipment classes for the rulemaking, and 

on the analytical framework, models, and tools that DOE used to analyze the impacts of 

energy conservation standards for commercial refrigeration equipment. In conjunction with 

the July 2007 ANOPR, DOE published on its website the complete ANOPR TSD, which 

included the results of DOE’s various preliminary analyses in this rulemaking. In the July 

2007 ANOPR, DOE requested oral and written comments on these results and on a range of 

other issues. DOE held a public meeting in Washington, DC, on August 23, 2007, to present 

the methodology and results of the ANOPR analyses and to receive oral comments from 

those who attended. The oral and written comments DOE received focused on DOE’s 

assumptions, approach, and equipment class breakdown, and were addressed in detail in the 

August 2008 NOPR. 

In the August 2008 NOPR, DOE proposed new energy conservation standards for 

commercial refrigeration equipment. 73 FR 50072. In conjunction with the August 2008 

NOPR, DOE also published on its website the complete technical support document (TSD) 

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for the proposed rule, which incorporated the final analyses DOE conducted and technical 

documentation for each analysis. The TSD included the engineering analysis spreadsheets, 

the LCC spreadsheet, and the national impact analysis spreadsheet. The standards DOE 

proposed for commercial refrigeration equipment are shown in Table II-1. 

Table II-1 August 2008 Proposed Standard Levels for Commercial Refrigeration 

Equipment 

Equipment Class Standard Level *,**

(kWh/day) 

Equipment 

Class 

Standard Level *,**

(kWh/day) 

VOP.RC.M 0.82 x TDA + 4.07 VCT.RC.I 0.71 x TDA + 3.05 

SVO.RC.M 0.83 x TDA + 3.18 HCT.RC.M 0.16 x TDA + 0.13 

HZO.RC.M 0.35 x TDA + 2.88 HCT.RC.L 0.34 x TDA + 0.26 

VOP.RC.L 2.28 x TDA + 6.85 HCT.RC.I 0.4 x TDA + 0.31 

HZO.RC.L 0.57 x TDA + 6.88 VCS.RC.M 0.11 x V + 0.26 

VCT.RC.M 0.25 x TDA + 1.95 VCS.RC.L 0.23 x V + 0.54 

VCT.RC.L 0.6 x TDA + 2.61 VCS.RC.I 0.27 x V + 0.63 

SOC.RC.M 0.51 x TDA + 0.11 HCS.RC.M 0.11 x V + 0.26 

VOP.SC.M 1.74 x TDA + 4.71 HCS.RC.L 0.23 x V + 0.54 

SVO.SC.M 1.73 x TDA + 4.59 HCS.RC.I 0.27 x V + 0.63 

HZO.SC.M 0.77 x TDA + 5.55 SOC.RC.L 1.08 x TDA + 0.22 

HZO.SC.L 1.92 x TDA + 7.08 SOC.RC.I 1.26 x TDA + 0.26 

VCT.SC.I 0.73 x TDA + 3.29 VOP.SC.L 4.37 x TDA + 11.82 

VCS.SC.I 0.38 x V + 0.88 VOP.SC.I 5.55 x TDA + 15.02 

HCT.SC.I 0.56 x TDA + 0.43 SVO.SC.L 4.34 x TDA + 11.51 

SVO.RC.L 2.28 x TDA + 6.85 SVO.SC.I 5.52 x TDA + 14.63 

VOP.RC.I 2.9 x TDA + 8.7 HZO.SC.I 2.44 x TDA + 9 

SVO.RC.I 2.9 x TDA + 8.7 SOC.SC.I 1.76 x TDA + 0.36 

HZO.RC.I 0.72 x TDA + 8.74 HCS.SC.I 0.38 x V + 0.88 *

 TDA is the total display area of the case, as measured in the ARI Standard 1200-2006, Appendix D. ** V is the volume of the case, as measured in ARI Standard 1200-2006, Appendix C. 

In the August 2008 NOPR, DOE identified seven issues on which is was particularly 

interested in receiving comments and views of interested parties: light-emitting diode (LED) 

price projections, base case efficiency trends, operating temperature ranges, offset factors 

for smaller equipment, extension of standards developed for the 15 primary classes to the 

remaining 23 secondary classes, standards for hybrid cases and wedges, and standard levels. 

73 FR 50134. After the publication of the August 2008 NOPR, DOE received written 

comments on these and other issues. DOE also held a public meeting in Washington, DC, on 

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September 23, 2008, to hear oral comments on and solicit information relevant to the 

proposed rule. The August 2008 NOPR included additional background information on the 

history of this rulemaking. 73 FR 50076-77. 

III. General Discussion 

A. Test Procedures 

On December 8, 2006, DOE published a final rule (the December 2006 final rule) in 

which it adopted American National Standards Institute (ANSI)/Air-Conditioning and 

Refrigeration Institute (ARI) Standard 1200-2006, “Performance Rating of Commercial 

Refrigerated Display Merchandisers and Storage Cabinets,” as the DOE test procedure for 

this equipment.4

 71 FR 71340, 71369-70; 10 CFR 431.63-431.64. ARI Standard 1200-2006 

contains rating temperature specifications of 38 °F (±2 °F) for commercial refrigerators and 

refrigerator compartments, 0 °F (±2 °F) for commercial freezers and freezer compartments, 

and -5 °F (±2 °F) for commercial ice-cream freezers. The standard also requires 

performance tests to be conducted according to the ANSI/American Society of Heating, 

Refrigerating, and Air-Conditioning Engineers (ASHRAE) Standard 72-2005, “Method of 

Testing Commercial Refrigerators and Freezers.” In the test procedure final rule, DOE also 

adopted a -15° F (±2° F) rating temperature for commercial ice-cream freezers. 71 FR 

71370. In addition, DOE adopted ANSI/Association of Home Appliance Manufacturers 

(AHAM) Standard HRF-1-2004, “Energy, Performance and Capacity of Household 

 

4

 The Air-Conditioning and Refrigeration Institute (ARI) and the Gas Appliance Manufacturers Association 

(GAMA) announced on December 17, 2007, that their members voted to approve the merger of two trade 

associations to represent the interests of cooling, heating, and commercial refrigeration equipment 

manufacturers. The merged association became AHRI on January 1, 2008. 

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Refrigerators, Refrigerator-Freezers and Freezers,” for determining compartment volumes 

for this equipment. 71 FR 71369-70. 

B. Technological Feasibility 

1. General 

As stated above, any standards that DOE establishes for commercial refrigeration 

equipment must be technologically feasible. (42 U.S.C. 6295(o)(2)(A) and (o)(3)(B); 42 

U.S.C. 6316(e)(1)) DOE considers a design option to be technologically feasible if it is in 

use by the respective industry or if research has progressed to the development of a working 

prototype. “Technologies incorporated in commercial products or in working prototypes 

will be considered technologically feasible.” 10 CFR part 430, subpart C, appendix A, 

section 4(a)(4)(i). 

This final rule considers the same design options as those evaluated in the August 

2008 NOPR. (See chapter 4 of the final rule TSD accompanying this notice.) All the 

evaluated technologies have been used (or are being used) in commercially available 

products or working prototypes. Therefore, DOE has determined that all of the efficiency 

levels evaluated in this notice are technologically feasible. 

2. Maximum Technologically Feasible Levels 

As required by EPCA, (42 U.S.C. 6295(p)(2) and 42 U.S.C. 6316(e)(1)) in 

developing the August 2008 NOPR, DOE identified the energy use levels that would 

achieve the maximum reductions in energy use that are technologically feasible (max-tech 

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levels) for commercial refrigeration equipment. 73 FR at 50077-78. (See NOPR TSD 

chapter 5.) DOE received comments indicating that LED efficacy had improved since the 

August 2008 NOPR. DOE also received comments regarding the LED lighting 

configurations assumed in the engineering analysis for various equipment types. This caused 

the max-tech levels proposed in the August 2008 NOPR to change for equipment classes 

with lighting. In general, the max-tech levels for open equipment classes decreased and the 

max-tech levels for closed cases increased from the max-tech levels proposed in the August 

2008 NOPR. For today’s final rule, the max-tech levels for all classes are the levels 

provided in Table III-1. 

Table III-1 “Max-Tech” Energy Use Levels

Equipment Class “Max-Tech” Level 

(kWh/day) Equipment Class “Max-Tech” Level (kWh/day) 

VOP.RC.M 0.74 x TDA + 4.07 VCT.RC.I 0.66 x TDA + 3.05 

SVO.RC.M 0.76 x TDA + 3.18 HCT.RC.M 0.16 x TDA + 0.13 

HZO.RC.M 0.35 x TDA + 2.88 HCT.RC.L 0.34 x TDA + 0.26 

VOP.RC.L 2.27 x TDA + 6.85 HCT.RC.I 0.4 x TDA + 0.31 

HZO.RC.L 0.57 x TDA + 6.88 VCS.RC.M 0.11 x V + 0.26 

VCT.RC.M 0.22 x TDA + 1.95 VCS.RC.L 0.23 x V + 0.54 

VCT.RC.L 0.56 x TDA + 2.61 VCS.RC.I 0.27 x V + 0.63 

SOC.RC.M 0.4 x TDA + 0.11 HCS.RC.M 0.11 x V + 0.26 

VOP.SC.M 1.65 x TDA + 4.71 HCS.RC.L 0.23 x V + 0.54 

SVO.SC.M 1.65 x TDA + 4.59 HCS.RC.I 0.27 x V + 0.63 

HZO.SC.M 0.77 x TDA + 5.55 SOC.RC.L 0.84 x TDA + 0.22 

HZO.SC.L 1.92 x TDA + 7.08 SOC.RC.I 0.99 x TDA + 0.26 

VCT.SC.I 0.67 x TDA + 3.29 VOP.SC.L 4.14 x TDA + 11.82 

VCS.SC.I 0.38 x V + 0.88 VOP.SC.I 5.26 x TDA + 15.02 

HCT.SC.I 0.56 x TDA + 0.43 SVO.SC.L 4.15 x TDA + 11.51 

SVO.RC.L 2.27 x TDA + 6.85 SVO.SC.I 5.27 x TDA + 14.63 

VOP.RC.I 2.89 x TDA + 8.7 HZO.SC.I 2.44 x TDA + 9. 

SVO.RC.I 2.89 x TDA + 8.7 SOC.SC.I 1.38 x TDA + 0.36 

HZO.RC.I 0.72 x TDA + 8.74 HCS.SC.I 0.38 x V + 0.88 

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C. Energy Savings 

DOE forecasted energy savings in its national energy savings (NES) analysis, 

through the use of an NES spreadsheet tool, as discussed in the August 2008 NOPR. 73 FR 

at 50078, 50101-04, 50121. 

One of the criteria that governs DOE’s adoption of standards for commercial 

refrigeration equipment is that the standard must result in “significant conservation of 

energy.” (42 U.S.C. 6295(o)(3)(B) and 42 U.S.C. 6316(e)(1)) While EPCA does not define 

the term “significant,” a U.S. Court of Appeals, in Natural Resources Defense Council v. 

Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985), indicated that Congress intended 

“significant” energy savings in this context to be savings that were not “genuinely trivial.” 

DOE’s estimates of the energy savings for energy conservation standards at each of the trial 

standard levels (TSLs) in today’s rule indicate that the energy savings each would achieve 

are nontrivial. Therefore, DOE considers these savings “significant” within the meaning of 

section 325 of EPCA. 

D. Economic Justification

1. Specific Criteria 

As noted earlier, EPCA provides seven factors to evaluate in determining whether an 

energy conservation standard for commercial refrigeration equipment is economically 

justified. (42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6316(e)(1)) The following sections 

discuss how DOE has addressed each of those seven factors in this rulemaking. 

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a. Economic Impact on Commercial Customers and Manufacturers 

DOE considered the economic impact of the new commercial refrigeration 

equipment standards on commercial customers and manufacturers. For customers, DOE 

measured the economic impact as the change in installed cost and life-cycle operating costs, 

i.e., the LCC. (See sections IV.E and VI.C.1.a, and chapter 8 of the TSD accompanying this 

notice.) DOE investigated the impacts on manufacturers through the manufacturer impact 

analysis (MIA). (See sections IV.I and VI.C.2, and chapter 13 of the TSD accompanying 

this notice.) The economic impact on commercial customers and manufacturers is discussed 

in detail in the August 2008 NOPR. 73 FR at 50078-79, 50095-50100, 50104-07, 50013-16, 

50117-21, 50130-31. 

b. Life-Cycle Costs 

DOE considered life-cycle costs of commercial refrigeration equipment, as discussed 

in the August 2008 NOPR. 73 FR at 50078-79, 50095-50100, 50104, 50013-16, 50117-18. 

DOE calculated the sum of the purchase price and the operating expense—discounted over 

the lifetime of the equipment—to estimate the range in LCC benefits that commercial 

consumers would expect to achieve due to the standards. 

c. Energy Savings 

Although significant conservation of energy is a separate statutory requirement for 

imposing an energy conservation standard, EPCA also requires DOE, in determining the 

economic justification of a proposed standard, to consider the total projected energy savings 

that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III) and 

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42 U.S.C. 6316(e)(1)) As in the August 2008 NOPR, 73 FR at 50078, 50101-04, 50121, for 

today’s final rule DOE used the NES spreadsheet results in its consideration of total 

projected savings that are directly attributable to the standard levels DOE considered. 

d. Lessening of Utility or Performance of Equipment 

In selecting today’s standard levels, DOE sought to avoid new standards for 

commercial refrigeration equipment that would lessen the utility or performance of that 

equipment. (42 U.S.C. 6295(o)(2)(B)(i)(IV) and 42 U.S.C. 6316(e)(1)) 73 FR at 50079, 

50088-89, 50123. 

e. Impact of Any Lessening of Competition 

DOE considers any lessening of competition that is likely to result from standards. 

Accordingly, as discussed in the August 2008 NOPR, 73 FR at 50079, 50123, DOE 

requested that the Attorney General transmit to the Secretary a written determination of the 

impact, if any, of any lessening of competition likely to result from the proposed standards, 

together with an analysis of the nature and extent of such impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii) and 42 U.S.C. 6316(e)(1)) 

To assist the Attorney General in making such a determination, DOE provided the 

Department of Justice (DOJ) with copies of the August 2008 proposed rule and the TSD for 

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review. (DOJ, No. 37 at pp. 1–2) The Attorney General’s response is discussed in section 

VI.C.5 below, and is reprinted at the end of this rule.5

f. Need of the Nation to Conserve Energy 

In considering standards for commercial refrigeration equipment, the Secretary must 

consider the need of the Nation to conserve energy. (42 U.S.C. 6295(o)(2)(B)(i)(VI) and 42 

U.S.C. 6316(e)(1)) The Secretary recognizes that energy conservation benefits the Nation in 

several important ways. The non-monetary benefits of the standards are likely to be 

reflected in improvements to the security and reliability of the Nation’s energy system. 

Today’s standards also will likely result in environmental benefits. As discussed in the 

proposed rule, DOE has considered these factors in adopting today’s standards. 73 FR at 

50074, 50079, 50108, 50123-26, 50132. 

g. Other Factors 

EPCA directs the Secretary of Energy, in determining whether a standard is 

economically justified, to consider any other factors that the Secretary deems to be relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)(VII) and 42 U.S.C. 6316(e)(1)) In adopting today’s standard, 

DOE considered the LCC impacts on the commercial refrigeration equipment of 

independent, small grocery/convenience store businesses. Compared to the impact of 

standards on the overall market for commercial refrigeration equipment, the impact of 

standards on these businesses might be disproportionate because these businesses 

 5 A notation in the form “DOJ, No. 37 at pp. 1-2” identifies a written comment that DOE has received and 

has included in the docket of this rulemaking. This particular notation refers to (1) a comment submitted by the 

Department of Justice (DOJ), (2) in document number 37 in the docket of this rulemaking, and (3) appearing 

on pages 1 and 2 of document number 37. 

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experience both higher discount rates and lack of access to national account equipment 

purchases. 73 FR at 50079, 50104, 50117-18. 

2. Rebuttable Presumption 

Section 325(o)(2)(B)(iii) of EPCA states that there is a rebuttable presumption that 

an energy conservation standard is economically justified if the additional cost to the 

consumer of a product 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. (42 U.S.C. 6295(o)(2)(B)(iii) and 42 U.S.C. 

6316(e)(1)) DOE’s LCC and payback period (PBP) analyses generate values that calculate 

the payback period for consumers of potential energy conservation standards, which 

includes, but is not limited to, the three-year payback period contemplated under the 

rebuttable presumption test discussed above. However, DOE routinely conducts a full 

economic analysis that considers the full range of impacts, including those to the consumer, 

manufacturer, Nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i) and 

42 U.S.C. 6316(e)(1). The results of this analysis serve as the basis for DOE to definitively 

evaluate the economic justification for a potential standard level (thereby supporting or 

rebutting the results of any preliminary determination of economic justification). 

IV. Methodology and Discussion of Comments on Methodology 

DOE used several analytical tools that it developed previously and adapted for use in 

this rulemaking. One is a spreadsheet that calculates LCC and PBP. Another tool calculates 

national energy savings and national NPV. DOE also used the Government Regulatory 

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Impact Model (GRIM), along with other methods, in its MIA. Finally, DOE developed an 

approach using the National Energy Modeling System (NEMS) to estimate impacts of 

energy efficiency standards for commercial refrigeration equipment on electric utilities and 

the environment. The TSD appendices discuss each of these analytical tools in detail. 73 FR 

at 50079-108. 

As a basis for this final rule, DOE has continued to use the spreadsheets and 

approaches explained in the August 2008 NOPR. DOE used the same general methodology 

as applied in the August 2008 NOPR, but revised some of the assumptions and inputs for 

the final rule in response to stakeholder comments. The following paragraphs discuss these 

revisions. 

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 equipment concerned, 

including the purpose of the equipment, the industry structure, and market characteristics. 

This activity includes both quantitative and qualitative assessments based primarily on 

publicly available information. DOE presented various subjects in the market and 

technology assessment for this rulemaking. (See the August 2008 NOPR and chapter 3 of 

the NOPR TSD.) These include equipment definitions, equipment classes, manufacturers, 

quantities and types of equipment sold and offered for sale, retail market trends, and 

regulatory and nonregulatory programs. 

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1. Definitions Related to Commercial Refrigeration Equipment 

a. Air-Curtain Angle Definition 

For equipment without doors, an air curtain divides the refrigerated compartment 

from the ambient space. DOE proposed the following definition of air-curtain angle in the 

August 2008 NOPR that is consistent with the industry-approved standards: “Air-curtain 

angle means: (1) For equipment without doors and without a discharge air grille or 

discharge air honeycomb, the angle between a vertical line extended down from the highest 

point on the manufacturer’s recommended load limit line and the load limit line itself, when 

the equipment is viewed in cross-section; and (2) For all other equipment without doors, the 

angle formed between a vertical line and the straight line drawn by connecting the point at 

the inside edge of the discharge air opening with the point at the inside edge of the return air 

opening, when the equipment is viewed in cross-section.” 73 FR 50080; 50135. DOE did 

not receive any additional comments on the definition of air-curtain angle in response to the 

August 2008 NOPR; thus, DOE is adopting these definitions as proposed. 

b. Door Angle Definition 

The door orientation affects the energy consumption of equipment with doors. This 

equipment can be broadly categorized by the angle of the door. In the August 2008 NOPR, 

DOE proposed the following definition of door angle: “(1) For equipment with flat doors, 

the angle between a vertical line and the line formed by the plane of the door, when the 

equipment is viewed in cross-section; and (2) For equipment with curved doors, the angle 

formed between a vertical line and the straight line drawn by connecting the top and bottom 

points where the display area glass joins the cabinet, when the equipment is viewed in cross46Cfinal 

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section.” 73 FR 50080; 50135. DOE did not receive any additional comments on the 

definition of door angle in response to the August 2008 NOPR; thus, DOE is adopting the 

definition as proposed. 

c. Ice-Cream Freezer Definition 

During the NOPR public meeting, interested parties expressed concern about the 

definition of an “ice-cream freezer” as used in this rulemaking. Hussman stated that using 

the term “ice cream” to refer to a temperature range might be confusing because ice cream is 

also a product. (Hussman, Public Meeting Transcript, No. 27 at p. 15)6

 Southern Store 

Fixtures expressed a similar concern, adding that other types of frozen items, such as frozen 

juice, may be displayed in ice-cream type cases. (Southern Store Fixtures, Public Meeting 

Transcript, No. 27 at p. 18) 

As described in the July 2007 ANOPR, the EPCA provision that required this 

rulemaking identifies specifically the categories “ice-cream freezers,” “self-contained 

commercial refrigerators, freezers, and refrigerator-freezers without doors,” and “remote 

condensing commercial refrigerators, freezers, and refrigerator-freezers.” (42 U.S.C. 

6313(c)(4)(A), added by EPACT 2005, section 136(c)) Because the term “ice-cream 

freezers” was specified in EPCA, the term “ice cream” is appropriate to describe that 

 

6

 A notation in the form “Hussman, Public Meeting Transcript, No. 27 at p. 15” identifies an oral comment that 

DOE received during the September 23, 2008, NOPR public meeting. This comment was recorded in the 

public meeting transcript in the docket for this rulemaking (Docket No. EE-2006-STD-0126), maintained in 

the Resource Room of the Building Technologies Program. This particular notation refers to a comment (1) 

made during the public meeting by Hussman; (2) recorded in document number 27, which is the public 

meeting transcript filed in the docket of this rulemaking; and (3) appearing on page 15 of document number 

27. 

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specific equipment category in this rulemaking, and DOE is therefore maintaining the use of 

that term in the rulemaking. Also, see section IV.A.2 of this final rule. 

d. Equipment Configuration Definitions 

The configuration of commercial refrigeration equipment affects its energy 

consumption and the equipment classes into which this equipment is divided. In the August 

2008 NOPR, DOE proposed five definitions of equipment configurations, shown in Table 

IV-1. 73 FR 50081; 50135. 

Table IV-1 Equipment Configuration Definitions 

Equipment Family Description 

Vertical Open (VOP) Equipment without doors and an air-curtain angle ≥ 0 degrees and < 10 

degrees from the vertical. 

Semivertical Open (SVO) Equipment without doors and an air-curtain angle ≥ 10 degrees and < 

80 degrees from the vertical. 

Horizontal Open (HZO) Equipment without doors and an air-curtain angle ≥ 80 degrees from the 

vertical. 

Vertical Closed (VC) Equipment with hinged or sliding doors and a door angle < 45 degrees. 

Horizontal Closed (HC) Equipment with hinged or sliding doors and a door angle ≥ 45 degrees. 

DOE did not receive any additional comments on the definitions of the five 

configurations; thus, DOE is adopting these definitions as proposed. 

e. Hybrid and Wedge Case Definitions 

As stated in the August 2008 NOPR, certain types of equipment meet the definition 

of “commercial refrigeration equipment” (Section 136(a)(3) of EPACT 2005), but do not 

fall directly into any of the 38 equipment classes defined in the market and technology 

assessment. Among these types are hybrid cases and wedge cases; DOE proposed 

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definitions for these in the August 2008 NOPR. Because DOE did not receive any additional 

comments on the definitions of “commercial hybrid refrigerators, freezers, and refrigeratorfreezers” or on the definition of “wedge case,” DOE is adopting these definitions as 

proposed in section 431.62. 

2. Equipment Classes 

Commercial refrigerators, commercial freezers, and commercial refrigerator-freezers 

can be divided into various equipment classes categorized largely by physical characteristics 

that affect energy efficiency. Some of these characteristics delineate the categories of 

equipment covered by this rulemaking.7

 Most affect the merchandise that the equipment can 

be used to display and how the customer can access that merchandise. Key physical 

characteristics that affect energy efficiency are the operating temperature, the presence or 

absence of doors (i.e., closed cases or open cases), the type of doors used (i.e., transparent or 

solid), the angle of the door or air-curtain (i.e., horizontal, semivertical, or vertical), and the 

type of condensing unit (i.e., remote or self-contained). As discussed in the August 2008 

NOPR, 73 FR 50080-83, DOE is adopting equipment classes in this rulemaking by: (1) 

dividing commercial refrigerators, commercial freezers, and commercial refrigeratorfreezers into equipment families; (2) subdividing these families based on condensing unit 

configurations and rating temperature designations; and (3) identifying the resulting classes 

that are within each of the three equipment categories covered by this rulemaking. Because 

 

7

 “Commercial refrigerators, commercial freezers, and commercial refrigerator-freezers” is a type of covered 

commercial equipment. For purposes of discussion only in this proceeding, DOE uses the term “categories” to 

designate groupings of “commercial refrigeration equipment.” The categories of equipment are: self-contained 

commercial refrigerators, commercial freezers, and commercial refrigerator-freezers without doors; remote 

condensing commercial refrigerators, commercial freezers, and commercial refrigerator-freezers; and 

commercial ice-cream freezers. DOE will analyze specific equipment classes that fall within these general 

categories and set appropriate standards. 

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DOE did not receive any comments in response to the presentation of equipment classes in 

the August 2008 NOPR, DOE is adopting the equipment classes as proposed without further 

modification. Table IV-2 presents the equipment classes covered under this rulemaking, 

organized by the three equipment categories. 

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Table IV-2 Commercial Refrigeration Equipment Classes by Category

Equipment 

Category 

Condensing Unit 

Configuration Equipment Family 

Operating 

Temperature 

(°F) 

Equipment 

Class 

Designation 

≥ 32 VOP.RC.M Vertical Open < 32 VOP.RC.L 

≥ 32 SVO.RC.M Semivertical Open < 32 SVO.RC.L 

≥ 32 HZO.RC.M Horizontal Open < 32 HZO.RC.L 

≥ 32 VCT.RC.M Vertical Closed Transparent < 32 VCT.RC.L 

≥ 32 HCT.RC.M Horizontal Closed Transparent < 32 HCT.RC.L 

≥ 32 VCS.RC.M Vertical Closed Solid < 32 VCS.RC.L 

≥ 32 HCS.RC.M Horizontal Closed Solid < 32 HCS.RC.L 

≥ 32 SOC.RC.M 

Remote 

Condensing 

Commercial 

Refrigerators, 

Commercial 

Freezers, and 

Commercial 

RefrigeratorFreezers 

Remote 

Service Over Counter < 32 SOC.RC.L 

≥ 32 VOP.SC.M Vertical Open < 32 VOP.SC.L 

≥ 32 SVO.SC.M Semivertical Open < 32 SVO.SC.L 

≥ 32 HZO.SC.M 

Self-Contained 

Commercial 

Refrigerators, 

Commercial 

Freezers, and 

Commercial 

RefrigeratorFreezers without 

Doors 

Self-Contained 

Horizontal Open < 32 HZO.SC.L 

Vertical Open VOP.RC.I 

Semivertical Open SVO.RC.I 

Horizontal Open HZO.RC.I 

Vertical Closed Transparent VCT.RC.I 

Horizontal Closed Transparent HCT.RC.I 

Vertical Closed Solid VCS.RC.I 

Horizontal Closed Solid HCS.RC.I 

Remote 

Service Over Counter SOC.RC.I 

Vertical Open VOP.SC.I 

Semivertical Open SVO.SC.I 

Horizontal Open HZO.SC.I 

Vertical Closed Transparent VCT.SC.I 

Horizontal Closed Transparent HCT.SC.I 

Vertical Closed Solid VCS.SC.I 

Horizontal Closed Solid HCS.SC.I 

Commercial IceCream Freezers 

Self-Contained 

Service Over Counter 

≤ -5* 

SOC.SC.I 

* Ice-cream freezer is defined in 10 CFR 431.62 as a commercial freezer designed to operate at or below -5 °F 

(-21 °C) and that the manufacturer designs, markets, or intends for the storing, displaying, or dispensing of ice 

cream. 

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B. Engineering Analysis 

The engineering analysis develops cost-efficiency relationships to show the 

manufacturing costs of achieving increased efficiency. As discussed in the August 2008 

NOPR, DOE used the design-option approach, involving consultation with outside experts, 

review of publicly available cost and performance information, and modeling of equipment 

cost and energy consumption. 73 FR 50083-50093. Chapter 5 of the NOPR TSD contained 

detailed discussion of the engineering analysis methodology. In response to the August 2008 

NOPR, DOE received a number of comments on the engineering analysis methodology. 

These comments, and DOE’s response, are detailed in the following paragraphs. 

1. Approach 

For the NOPR, DOE adopted a design-options approach for the engineering analysis. 

The methodology DOE used to perform the design-option analysis is described in detail in 

chapter 5 of the TSD. DOE used industry-supplied data, which were developed using an 

efficiency-level approach, to validate DOE data. DOE received no further comments on the 

design-options approach and, as a result, made no changes to this methodology for the final 

rule. 

2. Analytical Models 

a. Cost Model 

In the engineering analysis, DOE establishes the relationship between manufacturer 

production cost and energy consumption for the commercial refrigeration equipment 

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covered in this rulemaking. In determining this relationship, DOE estimated the incremental 

manufacturer production costs associated with technological changes that reduce the energy 

consumption of the baseline models (i.e., design options). 

During the NOPR public meeting, the American Council for an Energy-Efficient 

Economy (ACEEE) stated that DOE’s method of estimating manufacturer production costs 

based on a snapshot analysis of available engineering options is flawed, because historical 

data for other building technologies show that incremental costs of complying with 

standards have been much lower than DOE estimated. ACEEE attributed this to 

manufacturers redesigning their processes to meet new energy conservation standards. 

(ACEEE, Public Meeting Transcript, No. 27 at p. 28) AHRI disagreed with ACEEE and 

cited the residential central air-conditioner rulemaking as an example of where the actual 

cost of equipment was much higher than DOE estimated. (AHRI, Public Meeting 

Transcript, No. 27 at p. 29) However, ACEEE responded that this was because commodity 

prices increased dramatically for that equipment and that once this was accounted for, the 

observed price increase in baseline residential air-conditioner units was 2 percent lower than 

DOE’s estimate. (ACEEE, Public Meeting Transcript, No. 27 at p. 30) Appliance Standards 

Awareness Project (ASAP) added that a retrospective analysis would be useful for helping 

DOE evaluate its model for predicting costs. (ASAP, Public Meeting Transcript, No. 27 at 

p. 31) ACEEE also commented that DOE’s model for assessing the cost and value of energy 

conservation standards is flawed, because the model fails to account for manufacturer 

learning curves. Over time, the price of most equipment drops as more units are produced, 

regardless of the efficiency standards placed on them. Therefore, DOE’s assumption that 

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greater efficiency standards will cause equipment prices to increase is not valid. (ACEEE, 

No. 31 at p. 1) A comment submitted by representatives of ACEEE, Appliance Standards 

Awareness Project, Alliance to Save Energy, California Energy Commission, Natural 

Resources Defense Council, Northeast Energy Efficiency Partnerships, Northwest Power 

and Conservation Council, Pacific Gas and Electric Company, Sempra Energy Utilities, and 

Southern California Edison (hereafter referred to as the Joint Comment) agreed with 

ACEEE that DOE’s engineering analysis methodology should take manufacturer learning 

curves into account. (Joint Comment, No. 34 at p. 6) 

The cost-efficiency curves that DOE presented in the NOPR TSD showed 

incremental costs of implementing design option changes above the baseline. The costefficiency curves are not intended to capture future economies of scale, or other related cost 

reductions that may or may not result from increased cumulative production over time. DOE 

acknowledges that manufacturing efficiency evolves over time, but notes that earlier trends 

do not necessarily reflect future trends. DOE has insufficient data to project final minimized 

unit costs of newer technologies. DOE believes that thorough and rigorous manufacturing 

cost analysis based on actual equipment at all efficiency levels represents the most effective 

and appropriate way to estimate current and near-term incremental manufacturing costs. 

Therefore, DOE has used available information on existing design options in the costefficiency analysis. 

i. LED Price Projections 

DOE estimates the economic impacts of the proposed standards based on current 

costs of technologically feasible energy saving design options used in commercial 

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refrigeration equipment. One such technology, which has been a focal point in this 

rulemaking, is solid-state lighting (i.e., LEDs). For the ANOPR, DOE based LED lighting 

costs on a retrofit case study, but revised its assumptions for the NOPR after gathering 

information from LED chip and fixture manufacturers. These changes caused the original 

equipment manufacturer (OEM) cost (i.e., the cost to commercial refrigeration equipment 

manufacturers) of LED fixtures to increase for both open refrigeration cases and 

refrigeration cases with transparent doors. Based on these revised costs, DOE tentatively 

rejected TSL 5 (i.e., the efficiency level where LEDs were first implemented for most 

equipment classes) because it was not economically feasible. 

However, DOE conducted a sensitivity analysis for the NOPR to gauge the effect of 

expected LED price reductions. That analysis estimated NPV and LCC values for 

equipment classes if projected LED prices were used in DOE’s analysis. DOE’s Multi-Year 

Program Plan was used to estimate the reduction in LED chip price by 2012.8 The 

sensitivity analysis used an estimated reduction in LED chip price of 80 percent by 2012, 

which represented a 50-percent reduction in overall LED system cost, assuming the costs of 

the power supply and LED fixtures did not change significantly from the values used in the 

engineering analysis. DOE recognized that if these projected reductions were to be realized 

or exceeded, the economic impacts of this standard could change significantly, possibly 

making higher TSLs economically justified. Therefore, in the NOPR, DOE requested 

 

8

 U.S. Department of Energy, Solid-State Lighting Research and Development, Multi-Year Program Plan 

FY’09–FY’14. This document was prepared under the direction of a Technical Committee from the Next 

Generation Lighting Initiative Alliance (NGLIA). Information about NGLIA and its members is available at 

www.nglia.org. 

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comment on all aspects of the LED issue, specifically soliciting any information or data that 

could increase confidence in the price projections. 

 

DOE received several comments. ASAP, Natural Resources Defense Council 

(NRDC), Earthjustice, and the Joint Comment all expressed support for the use of DOE 

LED price projections. They stated that the projections are sufficiently justified and would 

be a more adequate basis for the standard than the assumption that LED prices will remain 

constant at 2007 levels. (ASAP, No. 27 at p. 100; NRDC, Public Meeting Transcript, No. 27 

at p. 105; Earthjustice, Public Meeting Transcript, No. 27 at p. 106; Joint Comment, No. 34 

at p. 2) Pacific Gas and Electric Company, Southern California Edison, and Sempra Energy 

Utilities (Southern California Gas and San Diego Gas and Electric Company) (hereafter the 

California Utilities Joint Comment) suggested that the DOE projections might be too 

conservative. (California Utilities Joint Comment, No. 41 at p. 3) ACEEE agreed, 

attributing this underestimation to the exclusion of scale-dependent factors. ACEEE stated 

that as LED production scales up, there will be greater price reductions and increased 

quality in terms of reproducibility. (ACEEE, No. 31 at p. 7 and Public Meeting Transcript, 

No. 27 at p. 111) As evidence of the validity of DOE LED cost projections, the California 

Utilities Joint Comment stated that LED prices have already dropped rapidly, rendering 

DOE analyses based on 2007 prices obsolete. It suggested that the price of LED lighting for 

use in refrigeration has already fallen by roughly 10 percent since 2007. (California Utilities 

Joint Comment, No. 41 at p. 13) The California Utilities Joint Comment also stated that 

LED prices will continue to drop after 2012, a fact that should be considered in the NPV 

analyses. (California Utilities Joint Comment, No. 41 at p. 8) 

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For today’s final rule, DOE updated the LED costs to represent the current cost of 

LEDs. DOE did not receive any data providing a greater level of confidence that LED price 

reductions would occur. However, LED costs have decreased and the costs used in the 

NOPR engineering analysis no longer represent the current cost of LEDs. While 

considerable information is available that suggests LED prices are likely to decline by at 

least as much as DOE’s sensitivity analysis assumed, DOE is not using this information as 

the basis of its analysis due to a lack of certainty about the timing and success of LED 

research and product development. See section V.A.2.a for more detail on the updated LED 

lighting assumptions. 

ii. Material Price Projections 

As discussed in the August 2008 NOPR, DOE performed a sensitivity analysis to 

explore the effects of future LED fixture prices on commercial refrigeration equipment 

prices in the engineering analysis. During the NOPR public meeting, AHRI commented that 

if DOE were to include LED price projections in the technical analyses, equivalent actions 

should be taken for other materials that also have shown recent price variability (i.e., 

refrigerants). (AHRI, Public Meeting Transcript, No. 27 at p. 102) AHRI believes 

commodity prices are likely to change significantly, which would affect equipment costs 

and change efficiency trends. AHRI cited the potential change in costs of hydrofluorocarbon 

refrigerants (HFCs) if pending legislation capping those refrigerants is passed. (AHRI, No. 

33 at p. 3) True Manufacturing Company (True) added that the industry is already using 

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cheaper, less efficient substitute materials to produce heat transfer devices in response to 

rising copper prices. (True, Public Meeting Transcript, No. 27 at p. 104) 

As stated above, DOE did not use LED price projections in the final rule due to a 

lack of certainty about the timing and extent to which the projections would be realized. 

Similarly, DOE also did not include material price projections in the final rule analysis. 

b. Energy Consumption Model 

 The energy consumption model estimates the daily energy consumption of 

commercial refrigeration equipment at various performance levels using a design-options 

approach. The model is specific to the categories of equipment covered under this 

rulemaking, but is sufficiently generalized to model the energy consumption of all covered 

equipment classes. For a given equipment class, the model estimates the daily energy 

consumption for the baseline and the energy consumption of several levels of performance 

above the baseline. The model is used to calculate each performance level separately. For 

the NOPR, DOE updated its radiation load calculations by revising its assumptions for the 

view factor and changed its calculation method for infiltration load by replacing defrost 

melt-water with infiltrated air. 73 FR 50086. No comments were received in response to 

these changes. Therefore, DOE maintained these revised calculation methodologies for the 

final rule. 

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3. Equipment Classes Analyzed 

For the final rule, DOE did not make any changes to the equipment classes directly 

analyzed in the NOPR engineering analysis. Table IV-3 shows the 15 equipment classes 

DOE directly analyzed. 

Table IV-3 Equipment Classes Directly Analyzed in the Engineering Analysis

Equipment 

Class Description 

VOP.RC.M Vertical Refrigerator without Doors with a Remote Condensing Unit, Medium Temperature 

VOP.RC.L Vertical Freezer without Doors with a Remote Condensing Unit, Low Temperature 

SVO.RC.M Semivertical Refrigerator without Doors with a Remote Condensing Unit, Medium Temperature 

HZO.RC.M Horizontal Refrigerator without Doors with a Remote Condensing Unit, Medium Temperature 

HZO.RC.L Horizontal Freezer without Doors with a Remote Condensing Unit, Low Temperature 

VCT.RC.M Vertical Refrigerator with Transparent Doors with a Remote Condensing Unit, Medium Temperature 

VCT.RC.L Vertical Freezer with Transparent Doors with a Remote Condensing Unit, Low Temperature 

SOC.RC.M Service Over Counter Refrigerator with a Remote Condensing Unit, Medium Temperature 

VOP.SC.M Vertical Refrigerator without Doors with a Self-Contained Condensing Unit, Medium Temperature 

SVO.SC.M Semivertical Refrigerator without Doors with a Self-Contained Condensing Unit, Medium 

Temperature 

HZO.SC.M Horizontal Refrigerator without Doors with a Self-Contained Condensing Unit, Medium Temperature 

HZO.SC.L Horizontal Freezer without Doors with a Self-Contained Condensing Unit, Low Temperature 

VCT.SC.I Vertical Ice-Cream Freezer with Transparent Doors with a Self-Contained Condensing Unit, IceCream Temperature 

VCS.SC.I Vertical Ice-Cream Freezer with Solid Doors with a Self-Contained Condensing Unit, Ice-Cream 

Temperature 

HCT.SC.I Horizontal Ice-Cream Freezer with Transparent Doors with a Self-Contained Condensing Unit, IceCream Temperature 

4. Wedge Cases 

In the August 2008 NOPR, DOE considered remote condensing and self-contained 

wedge cases as covered equipment.9 DOE proposed that the calculated daily energy 

consumption (CDEC) or total daily energy consumption (TDEC) be measured according to 

 

9

 If a wedge case does not include a refrigeration component and simply serves as a miter transition piece 

between two other cases, then it does not meet the definition of commercial refrigeration equipment, and is not 

covered under this rulemaking. 

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the ANSI/ASHRAE Standard 72-2005 test procedure.10 DOE also proposed that the 

maximum daily energy consumption (MDEC) for each model shall be the amount derived 

by incorporating into the standards equation for the appropriate equipment class a value for 

the TDA that is the product of: (1) the vertical height of the air curtain or glass (in a 

transparent door), and (2) the largest overall width of the case when viewed from the front. 

73 FR 50113. In the NOPR, DOE sought comment regarding appropriate standard levels for 

wedge cases, but did not receive any comments on this specific proposal. 

Hussman, Hill Phoenix, and AHRI commented that wedge cases should be excluded 

from this rulemaking because they are niche products that do not represent a significant part 

of the commercial refrigeration industry. (Hussman, No. 42 at p. 2; Hill Phoenix, No. 32 at 

p. 6; AHRI, No. 33 at p. 5) Hill Phoenix further states that most supermarkets and grocery 

stores do not use wedge cases at all, and those that do will only use a few within a store 

because they are much more expensive per linear foot than a standard case. (Hill Phoenix, 

Public Meeting Transcript, No. 27 at p. 18) Hussman further states that wedge cases use less 

than 0.5 percent of the total energy consumed by the supermarket industry and represent 

only 1.5 percent of the cases shipped. (Hussman, No. 42 at p. 2) DOE acknowledges that 

wedge cases are niche equipment and do not represent a significant market share in the 

commercial refrigeration equipment industry. However, market share is not a basis for 

 

10 In the August 2008 NOPR, the test procedure cited was ANSI/ASHRAE Standard 72-2005. However, the 

test procedure DOE adopted into section 431.64 of 10 CFR Part 431 is ARI Standard 1200-2006, which 

specifically references ANSI/ASHRAE Standard 72-2005 as the method of testing commercial refrigeration 

equipment. 71 FR 71356 DOE notes that ARI Standard 1200-2006 would give identical test results for the 

measurement of energy consumption as ANSI/ASHRAE Standard 72-2005. Therefore, for today’s final rule, 

DOE is referencing ARI Standard 1200-2006 for the measurement of CDEC and TDEC of wedge cases. 

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rejecting an equipment category from consideration in the rulemaking. Therefore, DOE 

concludes that wedge cases are covered in this rulemaking. 

Hill Phoenix and AHRI also commented that wedge cases should be excluded from 

this rulemaking because there are no test procedures in place to test wedges since ARI 

Standard 1200-2006 excludes wedges from its scope of coverage. (Hill Phoenix, No. 32 at p. 

2; AHRI, No. 33 at p. 5) As stated in the July 2007 ANOPR, EPCA directs DOE to set 

standards for commercial refrigeration equipment (i.e., the three categories of equipment 

identified above). Any equipment that meets the EPCA definition of a “commercial 

refrigerator, freezer, or refrigerator-freezer” and falls under one of these three categories 

will be covered by this rulemaking. In the December 2006 final rule, DOE incorporated by 

reference certain sections of ARI Standard 1200-2006 as the test procedure for commercial 

refrigeration equipment, but did not reference section 2.2, which provides exclusions for 

certain equipment such as wedge cases.11 The equipment excluded in this section of ARI 

Standard 1200-2006 will only be excluded from this rulemaking if they do not meet the 

EPACT 2005 definition of a “commercial refrigerator, freezer, or refrigerator-freezer.”12 72 

FR 41169 DOE believes that the EPACT 2005 definition of a “commercial refrigerator, 

 

11 ARI Standard 1200-2006 refers to wedge cases as “miter transition display merchandisers used as a corner 

section between two refrigerated display merchandisers.” 

12 “(9)(A) The term ‘commercial refrigerator, freezer, and refrigerator-freezer’ means refrigeration equipment 

that— 

(i) is not a consumer product (as defined in section 321of EPCA [42 U.S.C. 6291(1)]); 

(ii) is not designed and marketed exclusively for medical, scientific, or research purposes; 

(iii) operates at a chilled, frozen, combination chilled and frozen, or variable temperature; 

(iv) displays or stores merchandise and other perishable materials horizontally, semivertically, or vertically; 

(v) has transparent or solid doors, sliding or hinged doors, a combination of hinged, sliding, transparent, or 

solid doors, or no doors; 

(vi) is designed for pull-down temperature applications or holding temperature applications; and 

(vii) is connected to a self-contained condensing unit or to a remote condensing unit.” (42 U.S.C. 6311(9)(A)) 

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freezer, or refrigerator-freezer” is sufficiently broad that it includes wedge cases. Therefore, 

DOE has concluded that wedge cases are properly covered in this rulemaking. 

Hussman, Hill Phoenix, and AHRI also commented that wedge cases should be 

excluded from this rulemaking because they do not function effectively and cannot be tested 

as a stand-alone merchandiser since they require straight cases of the same model on either 

side. This configuration makes accurate performance testing of wedges nearly impossible 

and no specific testing guidelines for wedges exist within ANSI/ASHRAE Standard 72-

2005 or ANSI/ARI Standard 1200-6006. (Hussman, No. 42 at p. 2; Hill Phoenix, No. 32 at 

p. 6; AHRI, No. 33 at p. 5) DOE acknowledges that there is no specific guidance in the 

ANSI/ASHRAE Standard 72-2005 or ARI Standard 1200-2006 test procedures that 

addresses the proper operation of wedge cases. However, DOE believes that wedge cases 

are not significantly different from normal display cases used in between other display cases 

(i.e., cases within a display case line-up) in terms of operation and the ability to be tested. A 

wedge case and a normal case within a display case line-up both have display cases adjacent 

to them in normal operation and do not have end panels installed on their sides. DOE 

expects that wedge cases and cases within a display case line-up should be tested in the 

same manner under the test procedure. 

Hussman and Hill Phoenix also commented that wedge cases should be excluded 

from this rulemaking because the TDA for inside wedges approaches zero. Therefore, 

standards for such cases are not meaningful because the TDA in the standards equation is 

zero. (Hussman, Public Meeting Transcript, No. 27 at p. 16; Hill Phoenix, Public Meeting 

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Transcript, No. 27 at p. 19) As stated above, DOE proposed language in the August 2008 

NOPR to specifically address the TDA issue of wedge cases. DOE proposed that for remote 

condensing and self-contained wedge cases, the CDEC or TDEC shall be measured 

according to the ANSI/ASHRAE Standard 72-2005 Test Procedure. DOE also proposed that 

the MDEC for each model shall be the amount derived by incorporating into the standards 

equation for the appropriate equipment class a value for the TDA that is the product of: (1) 

the vertical height of the air curtain or glass (in a transparent door), and (2) the largest 

overall width of the case, when viewed from the front.10 73 FR 50113. (See section VI.A.1.) 

This procedure is conservative because it allows for the widest horizontal dimension of the 

display case to be used in determining TDA. That is, using this procedure, the standards for 

a wedge case would be less stringent than a normal display case, in the same equipment 

class, of equal refrigerated volume. 

If a manufacturer finds that meeting the standard for wedge cases would cause 

hardship, inequity, or unfair distribution of burdens, the manufacturer may petition OHA for 

exception relief or exemption from the standard pursuant to OHA’s authority under section 

504 of the DOE Organization Act (42 U.S.C. 7194), as implemented at subpart B of 10 CFR 

part 1003. OHA has the authority to grant such relief on a case-by-case basis if it determines 

that a manufacturer has demonstrated that meeting the standard would cause hardship, 

inequity, or unfair distribution of burdens. 

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5. Ice-Cream Freezers—Temperature Range 

In the test procedure final rule for commercial refrigeration equipment, DOE 

established the definition of ice-cream freezer as “a commercial freezer that is designed to 

operate at or below -5 °F (-21 °C) and that the manufacturer designs, markets, or intends for 

the storing, displaying, or dispensing of ice cream.” 71 FR 71369-70. DOE incorporated the 

test procedure into its regulations in 10 CFR 431.62. Under this definition, unless equipment 

is designed, marketed, or intended specifically for the storage, display or dispensing of ice 

cream, it would not be considered an ice-cream freezer. For example, multi-purpose 

commercial freezers manufactured for storing and displaying frozen foods in addition to ice 

cream and designed to operate at or below -5 °F (-21 °C) would not meet this definition. 

Thus, DOE would not treat them as commercial ice-cream freezers in this rulemaking. 

However, any commercial freezer that is specifically manufactured for storing, displaying, 

or dispensing ice cream and is designed for normal operation at or below -5 °F, would meet 

the definition. Other equipment that meet the definition include freezers designed to operate 

considerably below -5 °F and are specifically designed for ice cream storage (e.g., 

“hardening” cabinets), as well as ice-cream dipping cabinets designed to operate below -5 

°F. For the NOPR, DOE expanded the definition used to categorize a unit’s rating 

temperature by including a specific operating temperature range for medium-temperature, 

low-temperature, and ice-cream temperature applications. 

Hill Phoenix and AHRI commented on the proposed temperature ranges for lowtemperature and ice-cream temperature freezers. Hill Phoenix, in agreement with AHRI, 

stated that the operating range for low-temperature cases should be changed to less than 32 

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°F and greater than -15 °F, and the operating range for ice-cream temperature cases be 

changed to less than or equal to -15 °F. Hill Phoenix and AHRI stated that freezers that 

operate below -15 °F are constructed differently than cases that operate in the -5 °F to -10 °F 

range. Hill Phoenix stated that DOE’s current temperature range designations would require 

freezers that operate in the -5 °F to -10 °F range to be rated at -15 °F. (Hill Phoenix, No. 32 

at p. 4; AHRI, No. 33 at p. 4) 

As previously stated, ice-cream freezers are defined by the test procedure, which 

states that an ice-cream freezer is “a commercial freezer that is designed to operate at or 

below -5 °F (-21 °C) and that the manufacturer designs, markets, or intends for the storing, 

displaying, or dispensing of ice cream.” 71 FR 71369; 10 CFR 431.62. Based on the 

comments from AHRI and Hill Phoenix discussed above, DOE is modifying the operating 

temperature ranges used to define each type of equipment from the temperature ranges that 

were used in the NOPR. For today’s final rule, DOE is organizing equipment classes based 

on the three operating temperature ranges shown in Table IV-4. For today’s final rule, DOE 

will continue to classify equipment as medium temperature (refrigerators), low temperature 

(freezers), or ice-cream temperature (ice-cream freezers). Furthermore, DOE maintains the 

required rating temperatures as specified in the test procedure final rule: 38 °F (±2 °F) for 

commercial refrigerators and refrigerator compartments, 0 °F (±2 °F) for commercial 

freezers and freezer compartments, and -15 °F (±2 °F) for commercial ice-cream freezers. 

71 FR 71370. 

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Table IV-4 Rating Temperature Designations 

Operating Temperature (°F) Rating Temperature (°F) Description 

≥ 32 (M) 38 Medium temperature (refrigerators) 

< 32 (L) 0 Low temperature (freezers) 

≤ -5 (I)* -15 Ice-cream temperature (ice-cream freezers) 

* Ice-cream freezer is defined in 10 CFR 431.62 as a commercial freezer that is designed to operate at or 

below -5 °F (-21 °C) and that the manufacturer designs, markets, or intends for the storing, displaying, or 

dispensing of ice cream. 

6. Special Application Temperature Cases 

After the NOPR public meeting, DOE received comments on including “application 

temperatures” for commercial refrigeration equipment. These are rating temperatures other 

than the standard rating temperatures. Hill Phoenix stated that some refrigerated cases are 

designed for and operate at medium temperature and hold foods with temperature 

requirements that tend to range from10 °F to 20 °F. These cases are not designed to operate 

at the rating temperature of 0 °F. Hill Phoenix also stated that the cases would have to be 

redesigned to operate at the rating temperature, which would cause them to consume more 

energy. Therefore, Hill Phoenix recommended that this type of product be tested using the 

application temperature at which the product is designed to perform, but be required to meet 

the low-temperature standard. (Hill Phoenix, No. 32 at p. 4) AHRI concurred with Hill 

Phoenix, recommending that any case designed specifically to hold products at temperatures 

higher than the rating temperature specified for that class be tested at its application 

temperature and must meet the energy standards of that class. (AHRI, No. 33 at p. 5) 

However, the Joint Comment cautioned that rating specialty cases at application 

temperatures could create loopholes allowing equipment to be tested at an application 

temperature different from the temperature at which the equipment is designed to operate in 

the field. (Joint Comment, No. 34 at p. 4) 

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In the test procedure final rule for commercial refrigeration equipment, DOE 

adopted ARI Standard 1200-2006 as the DOE test procedure for commercial refrigeration 

equipment. 71 FR 71340, 71369-70; 10 CFR 431.63-431.64. ANSI/ARI Standard 1200–

2006 contains rating temperature specifications of 38 °F (±2 °F) for commercial 

refrigerators and refrigerator compartments, and 0 °F (±2 °F) for commercial freezers and 

freezer compartments. In the test procedure final rule, DOE also adopted a -15 °F (±2 °F) 

rating temperature for commercial ice-cream freezers. 71 FR 71370. 

Requiring manufacturers to test special application cases at one of the three specified 

standard rating temperatures (38 °F, 0 °F, and -15 °F) instead of at their corresponding 

application temperature could result in higher energy consumption for these cases if they 

have to be redesigned for testing at the standard rating temperature. However, DOE agrees 

with the Joint Comment that allowing such special application cases to be tested at an 

application temperature that is different from the temperature at which the equipment is 

designed to operate in the field could create loopholes. Therefore, DOE is maintaining the 

requirement that all equipment must be tested at one of the three specified standard rating 

temperatures adopted by DOE in the test procedure final rule. In the example from Hill 

Phoenix, the equipment is classified as a medium-temperature unit, but the equipment is 

designed to operate below 32 °F and above -5 °F, thus categorizing it as a low-temperature 

unit under today’s final rule. Because it is a low-temperature unit, it is required to be tested 

at 0 °F (±2 °F). 

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Any manufacturer that is unable to test such equipment at its designated rating 

temperature must request a test procedure waiver from DOE under the provisions described 

in 10 CFR 431.401. If the manufacturer believes that meeting the standard would cause 

hardship, inequity, or unfair distribution of burdens, it may petition OHA for exception 

relief from the energy conservation standard pursuant to OHA’s authority under section 504 

of the DOE Organization Act (42 U.S.C. 7194), as implemented at subpart B of 10 CFR part 

1003. However, the majority of equipment covered by this rulemaking can be tested using 

the three specified rating temperatures provided in the test procedure. 

7. Coverage of Remote Condensing Units 

In the framework document, ANOPR, and NOPR, DOE considered energy 

conservation standards that covered only the refrigerated cases of remote condensing 

commercial refrigeration equipment, and not the remote condensing unit. DOE cited 

language in EPACT 2005’s definitions for “self contained condensing unit” and “remote 

condensing unit” as a justification for this approach. DOE believes that, by definition, the 

remote condensing units that support remote condensing refrigeration equipment are not 

considered an “integral part” of the refrigeration equipment. (EPACT 2005, Section 

136(a)(3)) As a result, DOE stated in the August 2008 NOPR that remote condensing units 

would not be considered in this rulemaking. 

For the NOPR, the Joint Comment stated that the scope of this rulemaking should 

not be limited to the refrigerated cabinets or display cases of remote condensing systems. 

According to the Joint Comment, regulating the remote condensing units supporting these 

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cabinets has a significant potential to save energy because these units account for 90 percent 

of the total capacity of commercial refrigeration equipment subject to this rulemaking,. 

(Joint Comment, No. 34 at p. 7) 

As stated in the framework document and the July 2007 ANOPR, DOE does not 

believe that the remote condensing units of remote condensing refrigeration equipment 

systems are considered part of the equipment to which they are connected. EPCA defines a 

“self-contained condensing unit,” in part, as an “assembly of refrigerating components that 

is an integral part of the refrigerated equipment ...” (42 U.S.C. 6311(9)(F), added by 

EPACT 2005, section 136(a)(3)). EPCA also defines a “remote condensing unit,” in part, as 

an “assembly of refrigerating components that is remotely located from the refrigerated 

equipment ...” (42 U.S.C. 6311(9)(E), added by EPACT 2005, section 136(a)(3)) The 

EPCA definition of remote condensing unit implies that the remote condensing unit is not 

part of the refrigeration equipment because it refers to the unit and the refrigeration 

equipment as separate entities. A remote condensing unit functions as a supplement to 

remote condensing refrigeration equipment, but is not an “integral part.” Therefore, energy 

conservation standards for remote condensing commercial refrigerators, commercial 

freezers, and commercial refrigerator-freezers apply only to the refrigerated equipment (i.e., 

storage cabinets and display cases), but not to the remote condensing units. For the final 

rule, DOE maintains that the energy conservation standards set for remote condensing 

commercial refrigeration equipment only apply to display cases, not to the remote 

condensing units. 

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However, DOE has the authority to classify industrial or commercial equipment as 

covered under EPCA section 341(a) and (b), if classification is “necessary” to improve the 

efficiency of industrial equipment (which includes commercial refrigeration equipment) in 

order to conserve energy. (42 U.S.C. 6312(a) and (b)) If DOE were to add remote 

condensing units as covered equipment, DOE would undertake a separate rulemaking 

process to consider standards for these products in accordance with EPCA section 341(a) 

and (b). 

8. Regulating Secondary Cooling Applications 

In the framework document, DOE decided to exclude equipment designed for 

secondary coolant applications. DOE’s interpretation of the EPACT 2005 definitions of 

“commercial refrigerator, freezer, and refrigerator-freezer” was consistent with the ARI 

Standard 1200-2006, which explicitly excludes secondary coolant applications. Following 

the framework document, many interested parties, including ARI, Southern Company, and 

EEI, agreed with the exclusion of secondary coolant applications in this rule because of their 

insignificant presence in the market and the complexity of modifying the test procedure to 

accommodate them. ACEEE, on the other hand, commented that DOE should have a broad 

scope of coverage and should, in general, cover as much as possible in the rulemaking. 72 

FR 41171. 

After considering the framework comments, DOE decided to continue to exclude 

secondary coolant applications from this rulemaking in the July 2007 ANOPR. Following 

the ANOPR, commercial refrigeration manufacturers expressed concerns that the exclusion 

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of secondary coolant systems could provide a loophole if customers purchased these lower 

efficiency systems instead of regulated direct expansion equipment. 73 FR 50106. For the 

NOPR, the Joint Comment restated that DOE should consider secondary coolant 

applications in its analysis. (Joint Comment, No. 34 at p. 8) 

Section 340(9)(A)(vii) of EPCA (42 U.S.C. 6311((9)(A)(vii), added by EPACT 

2005, section 136(a)(3)), states that the terms commercial refrigerator, freezer, and 

refrigerator-freezer refer to equipment that is connected to a self-contained condensing unit 

or to a remote condensing unit. DOE maintains that this language excludes secondary 

coolant applications from coverage in this rulemaking because such applications are not 

directly connected to self-contained or remote condensing units. 72 FR 41171. For this 

reason, DOE is excluding secondary coolant applications from this rule. 

C. Markups to Determine Equipment Price

In the August 2008 NOPR, DOE explained how it developed the distribution 

channel markups it used. 73 FR 50093-95. DOE did not receive comments on these 

markups. However, DOE updated the distribution channel markups by including 2008 sales 

tax data, and updated the markups for commercial refrigeration equipment wholesalers 

using 2008 financial data. DOE used these markups, along with sales taxes, installation 

costs, and manufacturer selling prices (MSPs) developed in the engineering analysis, to 

arrive at the final installed equipment prices for baseline and higher efficiency commercial 

refrigeration equipment. As explained in the August 2008 NOPR, 73 FR 50093-95, DOE 

defined three distribution channels for commercial refrigeration equipment to describe how 

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the equipment passes from the manufacturer to the customer. DOE developed market shares 

by distribution channel for remote condensing and self-contained equipment. DOE retained 

the same distribution channel market shares described in the August 2008 NOPR. 

The new overall baseline and incremental markups for sales to supermarkets within 

each distribution channel are shown in Table IV-5, Table IV-6, Table IV-7, and Table IV-8. 

Chapter 6 of the TSD provides additional details on markups. 

Table IV-5 Baseline Markups by Distribution Channel Including Sales Tax for SelfContained Equipment in Supermarkets 

Wholesaler Mechanical Contractor 

(includes wholesaler) 

National Account 

(manufacturer-direct) Overall 

Distributor(s) 

Markup 1.370 2.082 1.185 1.564 

Sales Tax 1.069 1.069 1.069 1.069 

Overall Markup 1.465 2.226 1.267 1.672 

Table IV-6 Baseline Markups by Distribution Channel Including Sales Tax for Remote 

Condensing Equipment in Supermarkets 

Wholesaler Mechanical Contractor 

(includes wholesaler) 

National Account 

(manufacturer-direct) Overall 

Distributor(s) 

Markup 

1.370 2.082 1.185 1.347 

Sales Tax 1.069 1.069 1.069 1.069 

Overall Markup 1.465 2.226 1.267 1.440 

Table IV-7 Incremental Markups by Distribution Channel Including Sales Tax for 

Self-Contained Equipment in Supermarkets 

Wholesaler Mechanical Contractor 

(includes wholesaler) 

National Account 

(manufacturer-direct) Overall 

Distributor(s) 

Markup 1.114 1.370 1.057 1.186 

Sales Tax 1.069 1.069 1.069 1.069 

Overall Markup 1.191 1.465 1.130 1.268 

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Table IV-8 Incremental Markups by Distribution Channel Including Sales Tax for 

Remote Condensing Equipment in Supermarkets 

Wholesaler Mechanical Contractor 

(includes wholesaler) 

National Account 

(manufacturer-direct) Overall 

Distributor(s) 

Markup 1.114 1.370 1.057 1.112 

Sales Tax 1.069 1.069 1.069 1.069 

Overall Markup 1.191 1.465 1.130 1.189 

D. Energy Use Characterization

The energy use characterization estimates the annual energy consumption of 

commercial refrigeration equipment systems (including remote condensing units). This 

estimate is used in the subsequent LCC and PBP analyses (chapter 8 of the TSD) and NIA 

(chapter 11 of the TSD). For the August 2008 NOPR, DOE estimated the energy 

consumption of the 15 equipment classes analyzed in the engineering analysis (chapter 5 of 

the NOPR TSD) using the relevant test procedure. DOE then validated these energy 

consumption estimates with annual whole-building simulation modeling of selected 

equipment classes and efficiency levels. 73 FR 50095. For the final rule analyses, DOE used 

the same methodology to estimate the annual energy consumption of commercial 

refrigeration systems presented in the August 2008 NOPR. See chapter 7 of the TSD for 

additional detail on the energy use characterization. 

DOE assumed for the energy analysis 24-hour operation of case lighting based on 

input received during the ANOPR. The California Utilities Joint Comment stated that while 

many grocers in California may shut down case lighting for 8 hours per day, national trends 

may be closer to 24-hour operation. (California Utilities Joint Comment, No. 41 at p. 12) 

The California Utilities Joint Comment also indicated that LED lighting may be more likely 

to be controlled on and off during the operational day or dimmed based on motion sensors, 

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and that this can be done without the risk of moisture or startup problems common to 

fluorescent fixtures. They further speculated that retailers would take advantage of these 

LED characteristics through different operational scenarios. (California Utilities Joint 

Comment, No. 41 at p. 12) However, they provided no data to indicate the likelihood of a 

different LED usage profile, and did not provide costs to implement automatic or manual 

control to support this comment. While the potential for additional lighting controls exists 

and LEDs may offer additional controllability, the actual likelihood and costs of 

implementation are unknown. As a result, DOE did not change its default assumption of 24-

hour operation based on these comments. Additional detail on the energy use 

characterization can be found in chapter 7 of the TSD. 

E. Life-Cycle Cost and Payback Period Analyses

In response to the requirements of section 325(o)(2)(B)(i) of EPCA, DOE conducted 

LCC and PBP analyses to evaluate the economic impacts of possible new commercial 

refrigeration equipment standards on individual customers. DOE used the same spreadsheet 

models to evaluate the LCC and PBP as it used for the NOPR; however, DOE updated 

certain specific inputs to the models. Details of the spreadsheet model and of all the inputs 

to the LCC and PBP analyses are in TSD chapter 8. DOE conducted the LCC and PBP 

analyses using a spreadsheet model developed in Microsoft Excel for Windows 2003. 

The LCC is the total cost for a unit of commercial refrigeration equipment over the 

life of the equipment, including purchase and installation expense and operating costs 

(energy expenditures and maintenance). To compute the LCC, DOE summed the installed 

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price of the equipment and its lifetime operating costs discounted to the time of purchase. 

The PBP is the change in purchase expense due to a given energy conservation standard 

divided by the change in first-year operating cost that results from the standard. DOE 

expresses PBP in years. DOE measures the changes in LCC and in PBP associated with a 

given energy use standard level relative to a base case equipment energy use. The base case 

forecast reflects the market in the absence of mandatory energy conservation standards. 

The data inputs to the PBP calculation are the purchase expense (otherwise known as 

the total installed customer cost or first cost) and the annual operating costs for each 

selected design. The inputs to the equipment purchase expense were the equipment price 

and the installation cost, with appropriate markups. The inputs to the operating costs were 

the annual energy consumption, the electricity price, and the repair and maintenance costs. 

The PBP calculation uses the same inputs as the LCC analysis but, because it is a simple 

payback, the operating cost is for the year the standard takes effect, assumed to be 2012. For 

each efficiency level analyzed, the LCC analysis required input data for the total installed 

cost of the equipment, the operating cost, and the discount rate. 

Table IV-9 summarizes the inputs and key assumptions DOE used to calculate the 

economic impacts of various energy consumption levels on customers. Equipment price, 

installation cost, and baseline and standard design selection affect the installed cost of the 

equipment. Annual energy use, electricity costs, electricity price trends, and repair and 

maintenance costs affect the operating cost. The effective date of the standard, the discount 

rate, and the lifetime of equipment affect the calculation of the present value of annual 

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operating cost savings from a proposed standard. Table IV-9 also shows how DOE modified 

these inputs and key assumptions for the final rule, relative to the August 2008 NOPR. The 

changes in the input data and the discussion of the overall approach to the LCC analysis are 

provided in chapter 8 of the TSD. 

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Table IV-9 Summary of Inputs and Key Assumptions Used in the LCC and PBP 

Analyses 

Input NOPR Description Changes for Final Rule 

Baseline 

Manufacturer 

Selling Price 

Price charged by manufacturer to either a wholesaler or 

large customer for baseline equipment. Developed by 

using industry-supplied efficiency level data and a 

design option analysis. 

Data reflect updated 

engineering analysis. 

Standard-Level 

Manufacturer 

Selling Price 

Increases 

Incremental change in manufacturer selling price for 

equipment at each of the higher efficiency standard 

levels. Developed by using a combination of energy 

consumption level and design option analyses. 

Data reflect updated 

engineering analysis. 

Markups and Sales 

Tax 

Associated with converting the manufacturer selling 

price to a customer price (chapter 6 of TSD). 

Developed based on product distribution channels and 

sales taxes. 

Markups updated based 

on revised data on sales 

tax and wholesaler 

financial data. 

Installation Price 

Cost to the customer of installing the equipment. This 

includes labor, overhead, and any miscellaneous 

materials and parts. The total installed cost equals the 

customer equipment price plus the installation price. 

Installation cost data provided by industry comment. 

No change. 

Equipment Energy 

Consumption 

Site energy use associated with the use of commercial 

refrigeration equipment, which includes only the use of 

electricity by the equipment itself. Taken from 

engineering analysis and validated in energy use 

characterization. (chapter 7 of the TSD) 

Data reflect updated 

engineering analysis for 

each efficiency level. 

Electricity Prices 

Established average commercial electricity price 

($/kWh) from EIA data for 2007, in 2007$. DOE then 

established scaling factors for commercial refrigeration 

equipment consumers based on the 2003 Commercial 

Building Energy Consumption Survey. 

No change. 

Electricity Price 

Trends 

Used the AEO2007 reference case to forecast future 

electricity prices and extrapolated prices to 2042. Updated to AEO2008. 

Maintenance Costs 

Labor and material costs associated with maintaining 

the commercial refrigeration equipment (e.g., cleaning 

heat exchanger coils, checking refrigerant charge 

levels, lamp replacement). Estimated from data in RS 

Means Facilities Maintenance and Repair Cost Data13. 

Also considered lighting types and configurations for 

the refrigeration equipment. 

No change in 

methodology; however, 

LED fixture replacement 

costs reflect updated 

engineering analysis 

costs by equipment class. 

Repair Costs 

Labor and material costs associated with repairing or 

replacing components that have failed. Estimated based 

on replacement frequencies and costs for key 

components. 

No change in 

methodology from 

NOPR. Repair costs 

reflect estimates of 

individual component 

life and cost to replace. 

Repair costs increase 

with increasing 

component costs. 

Equipment Lifetime 

Age at which the commercial refrigeration equipment 

is retired from service. Used an average lifetime of 10 

years for large grocery and multi-line retailers and an 

average lifetime of 15 years for small grocers and 

No change. 

 

13 RS Means Company, Inc. 2006. Means Costworks 2006: Facility Maintenance & Repair Cost Data. 

Kingston, Massachusetts. 

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convenience stores. 

Discount Rate 

Computed by estimating the cost of capital for 

companies that purchase refrigeration equipment using 

business financial data from the Damodaran Online 

database. 

Updated based on data 

available in the 2008 

version of the 

Damodaran website. 

Rebound Effect A rebound effect was not taken into account in the 

LCC analysis. No change. 

The changes in the input data and the discussion of the overall approach to the LCC 

analysis are provided in chapter 8 of the TSD. 

In response to the NOPR, DOE received comments on two key issues affecting the 

LCC analysis: electricity price forecasts and lighting maintenance costs. Regarding 

electricity price forecasts, ACEEE asked DOE to confirm whether the Energy Information 

Administration (EIA) electricity price forecasts take into account well-documented 

regulatory-based changes in electricity prices and are not just based on responses to fuel cost 

forecasts. (ACEEE, Public Meeting Transcript, No. 27 at p. 82) In response, DOE notes that 

the EIA electricity price forecasts are developed through NEMS modeling and rely on a 

comprehensive series of supply- and demand-based modules integrated to capture the 

market dynamics for various energy sources, including oil, coal, and natural gas. These 

models also capture a wide range of consumption purposes, including such events as 

changes in the price and supplies of fossil fuels, developments in electricity markets, likely 

improvements in technology, and the impact of economic growth and various other 

regulatory impacts that affect market electricity prices. NEMS is regularly used to provide 

analyses to Congress and DOE. DOE believes that NEMS does attempt to capture many 

known regulatory changes. 

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The Joint Comment stated that DOE should use forecasts for electricity prices other 

than the Annual Energy Outlook (AEO), and that electricity price mitigation effects of the 

proposed standard must be documented. (Joint Comment, No. 34 at p. 6) This comment 

addresses both the LCC and NIA analyses. While DOE considers AEO2008 reference case 

forecasts in its central case fuel price scenario, DOE reviewed LCC and PBP results based 

on both the AEO2008 high price and low price electricity forecasts and discusses the 

resulting differences in the TSD. While the Joint Comment suggests that DOE consider 

other forecasts, it does not point to specific forecast sources or provide justification for the 

selection or weighting of one forecast over the other. The AEO2008 high price forecast used 

in the commercial refrigeration equipment analysis provides sufficient insight into probable 

commercial electricity price variation based on existing data and current regulatory 

schemes. 

DOE considered reporting electricity price impacts but found that the uncertainty of 

price projections, together with the fairly small impact of the standards relative to total 

electricity demand, makes these price changes highly uncertain. As a result, they should not 

be weighed heavily in the decision about the standard level. Given the current complexity of 

utility regulation in the United States (with significant variances among states), it does not 

seem appropriate to attempt to measure impacts on infrastructure costs and prices where 

there is likely to be significant overlap. 

DOE develops estimates for repair and maintenance costs for commercial 

refrigeration equipment in the LCC analysis. In the August 2008 NOPR, DOE assumed that 

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maintenance costs are constant and do not vary with time. AHRI commented that the costs 

of maintenance do not remain constant, as the cost of HFC refrigerants is expected to 

increase by 300 percent to 400 percent over the next decade. (AHRI, No. 33 at p. 6) DOE 

recognizes that refrigerant costs may increase. For remote condensing equipment, leakage 

during maintenance occurs throughout the entire refrigeration system, including store 

refrigeration piping and remote condensing units, and is expected to be approximately the 

same for all standard levels since little refrigerant is stored in the evaporator coils of remotecondensing commercial refrigeration equipment. The law also requires that any HFC 

refrigerant removed during maintenance must be captured (recovered), and in supermarkets 

it is often reused within the supermarket chain. 69 FR 11946. Any loss of refrigerant during 

maintenance is essentially the same at all standard levels analyzed, and therefore does not 

affect the results of DOE’s LCC or NPV analysis. In self-contained equipment, the 

refrigeration system is sealed and little leakage is expected to occur over the life of the 

equipment. Consequently, DOE did not revise the maintenance costs from the NOPR to 

account for future changes in refrigerant costs. 

DOE also included in the maintenance costs the cost of necessary lighting 

component replacements over the life of the commercial refrigeration equipment. DOE 

received comments on the lighting maintenance costs assumption for LED lamp fixtures. 

The California Utilities Joint Comment cited evidence from recent assessments, as well as 

the physical properties of LEDs, suggesting that 50,000 hours is likely a conservative 

estimate. Fixtures may actually be replaced less frequently than the 5.7 years assumed in the 

NOPR analysis. (California Utilities Joint Comment, No. 41 at pp. 10–11) The comment 

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noted that the LED light output degrades over time and the amount of degradation is a 

function of the junction temperature of the LED. Reducing the junction temperature can 

result in increased time to failure. 

While DOE agrees with this assessment, the brightness of a particular LED chip and 

the corresponding heat rejection and junction temperature are largely a function of power 

supplied by the LED driver circuitry. As such, manufacturers of LED fixtures can trade off 

brightness, total fixture cost, and design life for LED fixtures designed for commercial 

refrigeration equipment applications. The LED manufacturer equipment specification sheets 

that DOE examined for the final rule provide for a 50,000-hour life for the known 

commercial refrigeration equipment applications. Due to the recent availability of LED 

fixtures for use with commercial refrigeration equipment, there are few instances of installed 

LED light fixtures in this equipment exceeding the 50,000-hour specification. Therefore, 

DOE did not modify its LED fixture replacement cycle assumptions beyond the 

manufacturers’ estimated life. 

 DOE also received comments on using a rebuttable presumption payback period to 

establish the economic justification of an energy conservation standard level. Earthjustice 

commented that DOE does not provide any rationale for why it did not use or does not plan 

to use the rebuttable presumption payback period analysis to set the trial standard level for 

these products. Earthjustice stated that Congress specifically provided that once the 

rebuttable presumption payback period is satisfied for a trial standard level, no further 

economic justification would be necessary for DOE’s selection of that TSL as the final 

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standard. (Earthjustice, Public Meeting Transcript, No. 27 at p. 88) The Joint Comment also 

stated that DOE should give greater consideration to the rebuttable presumption payback 

period when selecting an appropriate standard level, reflecting the intent of Congress in 42 

USC section 6295(o)(2)(B)(iii) that the highest standard level with a 3-year payback 

constitutes the presumptive lowest standard level that DOE must adopt. (Joint Comment, 

No. 34 at pp. 3–4) 

DOE does consider both the rebuttable presumption payback criteria, as well as a 

full analysis including all seven relevant statutory criteria under 42 U.S.C. 6295(o)(2)(B)(i), 

when examining potential standard levels. DOE believes that the commenters may be 

misinterpreting the statutory provision in question. Earthjustice presents one possible 

reading of an ambiguous provision (i.e., that DOE need not look beyond the results of the 

rebuttable presumption inquiry), but DOE believes that such an approach is neither required 

nor appropriate, because it could ask the agency to ignore other relevant information that 

would affect the selection of the most stringent standard level that meets all applicable 

statutory criteria. The commenter’s interpretation would essentially restrict DOE from being 

able to rebut the findings of the preliminary presumptive analysis. However, the statute 

contains no such restriction, and such an approach would hinder DOE’s efforts to base its 

regulations on the best available information. 

Similarly, DOE believes that the Joint Comment misreads the statute in calling for a 

level that meets the rebuttable presumption test to serve as a minimum level when setting 

the final energy conservation standard. To do so would not only eliminate the “rebuttable” 

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aspect of the presumption but would also lock in place a level that may not be economically 

justified based on the full complement of statutory criteria. DOE is already obligated under 

EPCA to select the most stringent standard level that meets the applicable statutory criteria, 

so there is no need to tie the same requirement to the rebuttable presumption. 

DOE also received a comment supporting its selection of commercial refrigeration 

equipment lifetimes. For the NOPR, DOE determined the lifetime of commercial 

refrigeration equipment by consulting industry experts, other interested parties, and 

literature on equipment lifetimes. The Joint Comment stated that DOE’s assumptions in the 

NOPR regarding product life are reasonable. (Joint Comment, No. 34 at p. 2) Therefore, 

DOE has maintained the NOPR assumptions regarding product life for the final rule. 

F. Shipments Analysis

The shipments analysis develops future shipments for each class of commercial 

refrigeration equipment based on current shipments and equipment life assumptions, and 

takes into account the existing stock and expected growth of buildings using commercial 

refrigeration equipment. DOE received no comments on the shipments analysis or the 

resulting shipments during the NOPR. Therefore, DOE used the same shipments model for 

the final rule analysis as the NOPR. 

G. National Impact Analysis

The national impact analysis (NIA) assesses future NES and the national economic 

impacts of different efficiency levels. The analysis measures economic impacts using the 

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NPV metric (i.e., future amounts discounted to the present) of total commercial customer 

costs, and savings expected to result from new standards at specific efficiency levels. For 

the final rule analysis, DOE used the same spreadsheet model used in the NOPR to calculate 

the energy savings and the national economic costs and savings from new standards, but 

with updates to specific input data. Unlike the LCC analysis, the NES spreadsheet does not 

use distributions for inputs or outputs. DOE examined sensitivities by applying different 

scenarios. DOE used the NES spreadsheet to perform calculations of national energy 

savings and NPV using the annual energy consumption and total installed cost data from the 

LCC analysis and estimates of national shipments for each of the 15 primary commercial 

refrigeration equipment classes. DOE forecasted the energy savings from each TSL from 

2012 through 2042. DOE forecasted the energy cost savings, equipment costs, and NPV of 

benefits for all primary commercial refrigeration equipment classes from 2012 through 

2062. The forecasts provided annual and cumulative values for all four output parameters. 

DOE calculated the NES by subtracting energy use under a standards scenario from 

energy use in a base case (no new standards) scenario. Energy use is reduced when a unit of 

commercial refrigeration equipment in the base case efficiency distribution is replaced by a 

more efficient piece of equipment. Energy savings for each equipment class are the same 

national average values as calculated in the LCC and payback period spreadsheet. However, 

these results are normalized on a per-unit-length basis by equipment class and applied to the 

total annual estimated shipments in terms of line-up length of all equipment with the class. 

Table IV-10 summarizes key inputs to the NIA analysis and the changes DOE made in the 

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analysis for the final rule. Chapter 11 of the TSD provides additional information about the 

NIA spreadsheet. 

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Table IV-10 Summary of National Energy Savings and Net Present Value Inputs 

Input Data Description of NOPR Analysis Changes for Final Rule 

Shipments 

Annual shipments from shipments model for 15 

equipment classes. Shipments model based on 

projected growth in building stock using 

commercial refrigeration equipment (new stock) 

and annual replacements to stock based on an 

equipment life. Equipment lifetime distribution 

based on a 10-year average life in large grocery 

and multi-line retail, and a 15-year average life 

in small grocery and convenience stores (chapter 

10, Shipments Analysis). 

No change. 

Effective Date of 

Standard 

2012 No change. 

Base Case 

Efficiencies 

Distribution of base case shipments by 

efficiency level. 

No change in methodology to 

derive base case shipments by 

efficiency level. 

Standards Case 

Efficiencies

Distribution of shipments by efficiency level for 

each base case and each standards case. Annual 

market shares by efficiency level remain 

constant over time for the base case and each 

standards case. 

No change in methodology to 

derive shipments by efficiency 

level in each standards case. 

Annual Energy 

Consumption per 

Linear Foot 

Annual weighted-average values are a function 

of energy consumption level, which are 

established in the engineering analysis (chapter 

5 of the TSD). Converted to a per linear foot 

basis. 

No change in methodology. 

Energy consumption estimates 

reflect the updated final rule 

engineering analysis. 

Total Installed Cost 

per Linear Foot 

Annual weighted-average values are a function 

of energy consumption level (chapter 8 of the 

TSD). Converted to a per linear foot basis. 

No change in methodology. 

Installed costs reflect the updated 

final rule LCC. 

Repair Cost per 

Linear Foot 

Annual weighted-average values are constant in 

real dollar terms for each energy consumption 

level (chapter 8 of the TSD). Converted to a per 

linear foot basis. 

No change in methodology. 

Repair costs reflect the updated 

final rule LCC values. 

Maintenance Cost 

per Linear Foot 

Annual weighted-average value equals $160 in 

2007$ (chapter 8 of the TSD), plus lighting 

maintenance cost. Converted to a per linear foot 

basis. 

No change. 

Escalation of 

Electricity Prices 

EIA AEO2007 forecasts (to 2030) and 

extrapolation for beyond 2030 (chapter 8 of the 

TSD). 

EIA AEO2008 forecasts (to 2030) 

and extrapolation for beyond 

2030 (chapter 8 of the TSD). 

Electricity Site-toSource Conversion 

Conversion varies yearly and is generated by 

DOE/EIA’s NEMS program (a time series 

conversion factor; includes electric generation, 

transmission, and distribution losses) based on 

AEO2007. 

Conversion factor varies yearly 

and is generated by EIA’s NEMS 

model. Includes the impact of 

electric generation, transmission, 

and distribution losses based on 

AEO2008. 

Discount Rate 3 and 7 percent real. No change. 

Present Year Future costs are discounted to 2008. No change 

Rebound Effect 

A rebound effect (due to changes in shipments 

resulting from standards) was not considered in 

the NIA. 

No change. 

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The modifications DOE made to the NES and NIA analyses for the final rule 

primarily reflect updates to the same data sources used in the NOPR, but not changes in 

methodology. In addition, the underlying input data on equipment costs and energy savings 

by TSL are based on the LCC analysis results as revised in the final rule. 

For the final rule, DOE developed marginal site-source conversion factors that relate 

the national electrical energy savings at the point of use to the fuel savings at the power 

plant. These factors use the NEMS model and the examination of the corresponding energy 

savings from standards scenarios considered in DOE’s utility analysis (chapter 14 of the 

TSD). The conversion factors vary over time, due to projected changes in electricity 

generation sources (i.e., the power plant types projected to provide electricity to the country) 

and power plant dispatch scenarios. DOE revised the stream of conversion factors based on 

the final rule utility impacts analysis and using a version of NEMS consistent with 

AEO2008. DOE also updated the electricity price forecasts used in the NIA to reflect 

forecasts found in AEO2008 compared to AEO2007. 

DOE did not receive information to support revising the shipments analysis or the 

methodology used in the NIA to estimate future shipments by efficiency level. DOE 

requested input on this methodology or on additional data to estimate future shipments. True 

commented that because so many different features and options can degrade a product’s 

efficiency, True cannot afford to test every permutation’s efficiency. Traditionally, 

therefore, True tests the most severe case, which includes all the options, and makes sure it 

can exceed the standard. As a result, the units shipped out are often more efficient than the 

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testing would indicate. (True, Public Meeting Transcript, No. 27 at p. 119) DOE 

acknowledges this comment, but did not receive sufficient detail to address this concern in 

the final rule analysis for individual commercial refrigeration equipment classes. Because 

the distribution of efficiencies of all TSLs as well as the baseline would be similarly 

affected by some customers removing specific energy consuming options (e.g., shelf 

lighting) from their purchased products, the impact of this particular issue on the potential 

national energy savings of one TSL over another may be insignificant. 

To discount future impacts, DOE used discount rates of both 7 percent and 3 percent, 

in accordance with the Office of Management and Budget (OMB)’s guidelines (OMB 

Circular A-4, section E, Regulatory Analysis (September 17, 2003)). ASAP commented that 

DOE leans too heavily on the 7-percent discount rate, and that OMB has DOE looking at 

both the 3-percent and 7-percent discount rates. ASAP stated that DOE should be giving 

primacy to the lower discount rate, which is the societal discount rate—the time value of the 

society as a whole. (ASAP, Public Meeting Transcript, No. 27 at pp. 20–21 and p. 128) 

PG&E stated that a 3-percent discount rate is used for the California Energy Commission 

workshops on efficiency, and that it supports the 3-percent rate for the Federal rulemaking. 

(PG&E, Public Meeting Transcript, No. 27 at p. 131) The Joint Comment stated that DOE 

improperly weighs the 7-percent discount rate more than the 3-percent discount rate. The 

Joint Comment noted that DOE should use the 3-percent discount rate because it is the 

required social discount rate and because the actual weighted average cost of capital is lower 

than 7 percent. (Joint Comment, No. 34 at p. 6) 

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DOE reports and uses both 3-percent and 7-percent discount rates in its analysis of 

net present value. OMB’s guidance to Federal agencies for developing regulatory analysis 

(OMB Circular A-4, September 17, 2003)14 references OMB Circular A-9415 for the 

development of discount rates for regulatory analysis. OMB Circular A-94 states that, as a 

default position, constant-dollar benefit-cost analyses of proposed investments and 

regulations should report net present value and other outcomes determined using a real 

discount rate of 3 percent. The 7-percent rate is an estimate of the average before-tax rate of 

return to private capital in the U.S. economy. It is a broad measure that reflects the returns to 

real estate and small business capital as well as corporate capital. It approximates the 

opportunity cost of capital, and it is the appropriate discount rate whenever the main effect 

of a regulation is to displace or alter the use of capital in the private sector. OMB A-94 

states that regulatory analyses should show the sensitivity of the discounted net present 

value and other outcomes to variations in the discount rate. The importance of these 

alternative calculations will depend on the specific economic characteristics of the program 

under analysis. OMB A-4 notes that the effects of regulation do not always fall exclusively 

or primarily on the allocation of capital. When regulation primarily and directly affects 

private consumption (e.g., through higher consumer prices for goods and services), a lower 

discount rate is appropriate. The alternative most often used is sometimes called the social 

rate of time preference, or the rate at which society discounts future consumption flows to 

their present value. To represent these cases, OMB recommends using the rate the average 

saver uses to discount future consumption as the measure of the social rate of time 

preference, approximating this with the real rate of return on long-term Government debt 

 

14 www.whitehouse.gov/omb/circulars/a004/a-4.pdf. 15 www.whitehouse.gov/omb/circulars/a094/a094.html. 

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(e.g., the yield on Treasury notes minus the 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. For the 

commercial refrigeration equipment rulemaking in particular, DOE notes that the purchasers 

of commercial refrigeration equipment are indeed commercial businesses and not “savers.” 

Regarding the comment that the average cost of capital calculated for businesses purchasing 

commercial refrigeration equipment was less than 7 percent, DOE notes that the average 

cost of capital calculated for the LCC analysis is the after-tax cost of capital. OMB A-4 

specifically notes that pre-tax rates of return better measure society’s gains from investment. 

This is because corporate capital, in particular, pays an additional layer of taxation: the 

corporate income tax. This tax requires corporate capital to earn a higher pre-tax rate of 

return in order to provide investors with similar after-tax rates of return compared with noncorporate investments. Based on the guidance provided in OMB A-4, DOE considers both 

3-percent and 7-percent discount rates in the NIA analysis. 

ASAP stated that discount rates should not be applied to quads because a discount 

rate is a financial instrument and a quad is a physical quantity. (ASAP, Public Meeting 

Transcript, No. 27 at p. 22) DOE understands ASAP’s concern about discounting of 

physical quantities. Unlike economic factors that are discounted into the future, physical 

quantities are not discounted because they do not change over time. DOE reports the 

undiscounted energy savings in Table VI-31 of today’s final rule. 

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H. Life-Cycle Cost Sub-Group Analysis

In analyzing the potential impact of new or amended standards on commercial 

customers, DOE evaluates the impact on identifiable groups (i.e., sub-groups) of customers, 

such as different types of businesses that may be disproportionately affected by a National 

standard level. For this rulemaking, DOE identified independent small grocery and 

convenience stores as a commercial refrigeration equipment customer sub-group that could 

be disproportionately affected, and examined the impact of proposed standards on this 

group. DOE determined the impact on this commercial refrigeration equipment customer 

sub-group using the LCC spreadsheet model. DOE conducted the LCC and PBP analyses 

for commercial refrigeration equipment customers represented by the subgroup. DOE did 

not receive comments on its identification of this class of users as the key sub-group or on 

the assumptions applied to those sub-groups. DOE relied on the same methodology outlined 

in the NOPR for the final rule analysis. The results of DOE’s LCC sub-group analysis are 

summarized in section VI.C.2.e and described in detail in chapter 12 of the TSD. 

I. Manufacturer Impact Analysis

 DOE performed a manufacturer impact analysis (MIA) to estimate the financial 

impact of energy conservation standards on manufacturers of commercial refrigeration 

equipment, and to assess the impact of such standards on employment and manufacturing 

capacity. DOE conducted the MIA for commercial refrigeration equipment in three phases. 

Phase 1, Industry Profile, consisted of preparing an industry characterization, including data 

on market share, sales volumes and trends, pricing, employment, and financial structure. 

Phase 2, Industry Cash Flow Analysis, focused on the industry as a whole. In this phase, 

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DOE used the GRIM to prepare an industry cash-flow analysis. Using publicly available 

information developed in Phase 1, DOE adapted the GRIM's generic structure to perform an 

analysis of commercial refrigeration equipment energy conservation standards. In Phase 3, 

Sub-Group Impact Analysis, DOE conducted interviews with manufacturers representing 

the majority of domestic commercial refrigeration equipment sales. This group included 

large and small manufacturers, providing a representative cross-section of the industry. 

During these interviews, DOE discussed engineering, manufacturing, procurement, and 

financial topics specific to each company and obtained each manufacturer's view of the 

industry. The interviews provided valuable information DOE used to evaluate the impacts of 

an energy conservation standard on manufacturer cash flows, manufacturing capacities, and 

employment levels. 

 The GRIM inputs consist of the commercial refrigeration industry’s cost structure, 

shipments, and revenues. This includes information from many of the analyses described 

above, such as manufacturing costs and selling prices from the engineering analysis and 

shipments forecasts from the NES. 

 The GRIM uses the manufacturer production costs in the engineering analysis to 

calculate the MSPs for each equipment class at each TSL. By multiplying the production 

costs by different sets of markups, DOE derives the MSPs used to calculate industry 

revenues. Following the NOPR, DOE revised its engineering cost curves to derive new 

manufacturer production costs. DOE used these updated production costs in the GRIM for 

the final rule. 

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 The GRIM estimates manufacturer revenues based on total-unit-shipment forecasts 

and the distribution of these shipments by efficiency. Changes in the efficiency mix at each 

standard level are a key driver of manufacturer finances. For the final rule analysis, DOE 

used the total shipments and efficiency distribution found in the final rule NES. For 

additional detail on the manufacturer impact analysis, refer to chapter 13 of the TSD. 

J. Utility Impact Analysis

The utility impact analysis estimates the effects of reduced energy consumption due 

to improved equipment efficiency on the utility industry. This analysis compares forecast 

results for a case comparable to the AEO2008 reference case and forecast results for policy 

cases incorporating each of the commercial refrigeration equipment TSLs. 

DOE analyzed the effects of proposed standards on electric utility industry 

generation capacity and fuel consumption using a variant of EIA's NEMS. EIA uses NEMS 

to produce its AEO, a widely recognized baseline energy forecast for the United States. 

DOE used a variant known as NEMS-BT. The NEMS-BT is run similarly to the AEO2008

NEMS, except that commercial refrigeration equipment energy usage is reduced by the 

amount of energy (by fuel type) saved due to the TSLs. DOE obtained the inputs of national 

energy savings from the NES spreadsheet model. In response to the August 2008 NOPR, 

DOE did not receive comments directly on the methodology used for the utility impact 

analysis. DOE revised the final rule inputs to use the NEMS-BT consistent with the 

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AEO2008 and to use the NES impacts developed in the commercial refrigeration equipment 

final rule analysis. 

In the utility impact analysis, DOE reported the changes in installed capacity and 

generation by fuel type that result for each TSL, as well as changes in end-use electricity 

sales. Chapter 14 of the TSD provides details of the utility analysis methods and results. 

K. Employment Impact Analysis

DOE considers direct and indirect employment impacts when developing a standard. 

In this case, direct employment impacts are any changes in the number of employees for, 

commercial refrigeration equipment manufacturers, their suppliers, and related service 

firms. Indirect impacts are those changes in employment in the larger economy that occur 

due to the shift in expenditures and capital investment caused by the purchase and operation 

of more efficient commercial refrigeration equipment. In this rulemaking, the MIA 

addresses direct impacts (chapter 13 of the TSD), and the employment impact analysis 

addresses indirect impacts (chapter 15 of the TSD).. 

Indirect employment impacts from commercial refrigeration equipment standards 

consist of the net jobs created or eliminated in the national economy, other than in the 

manufacturing sector being regulated, as a consequence of: (1) reduced spending by end 

users on electricity (offset to some degree by the increased spending on maintenance and 

repair), (2) reduced spending on new energy supply by the utility industry, (3) increased 

spending on the purchase price of new commercial refrigeration equipment, and (4) the 

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effects of those three factors throughout the economy. DOE expects the net monetary 

savings from standards to be redirected to other forms of economic activity. DOE also 

expects these shifts in spending and economic activity to affect the demand for labor. 

DOE used the same methodology described in the August 2008 NOPR to estimate 

indirect national employment impacts using an input/output model of the U.S. economy, 

called ImSET (Impact of Sector Energy Technologies), which was developed by DOE’s 

Building Technologies Program. 73 FR 50072, 50107-108. 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 economic sectors. DOE estimated changes 

in expenditures using the NES spreadsheet. ImSET then estimated the net national indirect 

employment impacts of potential commercial refrigeration equipment efficiency standards 

on employment by sector. 

In response to the August 2008 NOPR, DOE received several comments on the 

employment impact analysis. ASAP commented that the discussion of the employment 

benefits resulting from the net increase in jobs follows a pattern of DOE trivializing these 

benefits in the rulemakings by stating that they are so small that they would be 

imperceptible in national labor statistics and might be offset by other unanticipated effects 

on employment. ASAP stated that it is important that DOE keep performing the 

employment analysis given the cumulative impact of possible DOE rulemakings over the 

next 4 years. (ASAP, Public Meeting Transcript, No. 27 at p. 161) 

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The Joint Comment also stated that TSL 5 would create more jobs than TSL 4, and 

that DOE cannot reject the difference as statistically insignificant because it must consider 

the combined effect of all rulemakings. (Joint Comment, No. 34 at p. 5) The Joint Comment 

further stated that DOE should consider indirect job creation as a serious factor weighing in 

favor of stronger standards. (Joint Comment, No. 34 at p. 5) 

Earthjustice noted that both indirect and direct employment benefits are shown to 

provide positive employment in the respective employment and MIA analyses and that DOE 

should consider this in the final rule. (Earthjustice, Public Meeting Transcript, No. 27 at p. 

166) 

DOE considers the employment impacts without quantifying the net economic value 

of such impacts. DOE agrees that the indirect employment analysis indicates that new 

energy conservation standards for commercial refrigeration equipment could increase the 

demand for labor in the economy and result in additional employment, a net benefit to 

society that DOE considers in establishing standards for commercial refrigeration 

equipment. Chapter 15 of the TSD describes and provides results for the employment 

impact analysis. 

L. Environmental Assessment 

DOE has prepared an environmental assessment (EA) pursuant to the National 

Environmental Policy Act and the requirements under 42 U.S.C. 6295(o)(2)(B)(i)(VI) and 

6316(a) to determine the environmental impacts of the standards being established in 

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today’s final rule. Specifically, DOE estimated the reduction in total emissions of CO2 using 

the NEMS–BT computer model. DOE calculated a range of estimates for reduction in NOX

emissions and mercury (Hg) emissions using current power sector emission rates. However, 

the EA does not include the estimated reduction in power sector impacts of sulfur dioxide 

(SO2), because DOE has determined that any such reduction resulting from an energy 

conservation standard would not affect the overall level of SO2 emissions in the United 

States due to the presence of national caps on SO2 emissions as addressed below (see 

chapter 16 of the TSD). 

The NEMS–BT is run similarly to the AEO2008 NEMS, except the energy use is 

reduced by the amount of energy saved due to the TSLs. DOE obtained the inputs of 

national energy savings from the NIA spreadsheet model. For the EA, the output is the 

forecasted physical emissions. The net benefit of the standard is the difference between 

emissions estimated by NEMS–BT and the AEO2008 reference case. The NEMS–BT tracks 

CO2 emissions using a detailed module that provides results with a broad coverage of all 

sectors and inclusion of interactive effects. 

The Clean Air Act Amendments of 1990 set an emissions cap on SO2 for all power 

generation. Attaining this target, however, is flexible among generators and is enforced 

through emissions allowances and tradable permits. Because SO2 emissions allowances 

have value, generators will almost certainly use them, although not necessarily immediately 

or in the same year with and without a standard in place. In other words, with or without a 

standard, total cumulative SO2 emissions will always be at or near the ceiling, while there 

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may be some timing differences between yearly forecasts. Thus, it is unlikely that there will 

be an SO2 environmental benefit from electricity savings as long as there is enforcement of 

the emissions ceilings. 

Although there may not be an actual reduction in SO2 emissions from electricity 

savings, there still may be an economic benefit from reduced demand for SO2 emission 

allowances. Electricity savings decrease the generation of SO2 emissions from power 

production, which can decrease the need to purchase or generate SO2 emissions allowance 

credits, and decrease the costs of complying with regulatory caps on emissions. 

Like SO2, future emissions of NOX and Hg would have been subject to emissions 

caps under the Clean Air Interstate Act (CAIR) and Clean Air Mercury Rule (CAMR). 

However, as discussed in section VI.C.6, a Federal court has vacated these rules. The 

NEMS–BT model used for today’s final rule assumed that both NOX and Hg emissions 

would be subject to CAIR and CAMR emissions caps. In the case of NOX emissions, CAIR 

would have permanently capped emissions in 28 eastern states and the District of Columbia. 

Because the NEMS–BT modeling assumed NOX emissions would be subject to CAIR, DOE 

established a range of NOX reductions based on the use of a NOX low and high emissions 

rates (in kt of NOX emitted per terawatt-hours (TWh) of electricity generated) derived from 

the AEO2008. To estimate the reduction in NOX emissions, DOE multiplied these emission 

rates by the reduction in electricity generation due to the standards considered. However, 

because the emissions caps specified by CAMR would have applied to the entire country, 

DOE was unable to use NEMS–BT model to estimate the physical quantity changes in 

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mercury emissions due to energy conservation standards. To estimate mercury emission 

reductions due to standards, DOE used an Hg emission rate (in metric tons of Hg per energy 

produced) based on AEO2008. Because virtually all mercury emitted from electricity 

generation is from coal-fired power plants, DOE based the emission rate on the metric tons 

of mercury emitted per TWh of coal-generated electricity. To estimate the reduction in 

mercury emissions, DOE multiplied the emission rate by the reduction in coal-generated 

electricity associated with standards considered. 

In comments on the August 2008 NOPR, ASAP stated that it was important for DOE 

to consider the economic impact calculations for carbon, noting that the economic savings 

are significant. In addition, until the CRE and packaged terminal air conditioner and heat 

pump (PTAC and PTHP) NOPRs, ASAP did not see that economic values for carbon 

emissions savings were factored into the analysis in a way that could affect decision 

making. (ASAP, Public Meeting Transcript, No. 27 at p. 172) On the other hand, AHRI 

believes DOE has no statutory obligation to monetize CO2 benefits. (AHRI, Public Meeting 

Transcript, No. 27 at p. 173) 

AHRI further commented that if DOE decides to monetize CO2 benefits, then it 

should account for CO2 emissions that will result from manufacturing more efficient 

products. For example, DOE should consider the CO2 emissions resulting from additional 

copper to be mined and incorporated into the finished product. (AHRI, Public Meeting 

Transcript, No. 27 at p. 173) True also commented on types of manufacturing processes that 

should be considered in the emissions analysis. True stated that the most significant impact 

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of commercial refrigeration equipment on the environment is from welding agents and 

refrigerants. True further explained with the global warming potentials (GWPs) of some of 

these substances at 1,300, 1,500, and 3,800, the impacts are astronomically greater than 

other impacts the industry faces. (True, Public Meeting Transcript, No. 27 at p. 174) 

On the contrary, ASAP emphasized that the congressional deadline of December 31, 

2008, means that “paralysis by analysis” is not an option at this point in this rulemaking and 

that it is incumbent upon AHRI to demonstrate that any proposed analysis changes would be 

significant. (ASAP, Public Meeting Transcript, No. 27 at p. 173) ACEEE commented that 

for buildings and the equipment used in them (not specific for this class of equipment), the 

energy use during the operating life is roughly 85 percent of the total lifecycle energy. Also, 

the incremental energy change from increased use of a largely recycled metals stock is 

likely have a small impact on this analysis. (ACEEE, Public Meeting Transcript, No. 27 at 

p. 173) 

 Several interested parties provided comments on the economic value of CO2 used in 

DOE’s monetization of carbon emissions for the August 2008 NOPR and the final rule for 

PTACs and PTHPs (73 FR 58772, October 7, 2008). ASAP stated that the low range for 

monetization of carbon emission reductions should not be zero. (ASAP, Public Meeting 

Transcript, No. 27 at p. 23) AHRI stated that DOE should not speculate on the value of CO2

emissions because it has no statutory obligation to do so and that any value DOE used 

would be an estimate. There is no consensus on any single estimate of the value of CO2

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emissions. Therefore, DOE should not indulge in speculation to determine a value when it 

has no statutory obligation to do so. (AHRI, No. 33 at p. 6) 

 Earthjustice commented that the upper and lower bounds of the values DOE uses for 

its carbon emissions are arbitrarily low. (Earthjustice, No. 38 at pp. 7–14) Specifically, 

Earthjustice stated that by using the value of the social cost of carbon (SCC) estimated in 

Dr. Richard Tol’s 2005 meta-analysis, DOE excluded critical damages and made optimistic 

assumptions that bias the damage cost downwards. (Earthjustice, No. 38 at p. 8) Earthjustice 

noted that Tol released an update of his 2005 meta-analysis in September 2007, which 

reports an increase in his peer-reviewed mean estimate of SCC from $14 to $20/ton CO2 and 

from $43 to $71/ton carbon.16 Earthjustice also asserted that the use of Tol’s mean as an 

upper bound is inconsistent with sound risk analysis and distributions of climate damage 

functions, leading to systematic undervaluation of damages. (Earthjustice, No. 38 at p. 9) 

Lastly, Earthjustice noted that Tol’s estimate relies primarily on estimates that did not use 

the currently accepted climate change discounting procedure of declining discount rate over 

time, and it fails to recognize the distinction between the ways in which scarcity affects the 

value of normal goods and environmental goods. (Earthjustice No. 38 at p. 11) 

AHRI noted that Congress is now engaged in debating a possible cap and trade 

program for the United States. The size of the allowance cap first set by such legislation or 

by implementing regulations and the pace of reduction of the emission allowances will 

largely determine the unit price or value of CO2 emissions reductions. AHRI stated that it 

 

16 Tol, R.S.J. (2007) The social cost of carbon: trends, outliers, and catastrophes. Research Unit Sustainability 

and Global Change, Working Paper FNU-144, Hamburg University and Centre for Marine and Atmospheric 

Science, Hamburg, Germany. 

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would be an arbitrary decision on DOE’s part to rely on valuations identified in the 

Intergovernmental Panel on Climate Change (IPCC) or valuations used in the European 

Union (EU) cap and trade program when the United States has not yet set an emissions cap 

itself. Further, AHRI stated that DOE should not allow evaluation of environmental impacts 

to negate or render moot what has always been, and should remain, the core analysis in 

appliance standards rulemakings, i.e. consumer payback and life-cycle cost analyses. 

(AHRI, No. 33 at p. 6) NRDC also stated that the cost of carbon emissions will become an 

issue with California adopting a Climate Program and the Regional Greenhouse Gas 

Initiative in the Northeast. (NRDC, Public Meeting Transcript, No. 27 at p. 105) 

Earthjustice’s written comment states that DOE’s monetization of CO2 emissions 

should reflect the potential U.S. legislation that would put a national cap on CO2 emissions. 

This includes examining the effect of the standard in reducing allowance prices and the 

benefit of reduced emissions in the NPV. This is Earthjustice’s primary suggested 

consideration for DOE; otherwise, DOE should take into account existing regional CO2 caps 

when monetizing CO2. Finally, the most basic consideration DOE must make, according to 

Earthjustice, is to economically account for the avoided environmental harm from CO2

emissions. (Earthjustice, No. 38 at pp. 2–6) 

The Joint Comment stated that DOE should incorporate the monetization of carbon 

emission reductions in the life-cycle cost analysis and the national impact analysis. The 

Joint Comment further stated that DOE's exclusion of carbon monetization in the LCC and 

NIA results in a systematic underestimation of benefits of new energy conservation 

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standards. (Joint Comment, No. 34 at p. 6) Earthjustice stated that DOE does not account for 

the economic value of CO2 emissions reductions resulting from efficiency standards in any 

meaningful way. Although DOE has begun estimating a range of values for carbon 

emissions, it then ignores these values when choosing the new standard level. Earthjustice 

stated that DOE must address these issues by (1) accounting for the value of emissions 

reductions resulting from a standard in the economic analyses, the LCC, and NIA; and (2) 

using reasonable assumptions and sources when determining the value of carbon emission 

reductions because the current sources evaluated are inadequate. (Earthjustice, No. 38 at p. 

1) Specifically, Earthjustice stated that DOE should quantify the effect of a CO2 emission 

cap on energy prices in the LCC analysis. (Earthjustice, No. 38 at p. 2) 

DOE has made several additions to its monetization of environmental emissions 

reductions in today’s rule, which are discussed in section VI.C.6. DOE has chosen to 

continue to report these benefits separately from the net benefits of energy savings. Nothing 

in EPCA or in the National Environmental Policy Act (NEPA) requires that the economic 

value of emissions reduction be incorporated in the net present value analysis of energy 

savings. Unlike energy savings, the economic value of emissions reduction is not priced in 

the marketplace. However, DOE will consider both values when weighing the benefits and 

burdens of standards. 

Although this rulemaking does not affect SO2 emissions, there are markets for SO2

emissions allowances. The market clearing price of SO2 emissions is roughly the marginal 

cost of meeting the regulatory cap, not the marginal value of the cap itself. Further, because 

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national SO2 emissions are regulated by a cap and trade system, the need to meet these caps 

is already included in the price of energy or energy savings. With a cap on SO2, the value of 

energy savings already includes the value of SO2 control for those consumers experiencing 

energy savings. The economic cost savings associated with SO2 emissions caps is 

approximately equal to the change in the price of traded allowances resulting from energy 

savings multiplied by the number of allowances that would be issued each year. That 

calculation is uncertain because the energy savings for commercial refrigeration equipment 

are so small relative to the entire electricity generation market that the resulting emissions 

savings would have almost no impact on price formation in the allowances market. These 

savings would most likely be outweighed by uncertainties in the marginal costs of 

compliance with SO2 emissions caps. 

For those emissions currently not priced (CO2, Hg, and NOX), only a range of 

estimated economic values based on environmental damage studies of varying quality and 

applicability is available. DOE is weighing these values separately and is not including them 

in the NPV analysis. 

 

V. Discussion of Other Comments 

Since DOE opened the docket for this rulemaking, it has received more than 100 

comments from a diverse set of parties, including manufacturers and their representatives, 

trade associations, wholesalers and distributors, energy conservation advocates, and electric 

utilities. Section IV of this preamble discusses comments DOE received on the analytic 

methodologies it used. Additional comments DOE received in response to the August 2008 

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NOPR addressed the information DOE used in its analyses, results of and inferences drawn 

from the analyses, impacts of standards, the merits of the different TSLs and standards 

options DOE considered, and other issues affecting adoption of standards for commercial 

refrigeration equipment. DOE addresses these comments in this section. 

A. Information and Assumptions Used in Analyses

1. Market and Technology Assessment 

a. Data Sources 

DOE summarized its analysis for energy consumption in chapter 3 of the NOPR 

TSD. Traulsen stated that there are problems with the use of energy consumption data 

reported to government agencies because of inaccurate data reporting. Traulsen cited several 

problems with U.S. Environmental Protection Agency’s (EPA’s) ENERGY STAR database 

for self-contained commercial solid-door food service refrigerators and freezers, including 

equipment listed in the database that does not conform to the ENERGY STAR 

specifications. Traulsen suggested that sources such as these not be used in the technical 

analyses because of the errors they contain. (Traulsen, No. 25 at p. 1) 

The ENERGY STAR requirements for commercial solid door refrigerators and 

freezers cover self-contained commercial refrigerators, freezers, and refrigerator-freezers 

that have solid doors, which are not covered in this commercial refrigeration equipment 

rulemaking. In terms of equipment classes, there is no overlap between the ENERGY STAR 

program and DOE’s rulemaking on commercial refrigeration equipment, except for 

commercial ice-cream freezers. EPA’s commercial ice-cream freezer equipment class does 

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not coincide with DOE’s commercial ice-cream freezer equipment class because they are 

defined differently and tested at different rating temperatures. In addition, DOE understands 

that Traulsen has a large market in the commercial refrigeration industry for self-contained 

commercial refrigerator and freezers with doors. However, these equipment classes are not 

covered in this rulemaking. Also, DOE did not use energy consumption databases from 

other government agencies such as EPA,. Rather, DOE conducted its own evaluation of 

energy consumption data for existing equipment from major manufacturers and compiled a 

performance database. The primary source of information for the database was equipment 

data sheets that were publicly available on manufacturers’ websites. From these data sheets, 

equipment information such as total refrigeration load, evaporator temperature, lighting 

power draw, defrost power draw, and motor power draw allowed determination of 

calculated daily energy consumption (CDEC) according to the DOE test procedure. See 

chapter 3 of the TSD for additional information on market performance data. 

b. Beverage Merchandisers 

In response to the NOPR, Coca-Cola submitted a comment questioning the market 

share and shipment data in DOE’s analysis. Coca-Cola stated that its own purchases 

contradict DOE’s figures. According to Coca-Cola, vertical closed transparent, selfcontained, medium temperature (VCT.SC.M) equipment makes up the majority of CocaCola’s purchases. DOE’s exclusion of this class accounts for the differences between CocaCola’s purchases and the number of units shipped that DOE reported in the engineering 

analysis. (Coca-Cola, No. 21 at p. 1) 

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As explained in the July 2007 ANOPR, VCT.SC.M equipment is currently covered 

by energy conservation standards established in EPCA. 72 FR 41176. Therefore, selfcontained glass-front beverage merchandisers (beverage coolers), which are included in the 

VCT.SC.M equipment class, are not covered in this commercial refrigeration equipment 

rulemaking. As a result, all the shipment and market share data reported in the engineering 

analysis are valid for the classes of commercial refrigeration equipment covered in this 

rulemaking. 

2. Engineering Analysis 

a. Design Options 

In the NOPR, DOE reevaluated the list of design options remaining after the 

ANOPR screening analysis. Based on public comments, DOE made the following design 

option changes in the NOPR and did not receive any further comment for the final rule: 

increasing insulation thickness as a design option; revising anti-sweat heater power values 

for certain equipment classes with glass doors; and revising assumptions made to estimate 

changes in cost and efficiency for high-efficiency, single-speed compressors used in selfcontained equipment. 73 FR 50087. However, there were certain design options for which 

DOE did receive comments and that warranted changes for the final rule. Specifically, LED 

cost and efficiency assumptions were updated. 

For the NOPR, DOE could only identify LED luminaires on the market for use in 

vertical refrigerated cases with transparent doors (i.e., the VCT equipment family). DOE 

used these LED luminaires as the basis for LED lighting for open refrigerated cases, 

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because DOE could not identify LED luminaires for use in open refrigerated cases. 

However, when DOE reexamined the current state of LED lighting for the final rule, DOE 

identified LED luminaries on the market for use in open refrigerated cases. DOE updated 

the LED lighting prices for open refrigerated cases using these newly identified LED 

luminaires. 

For the final rule, DOE also updated the LED prices for lighting used in the VCT 

equipment families using the actual reduction in the lumen-based price of LED chips 

reported in DOE’s Multi-Year Program Plan between 2007 and 2008. DOE’s 2007 MultiYear Program Plan reported that the latest available OEM device price for LED chips was 

$35/kilolumen.17 DOE’s 2008 Multi-Year Program Plan reported that the latest available 

OEM device price for LED chips was $25/kilolumen.18 This equates to a 29-percent 

reduction in lumen-based LED chip costs from 2007-2008. For the final rule, DOE applied 

this 29-percent reduction in lumen-based LED chip costs to the LED lighting for the VCT 

equipment families, representing about a 9-percent reduction in LED system costs, 

assuming the costs of the power supply and LED fixtures did not change from the values 

used in the NOPR engineering analysis. For additional detail regarding LED costs, see 

section IV.B.2.a. 

In addition to expected price reductions, DOE received comments on the unique 

performance advantages of LED systems following the NOPR. Philips stated that LED 

 

17 U.S. Department of Energy, Solid-State Lighting Research and Development, Multi-Year Program Plan 

FY08-FY13. 

18 U.S. Department of Energy, Solid-State Lighting Research and Development, Multi-Year Program Plan 

FY09-FY14. 

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systems are virtually maintenance-free. Without maintenance costs, LED payback periods 

amount to roughly half of their life expectancy. (Philips, No. 29 at pp. 1–6) Philips also 

claimed that LED efficacy (lm/W) is expected to increase. Increases in efficacy effectively 

reduce the operational costs of the system by allowing for less energy consumption while 

maintaining output. (Philips, No. 29 at p. 1) 

As mentioned above, for today’s final rule, DOE reexamined the LED lighting 

assumptions that were used in the NOPR. DOE identified more efficacious LED lighting 

options for use in both vertical refrigerated cases with transparent doors and open 

refrigerated cases than the LED lighting identified in the NOPR analysis. Based on the new 

LED lighting options, DOE updated case lighting configurations for each equipment class 

specific to LED lighting in the engineering analysis. For more detail about the updated LED 

lighting performance assumptions, see chapter 5 and appendix B of the TSD. 

In addition to the life-cycle benefits afforded by LEDs, the California Utilities Joint 

Comment stated that LED systems have a higher degree of controllability, which gives the 

systems dimming, cold start, and short cycling capabilities. (California Utilities Joint 

Comment, No. 41 at p. 3) ASAP added that these features allow LED systems to be turned 

off in situations in which fluorescents could not. This equates to improved energy efficiency 

for commercial refrigeration equipment that uses LED lighting. (ASAP, Public Meeting 

Transcript, No. 27 at p. 106) 

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The enhanced controllability of LED lighting can offer multiple benefits over 

fluorescent lighting. Specifically, the ability to reduce the operating time of LED lighting 

can lead to increased energy efficiency for commercial refrigeration equipment. Therefore, 

in the July 2007 ANOPR, DOE specifically requested public comment on using 24 hours as 

the case lighting operational hours. 72 FR at 41187. In the August 2008 NOPR, based on 

public comment, DOE determined that 24 hours was an adequate assumption for case 

lighting operating hours regardless of lighting type. 73 FR at 50095. In addition, the test 

procedure DOE adopted for commercial refrigeration equipment, ANSI/ARI Standard 

1200–2006, is a steady-state test procedure, which is unable to capture significant energy 

savings due to dimming controls or motion sensors. 71 FR at 71370. 

Following the NOPR, some manufacturers expressed concerns that implementing 

LED lighting would reduce the quality of their equipment. Specifically, they disagreed with 

the use of general white light LEDs to develop a price specifically for LED lighting used in 

commercial refrigeration equipment. True and Southern Store Fixtures stated that the 

grocery store market will be most affected by the use of LED lighting because certain food 

products, such as meat, dairy, deli, and produce, have to have a special display color. (True, 

Public Meeting Transcript, No. 27 at p. 111; Southern Store Fixtures, Public Meeting 

Transcript, No. 27 at p. 108) Continental Refrigerator added that in low-temperature 

applications, there is degradation in LED color quality, requiring the technology to be 

developed further. (Continental Refrigerator, No.27 at p. 141) Southern Store Fixtures stated 

that LEDs used in commercial refrigeration equipment are more expensive because 

additional labor is required to test and sort the LEDs to meet the industry’s color quality 

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requirements. (Southern Store Fixture, Public Meeting Transcript, No. 27 at p. 108) Hill 

Phoenix agreed with Southern Store Fixtures and added that repeatability and minimizing 

the LED output variance also factors into this costly sorting process (i.e., binning). (Hill 

Phoenix, Public Meeting Transcript, No. 27 at p. 109) PG&E estimated that this premium 

will remain constant independent of any future price reductions. (PG&E, Public Meeting 

Transcript, No. 27 at p. 110) AHRI and Hill Phoenix suggested that prices for LED systems 

used in commercial refrigeration equipment will not experience the same price reductions 

that the rest of the LED industry will. Both interested parties agreed that, because the 

commercial refrigeration market for LEDs is small, there will not be a great demand for 

high-quality LEDs, providing little incentive for LED suppliers to offer low-price, highquality LEDs. (AHRI, No. 33 at p. 2 and Hill Phoenix, No. 32 at p. 2) 

DOE acknowledges that a premium markup is applied to LED chips used in 

commercial refrigeration applications due to the binning process. This highly selective 

process requires LED chips to be chosen by hand to ensure the consistency in color 

temperature and light quality demanded by commercial refrigeration equipment customers. 

As LED technology advances (e.g., efficacy or price), the binning process for quality 

remains the same, resulting in a constant markup on the price of LED chips used for 

commercial refrigeration equipment. DOE accounted for this premium in the pricing used 

for the NOPR analysis. In the update of LED prices between 2007 and 2008 for the final 

rule, DOE maintained the markup associated with the higher level of quality needed for 

LEDs used in commercial refrigeration equipment. 

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DOE also received comments on the relative benefits of using LEDs in lowtemperature cases versus medium-temperature cases and in closed cases versus open cases. 

The California Utilities Joint Comment stated that LED luminous output is 10 percent 

higher at 0 °F than at 25 °F. (California Utilities Joint Comment, No. 41 at p. 11) Southern 

Store Fixtures stated the heat from the LED fixture could be used to control condensate on 

closed case doors. It suggested using a remote power module for open cases. (Southern 

Store Fixtures, Public Meeting Transcript, No. 27 at p. 98) Hill Phoenix also stated that it is 

still a challenge for LED lighting in open cases to provide the quality and quantity of light 

required by the food marketing industry. (Hill Phoenix, No. 32 at p. 1) 

As stated above, DOE was able to identify for the final rule LED luminaires 

currently available on the market for both open refrigerated cases and vertical refrigerated 

cases with transparent doors. The benefits of using LEDs vary depending on the type of 

commercial refrigerated equipment in which they are used. However, the luminaires DOE 

identified for use in the final rule analysis were specifically developed for individual types 

of commercial refrigeration equipment, and the luminaire manufacturers reported that the 

performance and quality of those luminaires were developed to meet the specific light 

output requirements of the commercial refrigeration equipment manufacturers that use them. 

Therefore, although the LED luminous output may be about 10 percent higher for lowtemperature cases compared to medium-temperature cases, the luminaires chosen for the 

analysis were actual products that commercial refrigeration equipment manufacturers 

specified provide appropriate lighting levels. Likewise, the power configuration used in the 

analysis for LED fixtures was also based on actual products used in closed and open cases. 

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However, DOE did modify the LED lighting configurations assumed in the engineering 

analysis based on comments received and lighting manufacturer specification sheets. Most 

notably, for the final rule, DOE doubled the shelf lighting for open cases compared to that 

assumed for the NOPR. This increase in shelf lighting is needed to meet the lighting 

requirements of open cases due to the directional nature of LED lighting. See appendix B 

for more detail regarding the lighting configurations assumed in the engineering analysis. 

b. Baseline Models 

 DOE established baseline specifications for each equipment class modeled in the 

engineering analysis by reviewing available manufacturer data, selecting several 

representative units, and then aggregating the physical characteristics of those units. This 

process created a unit representative of commercial refrigeration equipment currently 

offered for sale in each equipment class, with average characteristics for physical parameters 

(e.g., volume, TDA), and minimum performance of energy-consuming components (e.g., 

fans, lighting). In the NOPR analysis, DOE made several revisions to the baseline 

specifications. These changes include updates to baseline lighting, TDA calculations, and 

baseline energy consumption. Appendix B of the NOPR TSD explained in detail the 

changes made to the baseline design specifications relative to the ANOPR analysis. DOE 

received no comments specific to these changes, and is therefore maintaining them for the 

final rule. 

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c. Consideration of Alternative Refrigerants 

The framework document stated that due to the phaseout of chlorofluorocarbons 

(CFCs) and hydrochlorofluorocarbons (HCFCs) in refrigeration equipment, the industry 

would likely use HFC refrigerants in their products. Following the framework document, 

AHRI stated that most of the data it provided to DOE was based on the use of HFC 

refrigerants. In the ANOPR TSD and NOPR, DOE assumed that HFC refrigerants were 

already in wide use in the refrigeration industry, and therefore used HFC refrigerants as the 

basis for the technical analysis conducted in the rulemaking. 

The Joint Comment in response to the NOPR stated that DOE should consider 

alternative primary refrigerants such as hydrocarbons, ammonia, and CO2 in its analysis 

because of their potential energy benefits, and because of the current phase-out of CFCs and 

HCFCs as refrigerants. The Joint Comment pointed out that alternative primary refrigerants 

are widely used in countries other than the United States, principally in Europe. (Joint 

Comment, No. 34 at p. 8) 

As stated in the ANOPR TSD and NOPR, DOE based its technical analysis on the 

use of HFC refrigerants. A Federal phaseout of CFC refrigerants has already occurred, and a 

Federal phaseout of HCFC refrigerants is pending in 2010. Thus, DOE did not consider 

CFCs and HCFCs in its analysis. Likewise, although alternative refrigerants such as 

hydrocarbons, ammonia, and CO2 are used in Europe and elsewhere in the world, there is no 

evidence that they are widely used for commercial refrigeration applications in the United 

States. In addition, current state and local building codes would not allow the use of many 

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alternative refrigerants (Safety Class A3 - most hydrocarbon refrigerants) in remote 

condensing equipment covered by this rulemaking due to flammability concerns. These 

codes would also severely limit the use of ammonia due to toxicity concerns. Both could be 

considered for use with secondary loop refrigeration systems, but these are not the subject of 

this rulemaking. Hydrocarbon refrigerants could possibly be used for small self-contained 

commercial refrigeration equipment covered in this rulemaking if they contain less than 3 

pounds of refrigerant and if they have been certified by Underwriters Laboratories or 

another product certification lab. However, DOE believes that no such equipment has been 

certified for the U.S. market, and it did not consider these refrigerants as a viable design 

option in the engineering analysis. 

The majority of the U.S. commercial refrigeration industry uses HFC refrigerants in 

commercial refrigeration equipment. Since the analysis should be based on the refrigerant 

most widely used in commercial refrigeration equipment, it is unnecessary to consider 

alternative refrigerants. For these reasons, DOE has continued to use HFC refrigerants as the 

basis for its technical analysis. DOE used the HFC refrigerant R-404A for all remote 

condensing equipment and HFC refrigerant R-404A or refrigerant R-134A for all selfcontained equipment. 

d. Consideration of NSF 7 Type II Equipment 

On December 8, 2006, DOE published a final rule in which it adopted ANSI/ARI 

Standard 1200–2006 as the DOE test procedure for commercial refrigeration equipment. 71 

FR at 71340, 71369–70. DOE incorporated the test procedure into its regulations in 10 CFR 

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431.63–431.64. The standard also requires performance tests to be conducted according to 

ANSI/ASHRAE Standard 72–2005. Following the NOPR, DOE received comments from 

Southern Store Fixtures and Zero Zone stating that the DOE test procedure is insufficient 

because a subset of the equipment covered in this rulemaking is designed for and operates 

under harsher conditions than the 75.2 °F dry-bulb and 64.4 °F wet-bulb ambient 

temperature condition used in the DOE test procedure. 

According to Southern Store Fixtures and Zero Zone, the hotter, more humid 

ambient condition requires additional energy consumption to power larger compressors and 

the anti-condensate capabilities necessary in this environment. These conditions make it 

more difficult to meet the standards proposed by this rulemaking. As a result, both Zero 

Zone and Southern Store Fixtures suggested that DOE should account for the difference 

between test procedure ambient conditions and operating ambient conditions for this subset 

of equipment by making a distinction similar to the one currently used in the National 

Sanitation Foundation Standard 7 (NSF 7) standard. (Zero Zone Public Meeting Transcript, 

No. 27 at p. 17 and Southern Store Fixtures No. 27 at p. 18) Under NSF 7, equipment 

intended for use in more severe environments is designated as “Type II” equipment and is 

tested at 80 °F dry-bulb and 68 °F wet-bulb ambient conditions. NSF “Type I” equipment is 

tested at the same ambient conditions as the DOE test procedure, namely the 75.2 °F drybulb and 64.4 °F wet-bulb temperature ambient condition. 

To address this issue, AHRI suggested exempting Type II equipment from coverage 

or instructing manufacturers of Type II equipment to apply for waivers. (AHRI, Public 

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Meeting Transcript, No. 27 at p. 50) If the waiver approach is pursued, Southern Store 

Fixtures suggested using available NSF Type II testing data to find the relationship among 

food temperature, the metric used in NSF testing, and energy consumption, the metric used 

in the DOE test procedure. This relationship would allow at least some Type II equipment to 

be considered fairly under this rule and mitigate a spike in waiver applications. (Southern 

Store Fixtures, Public Meeting Transcript, No. 27 at p. 54) 

After consideration of these comments, DOE believes that instituting a distinction 

between Type I and Type II commercial refrigeration equipment, as defined by NSF 7, is 

unnecessary in this rulemaking. The DOE test procedure, ARI Standard 1200-2006, requires 

that energy consumption testing for all commercial refrigeration equipment covered in this 

rulemaking be conducted according to ANSI/ASHRAE Standard 72-2005, which prescribes 

specific ambient conditions. There is no requirement to address the ambient conditions 

specified in the NSF 7 standard. The two standards also serve different purposes. The 

ANSI/ASHRAE 72-2005 standard measures energy consumption for a specific ambient 

condition, whereas the NSF 7 standard measures food temperature at a specific ambient 

condition for food safety purposes. Although these test procedures have different purposes, 

including the NSF 7 Type II test procedure would have a minimal impact on the energy 

consumption of this equipment because the differences between the ANSI/ASHRAE 72-

2005 and NSF 7 Type II ambient test conditions are marginal. NSF 7 Type II equipment is 

defined as a unit intended for use in an environment in which the ambient dry-bulb 

temperature does not exceed 80 °F. This is at most 5 °F higher than the 75 °F ambient dry 

bulb temperature used in the DOE test procedure. Therefore, the test procedure requires all 

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commercial refrigeration equipment covered under this rulemaking to be tested for energy 

consumption according to the ambient conditions specified in ANSI/ASHRAE Standard 72-

2005 and will not include any distinction between Type I and Type II equipment as defined 

by NSF 7. 

e. Product Class Extension Factors 

In the NOPR, DOE developed multipliers to extend standards from the 15 equipment 

classes it directly analyzed to the remaining 23 secondary equipment classes of commercial 

refrigeration equipment it did not directly analyze. DOE’s approach involved a matched-pair 

analysis, which examined the relationship between several related pairs of equipment 

classes. Chapter 5 of the TSD discusses the development of the extension multipliers and 

the set of focused matched-pair analyses. 

Following the NOPR, Southern Store Fixtures questioned the extension multiplier 

for self-contained equipment that was based on the analytical results for open remote 

condensing equipment. Southern Store Fixtures believed that the extension multiplier of 

2.51 DOE developed to correlate remote medium-temperature equipment without doors to 

self-contained medium-temperature equipment without doors should be higher to adequately 

account for the more severe conditions in which self contained equipment are typically used, 

but did not offer a recommendation for the value. (Southern Store Fixtures, Public Meeting 

Transcript, No. 27 at p. 37) 

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The DOE test procedure, ARI Standard 1200-2006, requires that energy 

consumption testing for all commercial refrigeration equipment covered in this rulemaking 

be conducted according to ANSI/ASHRAE Standard 72-2005, which prescribes specific 

ambient conditions. The ambient conditions specified by the DOE test procedure are the 

same regardless of the condensing unit configuration (i.e., remote condensing or selfcontained). In addition, the 2.51 extension multiplier was developed based on the 

relationship between the medium temperature VOP, SVO, and HZO equipment classes that 

DOE directly analyzed. Because neither an alternative value nor contradicting analysis was 

offered, for today’s final rule, DOE will continue to use the 2.51 and other extension 

multipliers developed in the NOPR. 

f. TSL Energy Limits 

After the NOPR, Hussman submitted a comment expressing its concern about the 

technologies required for equipment to meet minimum energy consumption levels for TSL 

4. In particular, Hussman is reluctant to use the no-heat door design option in humid 

climates, such as Houston, Texas. In its experience, no-heat doors in humid climates result 

in more condensation on store floors. According to Hussman, wet floors have led to 

accidents and costly law suits, indirectly linking increased energy efficiency with increased 

safety risks. (Hussman, No. 42 at p. 1) 

Energy conservation standards for today’s final rule set a maximum allowable 

energy conservation level for commercial refrigeration equipment. DOE does not limit the 

technologies manufacturers can use to achieve standards. Manufacturers are free to use any 

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combination of technologies and design options to achieve a required level of energy 

consumption. Manufacturers also have the ability to design equipment for use in specific 

regions where certain design options may cause safety concerns. Certain anti-condensate 

design options consume no energy and could be used to achieve the energy consumption 

levels TSL 4 requires. Anti-condensate films can be applied to the inner surface of glass 

doors to prevent condensation and fog formation. By installing this film, some portion (and 

potentially all) of the glass and/or door mullion heaters can be removed and still maintain 

fog-free operation. In addition, DOE does not have the authority to set regional standards for 

commercial refrigeration equipment, and therefore cannot customize its analysis to exclude 

the use of design options in a specific climate region. Therefore, in developing the energy 

conservation standards for today’s final rule, DOE did not make any modifications to 

accommodate concerns related to any particular climate regions. 

g. Compressor Selection Oversize Factor 

DOE’s energy consumption model selects the most appropriate compressor by 

comparing each compressor’s capacity to the total refrigeration load in the case multiplied 

by the compressor oversize factor. For the ANOPR analysis, DOE listed capacity at the 

standard rating conditions used in ANSI/ARI Standard 540–2004.19 However, the standard 

rating conditions differed from the operating conditions used in the model, resulting in 

different capacity values. Because the standard conditions and modeled conditions differed, 

 

19 18 ANSI/ARI Standard 540–2004: Performance Rating of Positive Displacement Refrigerant Compressors 

and Compressor Units lists standard rating conditions for hermetic refrigeration compressors. For mediumtemperature equipment, compressors are rated at 20 °F suction dewpoint, 120 °F discharge dewpoint, 40 °F 

return gas, and 0 °F subcooling. For low-temperature equipment, compressors are rated at -10 °F suction 

dewpoint, 120 °F discharge dewpoint, 40 °F return gas, and 0 °F subcooling. For ice-cream-temperature 

equipment, compressors are rated at -25 °F suction dewpoint, 105 °F discharge dewpoint, 40 °F return gas, and 

0 °F subcooling. 

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the model typically overestimated the capacity of the selected compressors. To compensate, 

DOE adjusted the compressor oversize factor to an unrealistic level (typically level 1) for 

the ANOPR model to select the correct compressor. In the NOPR analysis, DOE revised the 

capacity values used to select self-contained compressors in the energy consumption model. 

For the NOPR, DOE used capacities based on the same conditions used to calculate total 

refrigeration load and revised the oversize factor (typically 1.4 in the NOPR model) for all 

self-contained equipment classes to maintain the selection of the correct compressor size. 

See chapter 5 of the TSD for more detail. 

Following the NOPR, Structural Concepts commented that the compressor selection 

criteria in the engineering analysis results in the selection of unreasonable compressors for 

the refrigeration load. Specifically, Structural Concepts stated that the refrigeration load is 

6,990 Btu/h for the VOP.SC.M equipment class, and the compressor sizing value is 9,787 

Btu/h. Using the oversize factor value of 1.4, the compressor selected in the engineering 

analysis has a capacity of 13,219 Btu/h. The selection of an unrealistically large compressor 

unfairly skews the energy efficiency ratio because the larger compressor has a higher 

efficiency rating than the next smallest compressor that has a rated capacity closer to the 

compressor sizing value. (Structural Concepts, No. 30 at p. 3) 

The energy consumption model selects a compressor assuming that the rated 

capacity of the compressor must be at or above the compressor sizing value. This prevents 

the selection of a compressor that is unable to meet the refrigeration load. The example 

Structural Concepts selected highlights one of the more extreme cases of how this model 

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can select a compressor that is larger than necessary. However, Structural Concepts did not 

provide a recommendation that would result in the selection of a more appropriate 

compressor, or a more appropriate compressor oversize factor value to use for all the selfcontained equipment classes. Because manufacturers previously agreed that the compressor 

oversize factor of 1.4 was appropriate to use for all the self-contained equipment classes 

used in the analysis, DOE maintained its assumptions from the NOPR. 

h. Offset Factors for Self-Contained Equipment 

For the NOPR, DOE developed offset factors to adjust the energy consumption 

calculations to accommodate smaller equipment for the equipment classes it directly 

analyzed. These offset factors account for the components of the refrigeration load that 

remain constant even when equipment sizes vary (i.e., the conduction end effects) and 

disproportionately affect smaller cases. In the equation that describes the relationship 

between energy consumption and the corresponding TDA or volume metric, the offset 

factors are intended to approximate these constant loads and provide a fixed end point that 

corresponds to a zero TDA or zero volume case. See chapter 5 of the TSD for further details 

on the development of these offset factors for each equipment class. Following the NOPR, 

Structural Concepts requested that DOE increase the offset factor for self-contained 

equipment because DOE’s analysis selected compressors that were too large and had 

unrealistically high efficiencies. (Structural Concepts, No. 30 at p. 4) 

The compressors suggested by Structural Concepts for DOE’s model would, in some 

cases, be undersized for the refrigeration load. As mentioned in section V.A.2.g, DOE 

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maintained the methodology used to select compressors in the energy consumption model. 

Because DOE did not receive any comments on necessary improvements or data on which 

its analysis can be reevaluated, and because the compressor selections used to develop the 

offset factors have not changed, DOE maintained the offset factors developed in the NOPR. 

i. Self-Contained Condensing Coils 

Following the NOPR, Structural Concepts revealed a discrepancy about the running 

temperature for self-contained equipment using coil enhancements. (Structural Concepts, 

No. 30 at p. 1) Chapter 5, section 5.6.3.7 of the NOPR TSD stated that self-contained 

equipment condenser coil enhancements would allow the condenser to run at a saturated 

condenser temperature (SCT) 10 °F cooler than a standard coil. However, the engineering 

analysis spreadsheet showed a decrease of 14 °F for this design option. There was a 

typographical error in the NOPR TSD and the 14 °F decrease in the engineering analysis is 

correct. In chapter 5 of the final rule TSD, DOE updated its figure to reflect the correct SCT 

14 °F cooler temperature for the coil enhancements design option for self-contained 

equipment. 

Structural Concepts also questioned the validity of using 98 °F as the baseline SCT 

in the engineering analysis. According to Structural Concepts, this value is not 

representative of the current “off the shelf” self-contained condensing units available. It 

believes the baseline SCT value should be closer to 105 °F or 110 °F. (Structural Concepts, 

No. 30 at p. 2) 

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There are condensing coils available that operate at both higher and lower SCT than 

the standard coil used in its model. This discrepancy exists because the standard coil used in 

DOE’s model is not an actual condensing coil. DOE reviewed a range of available 

manufacturer data, selected several representative units, and aggregated the physical 

characteristics of the selected units to create a representative unit for each equipment class. 

The 98 °F operating SCT is an average characteristic. DOE also conducted a sensitivity 

analysis to evaluate Structural Concept’s claim that baseline SCT was too low. In this 

sensitivity analysis in which the SCT was raised to 105 °F, DOE observed only minor 

changes in the energy consumption of the self-contained units. For these reasons, DOE will 

continue to use 98 °F as the baseline SCT for self-contained equipment condensers for 

today’s final rule. 

 

 For the NOPR, DOE used data from teardowns by Southern California Edison’s 

Refrigeration and Thermal Test Center (RTTC) to model the enhanced condenser coil used 

in the engineering analysis. Based on this information, DOE considered both minimum and 

maximum technology levels for this design option. For each level, DOE specified an overall 

UA-value and a coil cost. The UA-value is normalized to the standard coil, and the coil cost 

is normalized to the heat removal capacity of the coil. This approach allowed DOE to apply 

the details of coil design across all self-contained equipment classes. In consultation with 

outside experts, DOE determined that applying the same coil improvements to different 

sized coils would result in similar performance improvements. See chapter 5 of the TSD for 

more detail on the development of the enhanced condenser coil specifications. 

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Following the NOPR, Structural Concepts stated that DOE overstates the magnitude 

of the UA-value increase achievable with an enhanced condenser coil. It claimed the 

enhanced condenser prototype DOE used as a model for this design option is too large for 

use in self-contained equipment and, because UA-value primarily depends on surface area, 

the use of a smaller, practical condenser would yield a lower UA-value. As a result, it 

requested that DOE base the UA-value on coils that are closer in size to the standard coil. 

(Structural Concepts, No. 30 at p. 2) 

The specifications for the enhanced coil used in DOE’s analysis are based on a 

model developed specifically for use in a self-contained refrigeration system. The details of 

the coil construction are based on data from teardowns by Southern California Edison’s 

Refrigeration and Thermal Test Center (RTTC).20 Therefore, DOE is confident that it 

modeled an appropriately sized high efficiency condenser coil. In addition to increased 

exterior dimensions, DOE’s enhanced condenser coil also uses a higher fin pitch, rifled 

tubing, and different tube spacing to achieve a higher UA-value than the standard coil. 

Structural Concepts also did not provide costs for their suggested coil model. Because DOE 

did not receive additional information or data that would suggest that the UA-value is not 

representative of enhanced condenser coils, and the data that was provided were incomplete, 

DOE maintained its assumptions from the NOPR for the enhanced condenser coil. 

3. Manufacturer Impact Analysis 

The Joint Comment stated that DOE gives exclusive consideration to the 

 

20 Refrigeration and Thermal Test Center. Personal communication. Southern California Edison. March 29, 

2007. 

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preservation-of-gross-margin (absolute dollars) scenario. According to the Joint Comment, 

relying solely on this scenario only considers manufacturers’ expectations about the 

manufacturing impacts at the proposed standard. (Joint Comment, No. 7 at p. 2) The Joint 

Comment stated the preservation-of-gross-margin-percentage markup scenario provides a 

more plausible representation of impacts on manufacturers due to new energy conservation 

standards. (Joint Comment, No. 7 at p. 3) 

DOE developed two markup scenarios: the preservation-of-gross-margin-percentage 

and the preservation-of-gross-margin (absolute dollars). DOE used these scenarios to bound 

the potential impacts on the industry value as a result of new energy conservation standards 

and presented its findings in the August 2008 NOPR for public comment. 73 FR 50107. The 

preservation-of-gross-margin-percentage markup scenario is a lower bound estimate on 

manufacturer impacts because it assumes that manufacturers will be able to fully recover all 

the increases in production costs due to energy conservation standards requirements. The 

preservation-of-gross-margin (absolute dollars) markup scenario is an upper bound estimate 

on manufacturer impacts because it assumes that manufacturers will be able to only partially 

recover cost increases (to maintain an absolute dollar gross margin) due to energy 

conservation standards. The markup scenarios DOE modeled in the GRIM reflect both its 

interpretation of qualitative information learned during manufacturer interviews and the 

analysis of limited profit margin data provided under confidentiality agreements. 

DOE notes the large uncertainty about the actual impacts on the industry due to 

standards. The commercial refrigeration equipment industry has never been regulated for 

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energy efficiency and manufacturers do not have previous experience on how energy 

conservation standards affect their business. The seven manufacturers that DOE interviewed 

for the NOPR expressed a divergence of views on how prices would change after standards. 

Most manufacturers stated that they expect profit levels to decrease due to new energy 

conservation standards based on their recent inability to pass on increases in material and 

component costs to their customers. The portion of production costs reflected in selling 

prices varied significantly from manufacturer to manufacturer. In general, companies with 

lower market shares face greater challenges in passing along costs and would suffer larger 

margin impacts due to new energy conservation standards. Manufacturers with relatively 

large market shares have been more successful passing through costs and they are more 

confident of maintaining profit levels over the long term. Because of the divergence of 

experience with cost pass-through and the implication for prices and profitability after 

standards, DOE considers the full range of potential impacts bounded by the markup 

scenarios and does not consider one scenario to be more likely. 

In response to the NOPR, Earthjustice noted that the direct employment benefits are 

shown to provide positive employment in the MIA analysis. Earthjustice stated DOE should 

consider these benefits in the final rule. (Earthjustice, Public Meeting Transcript, No. 27 at 

p. 166) 

For the MIA, DOE calculated the direct employment impacts on the commercial 

refrigeration industry. DOE calculated total labor expenditures for the industry using the 

production costs from the engineering analysis, labor information from U.S. Census 

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Bureau’s 2006 Annual Survey of Manufactures, and the total industry shipments from the 

NES. DOE translated the total labor expenditures for the industry into the total number of 

domestic jobs using the domestic share of commercial refrigeration equipment 

manufacturing, the labor rate for the industry, and the annual hours per worker. DOE 

calculated its estimate of the domestic employment for the base case and each TSL. The 

direct employment results characterized by the MIA represent U.S. production and nonproduction workers that are affected by this rulemaking in the commercial refrigeration 

equipment manufacturing industry. 

For the final rule, DOE examined the impacts of energy conservation standards on 

domestic manufacturing employment levels. The direct employment impact analysis 

conducted as part of the MIA estimates the number of domestic workers who are affected by 

this rulemaking in the commercial refrigeration equipment manufacturing industry, 

assuming that shipment levels and product availability remain at current levels. Because 

labor costs are assumed to be a fixed percentage of total manufacturing production costs, 

which increase with more efficient equipment, the GRIM predicts a gradual increase in 

employment after standards. DOE has considered all employment impacts in weighing the 

benefits and the burdens, including direct (as calculated by the MIA) and indirect (as 

calculated by the employment impact analysis). For further details on the direct employment 

impact analysis, see chapter 13 of the accompanying TSD. 

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VI. Analytical Results and Conclusions 

A. Trial Standard Levels 

DOE selected between four and eight energy consumption levels for each 

commercial refrigeration equipment class in the LCC analysis. Based on the results of the 

analysis, DOE selected five trial standard levels above the baseline level for each equipment 

class for the NOPR. The range of TSLs selected includes the most energy efficient 

combination of design options with a positive NPV at the 7-percent discount rate, and the 

combination of design options with the minimum LCC. TSLs also were selected that filled 

large gaps between the baseline and the level with the minimum LCC. 

For the NOPR, DOE developed offset factors to adjust the energy efficiency 

requirements for smaller equipment in each equipment class analyzed. These offset factors 

account for certain components of the refrigeration load (such as the conduction end effects) 

that remain constant even when equipment sizes vary. These constant loads affect smaller 

cases disproportionately. The offset factors are intended to approximate these constant loads 

and provide a fixed end point, corresponding to a zero TDA or zero volume case, in an 

equation that describes the relationship between energy consumption and the corresponding 

TDA or volume metric. See chapter 5 of the TSD for further details on the development of 

these offset factors for each equipment class. 

For the final rule, DOE preserved the general methodology it used for the selection 

of efficiency levels in the NOPR in establishing specific efficiency levels for equipment 

classes. These levels are based on the results of the updated LCC analysis and made up the 

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TSLs used in the NOPR. Table VI-1 shows the TSL levels DOE selected for energy use for 

the equipment classes analyzed. TSL 5 is the max-tech level for each equipment class. TSL 

4 is the maximum efficiency level with a positive NPV at the 7-percent discount rate, except 

for VOP.RC.M. In this class, the minimal difference in energy efficiency between the 

minimum life-cycle cost level as determined by the LCC analysis and the maximum 

efficiency level with positive NPV prompted DOE to select the minimum life-cycle cost 

level instead of the maximum level with positive NPV. TSL 4 is a combination of the 

efficiency levels selected for TSL 3 and TSL 5. For a given equipment class, the efficiency 

levels selected for TSL 4 are either equivalent to those of TSL 3 or TSL 5. TSL 3 is the 

efficiency level that provides the minimum life-cycle cost determined by the LCC analysis. 

TSL 2 and TSL 1 represent lower efficiency levels that fill in the gap between the current 

baseline and the levels determined to have the minimum LCC. 

Table VI-1 shows the same TSL levels in terms of proposed equations that establish 

an MDEC limit through a linear equation of the form: 

MDEC = A × TDA + B (for equipment using TDA as a normalizing metric)

or

MDEC = A × V + B (for equipment using volume as a normalizing metric)

Coefficients A and B are uniquely derived for each equipment class based on the 

calculated offset factor B (see chapter 5 of the TSD for offset factors) and the equation slope 

A. Equation slope A would be used to describe the efficiency requirements for equipment of 

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different sizes within the same equipment class. Chapter 9 of the TSD explains the 

methodology DOE used for selecting TSLs and developing the coefficients shown in Table 

VI-2. 

Table VI-1 Trial Standard Levels for Analyzed Equipment Expressed in Terms of 

Daily Energy Consumption 

Trial Standard Levels for Equipment Analyzed 

Expressed in Terms of Energy Consumption 

(kWh/day) Equipment 

Class 

Normalization 

Metric

Normalization 

Value*

Test 

Metric Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

VOP.RC.M TDA [ft2

]

** 53.30 CDEC 

kWh/day 57.90 51.99 50.68 47.69 47.69 43.75 

VOP.RC.L TDA [ft2

] 44.66 CDEC 

kWh/day 133.60 118.44 113.28 112.00 108.40 108.40 

VOP.SC.M TDA [ft2

] 14.93 TDEC††

kWh/day 39.60 35.95 33.38 30.70 30.70 29.33 

VCT.RC.M TDA [ft2

] 65.00 CDEC 

kWh/day 33.18 31.77 30.00 16.36 16.18 16.18 

VCT.RC.L TDA [ft2

] 65.00 CDEC 

kWh/day 69.31 65.73 46.90 39.60 39.18 39.18 

VCT.SC.I TDA [ft2

] 26.00 TDEC 

kWh/day 45.63 33.35 23.39 21.17 20.81 20.81 

VCS.SC.I V [ft3

]

† 48.00 TDEC 

kWh/day 27.13 24.31 21.64 19.07 19.07 19.07 

SVO.RC.M TDA [ft2

] 40.00 CDEC 

kWh/day 43.56 39.58 38.59 36.34 36.34 33.61 

SVO.SC.M TDA [ft2

] 12.80 TDEC 

kWh/day 33.11 30.66 28.87 26.74 26.74 25.74 

SOC.RC.M TDA [ft2

] 51.00 CDEC 

kWh/day 31.70 30.01 27.93 26.24 26.24 20.62 

HZO.RC.M TDA [ft2

] 33.00 CDEC 

kWh/day 19.63 17.89 15.73 14.69 14.54 14.54 

HZO.RC.L TDA [ft2

] 46.00 CDEC 

kWh/day 38.38 35.30 33.41 32.97 32.97 32.97 

HZO.SC.M TDA [ft2

] 12.00 TDEC 

kWh/day 19.23 17.85 16.51 14.93 14.81 14.81 

HZO.SC.L TDA [ft2

] 12.00 TDEC 

kWh/day 38.69 36.02 33.52 30.31 30.14 30.14 

HCT.SC.I TDA [ft2

] 5.12 TDEC 

kWh/day 7.25 6.37 3.70 3.53 3.32 3.32 

* This is the assumed baseline size for each equipment class used in DOE’s analyses. 

** TDA is total display area of the case. 

† V is gross refrigerated volume of the case. 

†† TDEC is total daily energy consumption of the case. 

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Table VI-2 Trial Standard Levels Expressed in Terms of Equations and Coefficients 

for Each Primary Equipment Class 

Equipment Trial Standard Levels for Primary Equipment Classes Analyzed 

Class 

Test 

Metric Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

VOP.RC.M CDEC 

kWh/day 

1.01 x TDA 

+ 4.07 

0.9 x TDA + 

4.07 

0.87 x TDA 

+ 4.07 

0.82 x TDA 

+ 4.07 

0.82 x TDA 

+ 4.07 

0.74 x TDA 

+ 4.07 

VOP.RC.L CDEC 

kWh/day 

2.84 x TDA 

+ 6.85 

2.5 x TDA + 

6.85 

2.38 x TDA 

+ 6.85 

2.35 x TDA 

+ 6.85 

2.27 x TDA 

+ 6.85 

2.27 x TDA 

+ 6.85 

VOP.SC.M TDEC 

kWh/day 

2.34 x TDA 

+ 4.71 

2.09 x TDA 

+ 4.71 

1.92 x TDA 

+ 4.71 

1.74 x TDA 

+ 4.71 

1.74 x TDA 

+ 4.71 

1.65 x TDA 

+ 4.71 

VCT.RC.M CDEC 

kWh/day 

0.48 x TDA 

+ 1.95 

0.46 x TDA 

+ 1.95 

0.43 x TDA 

+ 1.95 

0.22 x TDA 

+ 1.95 

0.22 x TDA 

+ 1.95 

0.22 x TDA 

+ 1.95 

VCT.RC.L CDEC 

kWh/day 

1.03 x TDA 

+ 2.61 

0.97 x TDA 

+ 2.61 

0.68 x TDA 

+ 2.61 

0.57 x TDA 

+ 2.61 

0.56 x TDA 

+ 2.61 

0.56 x TDA 

+ 2.61 

VCT.SC.I TDEC 

kWh/day 

1.63 x TDA 

+ 3.29 

1.16 x TDA 

+ 3.29 

0.77 x TDA 

+ 3.29 

0.69 x TDA 

+ 3.29 

0.67 x TDA 

+ 3.29 

0.67 x TDA 

+ 3.29 

VCS.SC.I TDEC 

kWh/day 

0.55 x V + 

0.88 

0.49 x V + 

0.88 

0.43 x V + 

0.88 

0.38 x V + 

0.88 

0.38 x V + 

0.88 

0.38 x V + 

0.88 

SVO.RC.M CDEC 

kWh/day 

1.01 x TDA 

+ 3.18 

0.91 x TDA 

+ 3.18 

0.89 x TDA 

+ 3.18 

0.83 x TDA 

+ 3.18 

0.83 x TDA 

+ 3.18 

0.76 x TDA 

+ 3.18 

SVO.SC.M TDEC 

kWh/day 

2.23 x TDA 

+ 4.59 

2.04 x TDA 

+ 4.59 

1.9 x TDA + 

4.59 

1.73 x TDA 

+ 4.59 

1.73 x TDA 

+ 4.59 

1.65 x TDA 

+ 4.59 

SOC.RC.M CDEC 

kWh/day 

0.62 x TDA 

+ 0.11 

0.59 x TDA 

+ 0.11 

0.55 x TDA 

+ 0.11 

0.51 x TDA 

+ 0.11 

0.51 x TDA 

+ 0.11 

0.4 x TDA + 

0.11 

HZO.RC.M CDEC 

kWh/day 

0.51 x TDA 

+ 2.88 

0.45 x TDA 

+ 2.88 

0.39 x TDA 

+ 2.88 

0.36 x TDA 

+ 2.88 

0.35 x TDA 

+ 2.88 

0.35 x TDA 

+ 2.88 

HZO.RC.L CDEC 

kWh/day 

0.68 x TDA 

+ 6.88 

0.62 x TDA 

+ 6.88 

0.58 x TDA 

+ 6.88 

0.57 x TDA 

+ 6.88 

0.57 x TDA 

+ 6.88 

0.57 x TDA 

+ 6.88 

HZO.SC.M TDEC 

kWh/day 

1.14 x TDA 

+ 5.55 

1.03 x TDA 

+ 5.55 

0.91 x TDA 

+ 5.55 

0.78 x TDA 

+ 5.55 

0.77 x TDA 

+ 5.55 

0.77 x TDA 

+ 5.55 

HZO.SC.L TDEC 

kWh/day 

2.63 x TDA 

+ 7.08 

2.41 x TDA 

+ 7.08 

2.2 x TDA + 

7.08 

1.94 x TDA 

+ 7.08 

1.92 x TDA 

+ 7.08 

1.92 x TDA 

+ 7.08 

HCT.SC.I TDEC 

kWh/day 

1.33 x TDA 

+ 0.43 

1.16 x TDA 

+ 0.43 

0.64 x TDA 

+ 0.43 

0.6 x TDA + 

0.43 

0.56 x TDA 

+ 0.43 

0.56 x TDA 

+ 0.43 

In addition to the standards for the 15 primary equipment classes DOE analyzed, 

DOE is adopting standards for the remaining 23 secondary equipment classes of commercial 

refrigeration equipment covered in this rulemaking that were not directly analyzed in the 

engineering analysis due to low annual shipments (less than 100 units per year). DOE’s 

approach involved extension multipliers developed using both the 15 primary equipment 

classes analyzed and a set of focused matched-pair analyses. In addition, standards for 

certain primary equipment classes could be directly applied to other similar secondary 

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equipment classes. Chapter 5 of the TSD discusses the development of the extension 

multipliers and the set of focused matched-pair analyses. 

Using this approach, DOE developed an additional set of TSLs for these secondary 

equipment classes that corresponds to each of the equations shown in Table VI-2 at each 

TSL. Table VI-3 shows this additional set of corresponding TSL levels. 

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Table VI-3 Trial Standard Levels Expressed in Terms of Equations and Coefficients for 

Each Secondary Equipment Class 

Equipment Trial Standard Levels for Secondary Equipment Classes Analyzed

Class 

Test 

Metric Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

SVO.RC.L CDEC 

kWh/day 

2.84 x TDA 

+ 6.85 

2.5 x TDA + 

6.85 

2.38 x TDA 

+ 6.85 

2.35 x TDA 

+ 6.85 

2.27 x TDA 

+ 6.85 

2.27 x TDA 

+ 6.85 

VOP.RC.I CDEC 

kWh/day 

3.6 x TDA + 

8.7 

3.17 x TDA 

+ 8.7 

3.03 x TDA 

+ 8.7 

2.99 x TDA 

+ 8.7 

2.89 x TDA 

+ 8.7 

2.89 x TDA 

+ 8.7 

SVO.RC.I CDEC 

kWh/day 

3.6 x TDA + 

8.7 

3.17 x TDA 

+ 8.7 

3.03 x TDA 

+ 8.7 

2.99 x TDA 

+ 8.7 

2.89 x TDA 

+ 8.7 

2.89 x TDA 

+ 8.7 

HZO.RC.I CDEC 

kWh/day 

0.87 x TDA 

+ 8.74 

0.78 x TDA 

+ 8.74 

0.73 x TDA 

+ 8.74 

0.72 x TDA 

+ 8.74 

0.72 x TDA 

+ 8.74 

0.72 x TDA 

+ 8.74 

VCT.RC.I CDEC 

kWh/day 

1.2 x TDA + 

3.05 

1.14 x TDA 

+ 3.05 

0.8 x TDA + 

3.05 

0.67 x TDA 

+ 3.05 

0.66 x TDA 

+ 3.05 

0.66 x TDA 

+ 3.05 

HCT.RC.M CDEC 

kWh/day 

0.39 x TDA 

+ 0.13 

0.34 x TDA 

+ 0.13 

0.19 x TDA 

+ 0.13 

0.18 x TDA 

+ 0.13 

0.16 x TDA 

+ 0.13 

0.16 x TDA 

+ 0.13 

HCT.RC.L CDEC 

kWh/day 

0.81 x TDA 

+ 0.26 

0.71 x TDA 

+ 0.26 

0.39 x TDA 

+ 0.26 

0.37 x TDA 

+ 0.26 

0.34 x TDA 

+ 0.26 

0.34 x TDA 

+ 0.26 

HCT.RC.I CDEC 

kWh/day 

0.95 x TDA 

+ 0.31 

0.83 x TDA 

+ 0.31 

0.46 x TDA 

+ 0.31 

0.43 x TDA 

+ 0.31 

0.4 x TDA + 

0.31 

0.4 x TDA + 

0.31 

VCS.RC.M CDEC 

kWh/day 

0.16 x V + 

0.26 

0.14 x V + 

0.26 

0.13 x V + 

0.26 

0.11 x V + 

0.26 

0.11 x V + 

0.26 

0.11 x V + 

0.26 

VCS.RC.L CDEC 

kWh/day 

0.33 x V + 

0.54 

0.3 x V + 

0.54 

0.26 x V + 

0.54 

0.23 x V + 

0.54 

0.23 x V + 

0.54 

0.23 x V + 

0.54 

VCS.RC.I CDEC 

kWh/day 

0.39 x V + 

0.63 

0.35 x V + 

0.63 

0.31 x V + 

0.63 

0.27 x V + 

0.63 

0.27 x V + 

0.63 

0.27 x V + 

0.63 

HCS.RC.M CDEC 

kWh/day 

0.16 x V + 

0.26 

0.14 x V + 

0.26 

0.13 x V + 

0.26 

0.11 x V + 

0.26 

0.11 x V + 

0.26 

0.11 x V + 

0.26 

HCS.RC.L CDEC 

kWh/day 

0.33 x V + 

0.54 

0.3 x V + 

0.54 

0.26 x V + 

0.54 

0.23 x V + 

0.54 

0.23 x V + 

0.54 

0.23 x V + 

0.54 

HCS.RC.I CDEC 

kWh/day 

0.39 x V + 

0.63 

0.35 x V + 

0.63 

0.31 x V + 

0.63 

0.27 x V + 

0.63 

0.27 x V + 

0.63 

0.27 x V + 

0.63 

SOC.RC.L CDEC 

kWh/day 

1.3 x TDA + 

0.22 

1.23 x TDA 

+ 0.22 

1.15 x TDA 

+ 0.22 

1.08 x TDA 

+ 0.22 

1.08 x TDA 

+ 0.22 

0.84 x TDA 

+ 0.22 

SOC.RC.I CDEC 

kWh/day 

1.52 x TDA 

+ 0.26 

1.44 x TDA 

+ 0.26 

1.34 x TDA 

+ 0.26 

1.26 x TDA 

+ 0.26 

1.26 x TDA 

+ 0.26 

0.99 x TDA 

+ 0.26 

VOP.SC.L TDEC 

kWh/day 

5.87 x TDA 

+ 11.82 

5.25 x TDA 

+ 11.82 

4.82 x TDA 

+ 11.82 

4.37 x TDA 

+ 11.82 

4.37 x TDA 

+ 11.82 

4.14 x TDA 

+ 11.82 

VOP.SC.I TDEC 

kWh/day 

7.45 x TDA 

+ 15.02 

6.67 x TDA 

+ 15.02 

6.13 x TDA 

+ 15.02 

5.55 x TDA 

+ 15.02 

5.55 x TDA 

+ 15.02 

5.26 x TDA 

+ 15.02 

SVO.SC.L TDEC 

kWh/day 

5.59 x TDA 

+ 11.51 

5.11 x TDA 

+ 11.51 

4.76 x TDA 

+ 11.51 

4.34 x TDA 

+ 11.51 

4.34 x TDA 

+ 11.51 

4.15 x TDA 

+ 11.51 

SVO.SC.I TDEC 

kWh/day 

7.11 x TDA 

+ 14.63 

6.5 x TDA + 

14.63 

6.05 x TDA 

+ 14.63 

5.52 x TDA 

+ 14.63 

5.52 x TDA 

+ 14.63 

5.27 x TDA 

+ 14.63 

HZO.SC.I TDEC 

kWh/day 

3.35 x TDA 

+ 9. 

3.06 x TDA 

+ 9. 

2.8 x TDA + 

9. 

2.46 x TDA 

+ 9. 

2.44 x TDA 

+ 9. 

2.44 x TDA 

+ 9. 

SOC.SC.I TDEC 

kWh/day 

2.13 x TDA 

+ 0.36 

2.02 x TDA 

+ 0.36 

1.88 x TDA 

+ 0.36 

1.76 x TDA 

+ 0.36 

1.76 x TDA 

+ 0.36 

1.38 x TDA 

+ 0.36 

HCS.SC.I TDEC 

kWh/day 

0.55 x V + 

0.88 

0.49 x V + 

0.88 

0.43 x V + 

0.88 

0.38 x V + 

0.88 

0.38 x V + 

0.88 

0.38 x V + 

0.88 

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1. Miscellaneous Equipment 

As stated in the August 2008 NOPR, certain types of equipment meet the definition 

of “commercial refrigeration equipment” (Section 136(a)(3) of EPACT 2005), but do not 

fall directly into any of the 38 equipment classes defined in the market and technology 

assessment. One of these types is hybrid cases, in which two or more compartments are in 

different equipment families and are contained in one cabinet. Another is refrigeratorfreezers, which have two compartments in the same equipment family but have different 

operating temperatures. Hybrid refrigerator-freezers, where two or more compartments are 

in different equipment families and have different operating temperatures, may also exist. 

Another is wedge cases, which form miter transitions (a corner section between two 

refrigerated display merchandisers) between standard display case lineups. DOE is using 

language that will allow manufacturers to determine appropriate standard levels for these 

types of equipment. 

An example of a pure hybrid case (one with two or more compartments in different 

equipment families and operating at the same temperature) is a unit with one open and one 

closed medium-temperature compartment, such as those seen in coffee shops that sell baked 

goods and beverages. These hybrid cases may be either self-contained or remote 

condensing, and may be cooled by one or more condensing units. They may also have one 

evaporator cooling both compartments or one evaporator feeding each compartment 

separately. 

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An example of a refrigerator-freezer is a unit with doors where one compartment 

operates at medium temperature and one compartment operates at low temperature. Remote 

condensing commercial refrigerator-freezers (with and without doors) and self-contained 

commercial refrigerator-freezers without doors may operate in one of two ways. They may 

operate as separate chilled and frozen compartments with evaporators fed by two sets of 

refrigerant lines or two compressors. Alternatively, they may operate as separate chilled and 

frozen compartments fed by one set of low-temperature refrigerant lines (with evaporator 

pressure regulator (EPR) valves or similar devices used to raise the evaporator pressure) or 

one compressor. 

An example of a hybrid refrigerator-freezer is a unit with one open compartment at 

medium temperature and one closed compartment at low temperature. As with pure hybrid 

cases, these cases may be either self-contained or remote condensing, and may be cooled by 

one or more condensing units. In the case of remote condensing equipment, they may 

operate as separate chilled and frozen compartments with evaporators fed by two sets of 

refrigerant lines or two compressors, or they may operate as separate chilled and frozen 

compartments fed by one set of low-temperature refrigerant lines (with EPR valves or 

similar devices used to raise the evaporator pressure of one compartment) or one 

compressor. 

In the August 2008 NOPR, DOE proposed using the following language for 

requiring manufacturers to meet standards for hybrid cases, refrigerator-freezers, and hybrid 

refrigerator-freezers: 

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• For commercial refrigeration equipment with two or more compartments (i.e., hybrid 

refrigerators, hybrid freezers, hybrid refrigerator-freezers, and non-hybrid 

refrigerator freezers), the MDEC for each model shall be the sum of the MDEC 

values for all of its compartments. For each compartment, measure the TDA or 

volume of that compartment, and determine the appropriate equipment class based 

on that compartment’s equipment family, condensing unit configuration, and 

designed operating temperature. The MDEC limit for each compartment shall be the 

calculated value obtained by entering that compartment’s TDA or volume into the 

standard equation for that compartment’s equipment class. Measure the calculated 

daily energy consumption (CDEC) or total daily energy consumption (TDEC) for 

the entire case as follows: 

o For remote condensing commercial hybrid refrigerators, hybrid freezers, 

hybrid refrigerator-freezers, and non-hybrid refrigerator-freezers, where two 

or more independent condensing units each separately cool only one 

compartment, measure the total refrigeration load of each compartment 

separately according to the ANSI/ASHRAE Standard 72-2005 test 

procedure. Calculate compressor energy consumption (CEC) for each 

compartment using Table 1 in ARI Standard 1200-2006 using the saturated 

evaporator temperature for that compartment. The calculated daily energy 

consumption (CDEC) for the entire case shall be the sum of the CEC for each 

compartment, fan energy consumption (FEC), lighting energy consumption 

(LEC), anti-condensate energy consumption (AEC), defrost energy 

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consumption (DEC), and condensate evaporator pan energy consumption 

(PEC) (as measured in ARI Standard 1200-2006). 

o For remote condensing commercial hybrid refrigerators, hybrid freezers, 

hybrid refrigerator-freezers, and non-hybrid refrigerator-freezers, where two 

or more compartments are cooled collectively by one condensing unit, 

measure the total refrigeration load of the entire case according to the 

ANSI/ASHRAE Standard 72-2005 test procedure. Calculate a weighted 

saturated evaporator temperature for the entire case by (i) multiplying the 

saturated evaporator temperature of each compartment by the volume of that 

compartment (as measured in ARI Standard 1200-2006), (ii) summing the 

resulting values for all compartments, and (iii) dividing the resulting total by 

the total volume of all compartments. Calculate the CEC for the entire case 

using Table 1 in ARI Standard 1200-2006, using the total refrigeration load 

and the weighted average saturated evaporator temperature. The CDEC for 

the entire case shall be the sum of the CEC, FEC, LEC, AEC, DEC, and 

PEC. 

o For self-contained commercial hybrid refrigerators, hybrid freezers, hybrid 

refrigerator-freezers, and non-hybrid refrigerator-freezers, measure the total 

daily energy consumption (TDEC) for the entire case according to the 

ANSI/ASHRAE Standard 72-2005 test procedure. 

In response to the NOPR, Traulsen suggested that DOE address commercial 

refrigerator-freezers by summing the maximum daily energy consumption values for all of 

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its individual compartments. (Traulsen, No. 25 at p. 2) 

DOE agrees with this suggestion and notes that it is in alignment with the proposal 

in the August 2008 NOPR for commercial refrigeration equipment with two or more 

compartments. Therefore, DOE is adopting the language above for hybrid cases, 

refrigerator-freezers, and hybrid refrigerator freezers in its final rule. 

Additionally, DOE is adopting the following language to address wedge cases: 

For remote condensing and self-contained wedge cases, measure the CDEC or TDEC 

according to the ANSI/ARI 1200-2006 test procedure. The MDEC for each model shall be 

the amount derived by incorporating into the standard equation for the appropriate 

equipment class a value for the TDA that is the product of: (1) the vertical height of the air 

curtain (or glass in a transparent door), and (2) the largest overall width of the case when 

viewed from the front. 

B. Significance of Energy Savings

To estimate the energy savings through 2042 due to new standards, DOE compared 

the energy consumption of commercial refrigeration equipment under the base case (no 

standards) to energy consumption of this equipment under each TSL that DOE considered. 

Table VI-4 shows DOE’s NES estimates, which it based on the AEO2008 reference case, 

for each TSL. Chapter 11 of the TSD describes these estimates in more detail. DOE reports 

both undiscounted and discounted values of energy savings. Discounted energy savings 

represent a policy perspective where energy savings farther in the future are less significant 

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than energy savings closer to the present. Each TSL considered in this rulemaking resulted 

in significant energy savings, and the amount of savings increased with higher energy 

conservation standards. Energy savings ranged from an estimated 0.168 quads to 1.298 

quads for TSLs 1 through 5 (undiscounted). 

Table VI-4 Summary of Cumulative National Energy Savings for Commercial 

Refrigeration Equipment (Energy Savings for Units Sold from 2012 to 2042) 

Primary National Energy Savings (quads) 

Trial Standard Level (sum of all equipment classes)

Undiscounted 3% Discounted 7% Discounted

1 0.168 0.088 0.041 

2 0.645 0.339 0.159 

3 1.013 0.532 0.250 

4 1.035 0.544 0.256 

5 1.298 0.683 0.321 

C. Economic Justification

1. Economic Impact on Commercial Customers 

a. Life-Cycle Costs and Payback Period 

Commercial customers will be affected by the standards because they will 

experience higher purchase prices and lower operating costs. Generally, these impacts are 

best captured by changes in life-cycle costs and payback period. Therefore, DOE calculated 

the LCC and PBP for the standard levels considered in this rulemaking. DOE’s LCC and 

PBP analyses provided five key outputs for each TSL, reported in Table VI-5 through Table 

VI-19. The first three outputs are the proportion of purchases of commercial refrigeration 

equipment where the purchase of a design that complies with the TSL would create: (1) a 

net life-cycle cost, (2) no impact, or (3) a net life-cycle savings for the consumer. The fourth 

output is the average net life-cycle savings from purchasing a complying design. The fifth 

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output is the average PBP for the customer purchasing a design that complies with the TSL 

compared with purchasing baseline equipment. The PBP is the number of years it would 

take for the customer to recover the increased costs of higher-efficiency equipment through 

energy savings based on the operating cost savings from the first year of ownership. The 

PBP is an economic benefit-cost measure that uses benefits and costs without discounting. 

Table VI-5 Summary LCC and PBP Results for VOP.RC.M Equipment Class

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 99 

Equipment with No Change in LCC (%) 64 46 29 29 1 

Equipment with Net LCC Savings (%) 36 54 71 71 0 

Mean LCC Savings ($)* 1,344 1,308 1,788 1,788 (3,959) 

Mean Payback Period (years) 0.8 1.3 2.0 2.0 138.1 

* Numbers in parentheses indicate negative savings. 

Table VI-6 Summary LCC and PBP Results for VOP.RC.L Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 69 52 23 8 8 

Equipment with Net LCC Savings (%) 31 48 77 92 92 

Mean LCC Savings ($) 3,501 4,500 4,610 3,938 3,938 

Mean Payback Period (years) 0.7 1.1 1.2 2.8 2.8 

Table VI-7 Summary LCC and PBP Results for VOP.SC.M Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 69 

Equipment with No Change in LCC (%) 67 35 21 21 1 

Equipment with Net LCC Savings (%) 33 65 79 79 30 

Mean LCC Savings ($) 842 1,209 1,549 1,549 (451) 

Mean Payback Period (years) 0.8 1.6 2.4 2.4 11.2 

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Table VI-8 Summary LCC and PBP Results for VCT.RC.M Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 80 60 17 8 8 

Equipment with Net LCC Savings (%) 20 40 83 92 92 

Mean LCC Savings ($) 320 657 2,375 2,339 2,339 

Mean Payback Period (years) 0.8 1.3 3.8 3.9 3.9 

Table VI-9 Summary LCC and PBP Results for VCT.RC.L Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 62 43 20 10 10 

Equipment with Net LCC Savings (%) 38 57 80 90 90 

Mean LCC Savings ($) 762 4,137 5,450 5,419 5,419 

Mean Payback Period (years) 1.1 2.4 2.5 2.6 2.6 

Table VI-10 Summary LCC and PBP Results for VCT.SC.I Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 55 41 20 9 9 

Equipment with Net LCC Savings (%) 45 59 80 91 91 

Mean LCC Savings ($) 2,941 4,893 5,234 5,217 5,217 

Mean Payback Period (years) 1.0 1.5 1.6 1.7 1.7 

Table VI-11 Summary LCC and PBP Results for VCS.SC.I Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 76 50 11 11 11 

Equipment with Net LCC Savings (%) 24 50 89 89 89 

Mean LCC Savings ($) 704 1,321 1,757 1,757 1,757 

Mean Payback Period (years) 0.4 0.6 1.3 1.3 1.3 

Table VI-12 Summary LCC and PBP Results for SVO.RC.M Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 99 

Equipment with No Change in LCC (%) 65 47 30 30 1 

Equipment with Net LCC Savings (%) 35 53 70 70 0 

Mean LCC Savings ($) 907 896 1,274 1,274 (2,974) 

Mean Payback Period (years) 0.8 1.3 1.9 1.9 196.8 

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Table VI-13 Summary LCC and PBP Results for SVO.SC.M Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 69 

Equipment with No Change in LCC (%) 68 36 22 22 2 

Equipment with Net LCC Savings (%) 32 64 78 78 29 

Mean LCC Savings ($) 583 853 1,136 1,136 (355) 

Mean Payback Period (years) 0.6 1.4 2.3 2.3 11.5 

Table VI-14 Summary LCC and PBP Results for SOC.RC.M Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 92 

Equipment with No Change in LCC (%) 82 64 29 29 3 

Equipment with Net LCC Savings (%) 18 36 71 71 5 

Mean LCC Savings ($) 405 851 945 945 (1,458) 

Mean Payback Period (years) 0.5 0.8 1.7 1.7 19.4 

Table VI-15 Summary LCC and PBP Results for HZO.RC.M Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 80 60 39 19 19 

Equipment with Net LCC Savings (%) 20 40 61 81 81 

Mean LCC Savings ($) 419 887 1,063 1,040 1,040 

Mean Payback Period (years) 0.5 0.8 1.2 1.6 1.6 

Table VI-16 Summary LCC and PBP Results for HZO.RC.L Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 59 39 19 19 19 

Equipment with Net LCC Savings (%) 41 61 81 81 81 

Mean LCC Savings ($) 668 1,047 1,102 1,102 1,102 

Mean Payback Period (years) 1.0 1.4 1.6 1.6 1.6 

Table VI-17 Summary LCC and PBP Results for HZO.SC.M Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 73 45 21 10 10 

Equipment with Net LCC Savings (%) 27 55 79 90 90 

Mean LCC Savings ($) 344 615 861 826 826 

Mean Payback Period (years) 0.4 1.0 1.8 2.3 2.3 

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Table VI-18 Summary LCC and PBP Results for HZO.SC.L Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 73 46 21 10 10 

Equipment with Net LCC Savings (%) 27 54 79 90 90 

Mean LCC Savings ($) 670 1,215 1,784 1,761 1,761 

Mean Payback Period (years) 0.3 0.8 1.5 1.7 1.7 

Table VI-19 Summary LCC and PBP Results for HCT.SC.I Equipment Class 

Trial Standard Level 

1 2 3 4 5 

Equipment with Net LCC Increase (%) 0 0 0 0 0 

Equipment with No Change in LCC (%) 65 47 30 14 14 

Equipment with Net LCC Savings (%) 35 53 70 86 86 

Mean LCC Savings ($) 211 775 797 785 785 

Mean Payback Period (years) 0.6 1.4 1.5 1.9 1.9 

 For five equipment classes (VOP.RC.M, VOP.SC.M, SVO.RC.M, SVO.SC.M, and 

SOC.RC.M), TSL 5 resulted in negative LCC savings compared to the purchase of baseline 

equipment. For all other equipment classes, TSL 5 showed positive LCC savings. For 

equipment classes with lighting, including LED lighting at TSL 5 had a significant impact 

on the calculated LCC savings. For equipment classes without lighting (i.e., VCS.SC.I, 

HZO.RC.L, HZO.SC.M, HZO.SC.L, and HCT.SC.I), the difference in LCC savings 

between TSL 3 and TSL 5 was small, between $0 and $35 less at TSL 5 than at TSL 3. For 

VCT.RC.L, VCT.RC.I, and VCT.SC.I, the difference in LCC savings between TSL 3 and 

TSL 5 was small as well (between $17 and $36 less savings at TSL 5 than at TSL 3). 

VOP.RC.L showed a more significant reduction in LCC savings at TSL 5 compared to TSL 

3 at $672. 

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b. Commercial Customer Sub-Group Analysis 

Using the LCC spreadsheet model, DOE estimated the impact of the TSLs on small 

businesses, a customer sub-group. DOE estimated the LCC and PBP for small food sales 

businesses defined by the Small Business Administration (SBA) by presuming that most 

small business customers could be represented by the analysis performed for small grocery 

and convenience store owners. DOE further assumed that the smaller, independent grocery 

and convenience store chains may not have access to national accounts, but would instead 

purchase equipment primarily through distributors and grocery wholesalers. DOE modified 

the distribution channels for remote condensing and self-contained equipment to these small 

businesses as follows: 

• For remote condensing equipment, 15 percent of the sales were assumed to 

pass through a manufacturer-to-distributor-to-contractor-to-customer 

channel, and 85 percent were assumed to be purchased through a 

manufacturer-to-distributor-to-customer channel. 

• For self-contained equipment, 35 percent of sales were assumed to pass 

through a manufacturer-to-distributor-to-contractor-to-customer channel, and 

65 percent were assumed to be purchased through a manufacturer-todistributor-to-customer channel. 

In both cases, the distribution chain markups were calculated with these revised 

shipment weights. Table VI-20 shows the mean LCC savings from proposed energy 

conservation standards for the small business sub-group, and Table VI-21 shows the mean 

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payback period (in years) for this sub-group. More detailed discussion on the LCC subgroup analysis and results can be found in chapter 12 of the TSD. 

Table VI-20 Mean Life-Cycle Cost Savings for Commercial Refrigeration 

Equipment Purchased by LCC Sub-Group (Small Business) (2007$)*

Equipment Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

VOP.RC.M 1,746 1,764 2,443 2,443 (3,463) 

VOP.RC.L 4,534 5,882 6,064 5,549 5,549 

VOP.SC.M 1,094 1,624 2,145 2,145 131 

VCT.RC.M 416 868 3,484 3,458 3,458 

VCT.RC.L 1,001 5,639 7,454 7,447 7,447 

VCT.SC.I 3,811 6,451 6,944 6,949 6,949 

VCS.SC.I 902 1,703 2,314 2,314 2,314 

SVO.RC.M 1,177 1,209 1,738 1,738 (2,637) 

SVO.SC.M 752 1,138 1,565 1,565 61 

SOC.RC.M 521 1,106 1,290 1,290 (948) 

HZO.RC.M 538 1,152 1,397 1,383 1,383 

HZO.RC.L 875 1,383 1,466 1,466 1,466 

HZO.SC.M 440 803 1,156 1,129 1,129 

HZO.SC.L 857 1,574 2,364 2,352 2,352 

HCT.SC.I 272 1,022 1,055 1,057 1,057 *

 Numbers in parentheses indicate negative savings. 

Table VI-21 Mean Payback Period for Commercial Refrigeration Equipment 

Purchased by LCC Sub-Group (Small Business) (Years) 

Equipment Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

VOP.RC.M 0.71 1.19 1.77 1.77 51.97 

VOP.RC.L 0.64 0.99 1.10 2.53 2.53 

VOP.SC.M 0.70 1.43 2.17 2.17 9.50 

VCT.RC.M 0.73 1.14 3.54 3.64 3.64 

VCT.RC.L 1.00 2.17 2.32 2.42 2.42 

VCT.SC.I 0.90 1.32 1.47 1.57 1.57 

VCS.SC.I 0.33 0.53 1.17 1.17 1.17 

SVO.RC.M 0.70 1.19 1.73 1.73 106.71 

SVO.SC.M 0.55 1.26 2.09 2.09 9.71 

SOC.RC.M 0.48 0.75 1.55 1.55 15.62 

HZO.RC.M 0.46 0.72 1.13 1.47 1.47 

HZO.RC.L 0.93 1.26 1.50 1.50 1.50 

HZO.SC.M 0.36 0.92 1.66 2.06 2.06 

HZO.SC.L 0.29 0.71 1.35 1.55 1.55 

HCT.SC.I 0.58 1.24 1.32 1.74 1.74 

For commercial refrigeration equipment, the LCC and PBP impacts for small 

businesses are similar to those of all customers as a whole. While the discount rate for small 

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grocery stores is higher than the rate for commercial refrigeration equipment customers as a 

whole and equipment prices are higher due to the higher markups, these small business 

customers appear to retain commercial refrigeration equipment over longer periods. Also, 

smaller stores generally tend to pay higher electric prices. The average LCC savings for the 

small business sub-group is slightly higher than that calculated for the average commercial 

refrigeration equipment customer, and the average PBP is slightly shorter than the national 

average. DOE concluded that the small food sales businesses defined by SBA will not 

experience economic impacts significantly different or more negative than those impacts on 

food sales businesses as a whole. 

2. Economic Impact on Manufacturers 

DOE determined the economic impacts of today’s standard on manufacturers, as 

described in the proposed rule. 73 FR at 50118-21. For the final rule, DOE analyzed 

manufacturer impacts under two distinct markup scenarios: (1) the preservation-of-grossmargin-percentage markup scenario, and (2) the preservation-of-gross-margin (absolute 

dollars) markup scenario. 73 FR 50107. Under the first scenario, DOE applied a single 

uniform “gross margin percentage” markup that represents the current markup for 

manufacturers in the commercial refrigeration equipment industry. This markup scenario 

implies that as production costs increase with efficiency, the absolute dollar markup will 

also increase. DOE calculated that the non-production cost markup—which consists of 

selling, general, and administrative (SG&A) expenses; research and development (R&D) 

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expenses; interest; and profit—is 1.32. This markup is consistent with the one DOE used in 

its engineering and GRIM analyses for the base case. 

The implicit assumption behind the second scenario is that the industry can only 

maintain its gross margin from the baseline (in absolute dollars) after the standard. The 

industry would do so by passing its increased production costs on to customers without 

passing on its increased R&D and SG&A expenses so the gross profit per unit is the same in 

absolute dollars. DOE implemented this markup scenario in the GRIM by setting the 

production cost markups at each TSL to yield approximately the same gross margin in the 

standards cases in 2012 as they yielded in the base case. 

Together, these two markup scenarios characterize the range of possible conditions 

the commercial refrigeration equipment market will experience as a result of new energy 

conservation standards. See chapter 13 of the TSD for additional details of the markup 

scenarios and analysis. DOE also examined both of these scenarios for this final rule. 

a. Industry Cash-Flow Analysis Results 

Using two different markup scenarios, 73 FR at 50107, 50118-20, DOE estimated 

the impact of new standards for commercial refrigeration equipment on the INPV of the 

commercial refrigeration equipment industry. The impact consists of the difference between 

INPV in the base case and INPV in the standards case. INPV is the primary metric used in 

the MIA, and represents one measure of the fair value of the industry in today’s dollars. 

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DOE calculated the INPV by summing all of the net cash flows, discounted at the 

commercial refrigeration equipment industry’s cost of capital or discount rate. 

Table VI-22 and Table VI-23 show the changes in INPV that DOE estimates would 

result from the TSLs DOE considered for this final rule. The tables also present the 

equipment conversion expenses and capital investments that the industry would incur at 

each TSL. Product conversion expenses include engineering, prototyping, testing, and 

marketing expenses incurred by a manufacturer as it prepares to comply with a standard. 

Capital investments are the one-time outlays for tooling and plant changes required for the 

industry to comply (i.e., conversion capital expenditures). 

Table VI-22 Manufacturer Impact Analysis Results, Including INPV Estimates, for 

Commercial Refrigeration Equipment Under the Preservation of Gross Margin 

Percentage Markup Scenario 

Preservation of Gross Margin Percentage Markup Scenario with a Rollup Shipment Scenario 

Trial Standard Level 

 Units Base 

Case 1 2 3 4 5 

INPV 2007$ 

millions 540 540 548 530 501 560 

2007$ 

millions - 0 8 (11) (39) 20 Change in INPV* 

(%) - 0.02 1.42 (1.95) (7.29) 3.73 

New Energy 

Conservation Standards 

Equipment Conversion 

Expenses 

2007$ 

millions - 0.5 2.8 20.6 40.4 51.6 

New Energy 

Conservation Standards 

Capital Investments 

2007$ 

millions - 0.8 5.0 36.3 71.2 90.8 

Total Investment 

Required 

2007$ 

millions - 1.3 7.8 57.0 111.6 142.4 

* Values in Table VI-22 may not appear to sum due to rounding. 

Table VI-23 Manufacturer Impact Analysis Results, Including INPV Estimates, for 

Commercial Refrigeration Equipment Under the Preservation of Gross Margin 

(Absolute Dollars) Markup Scenario 

Preservation of Gross Margin Absolute Dollars Markup Scenario 

with a Rollup Shipment Scenario 

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Trial Standard Level 

 Units Base 

Case 1 2 3 4 5 

INPV 2007$ 

millions 540 533 502 442 392 200 

2007$ 

millions - (7) (39) (99) (148) (340) Change in INPV* 

(%) - (1.27) (7.16) (18.26) (27.35) (63.01) 

New Energy 

Conservation Standards 

Equipment Conversion 

Expenses 

2007$ 

millions - 0.5 2.8 20.6 40.4 51.6 

New Energy 

Conservation Standards 

Capital Investments 

2007$ 

millions - 0.8 5.0 36.3 71.2 90.8 

Total Investment 

Required 

2007$ 

millions - 1.3 7.8 57.0 111.6 142.4 

* Values in Table VI-23 may not appear to sum due to rounding. 

The August 2008 NOPR discusses the estimated impact of new commercial 

refrigeration equipment standards on INPV for each equipment class. 73 FR 50118–20. See 

chapter 13 of the TSD for details. 

b. Cumulative Regulatory Burden 

DOE’s assesses manufacturer burden through the cumulative impact of multiple 

DOE standards and other regulatory actions that affect manufacturers of the same covered 

equipment and other equipment produced by the same manufacturers or their parent 

companies. 73 FR at 50120. For the August 2008 NOPR, DOE listed the EPA-mandated 

phaseout of HCFCs as refrigerants and blowing agents, and energy conservation standards 

for residential central air conditioners and heat pumps and room air conditioners as 

examples of other Federal regulations that could affect manufacturers of commercial 

refrigeration equipment. 73 FR 50120. 

 

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Following the August 2008 NOPR, public comments made DOE aware that 

commercial refrigeration equipment manufacturers must test equipment using the NSF 7 test 

procedure in addition to the DOE test procedure. As mentioned previously, NSF 7 measures 

product temperature for food safety requirements, while the DOE test procedure measures 

energy consumption for energy conservation standards. Although NSF 7 is not a Federal 

regulation, the commercial refrigeration equipment industry in general already tests its 

equipment using this procedure to meet food safety requirements. 

For this final rule, DOE also identified the other DOE regulations commercial 

refrigeration equipment manufacturers are facing for other equipment. DOE identified 

several regulations that go into effect 3 years before and after the effective date of the new 

energy conservation standards for commercial refrigeration equipment. DOE recognizes that 

each regulation can significantly affect manufacturers’ financial operations. Multiple 

regulations affecting the same manufacturer can quickly reduce manufacturers’ profits and 

possibly cause an exit from the market. 

DOE requested information about the cumulative regulatory burden during 

manufacturer interviews. Manufacturers indicated that they had already begun using other 

non-HCFC refrigerants and blowing agents. Manufacturers did not indicate that the DOE 

regulations on residential central air conditioners and heat pumps or room air conditioners 

were a great concern. DOE sought comment on these and other potential regulations 

affecting manufacturers for the final rule. From its own research, DOE learned that 

manufacturers of commercial refrigeration equipment or their parent companies could also 

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be affected by rulemakings on PTACs and PTHPs, room air conditioners, residential 

furnaces, and walk-in freezers and coolers. DOE identified the costs of additional 

regulations when these estimates were available from other DOE rulemakings. For example, 

two commercial refrigeration equipment manufacturers (or their parent companies) also 

manufacture PTACs and PTHPs. DOE estimated that in the PTAC and PTHP industry, 

manufacturers may incur an estimated total conversion expense of $17.3 million (2007$). 

However, DOE has limited data on the importance of these other regulated products for 

manufacturers of commercial refrigeration equipment. Differences in market shares and 

manufacturing processes of other regulated products for each manufacturer could cause 

varying degrees of burdens on these manufacturers. See chapter 13 of the TSD for 

additional information regarding the cumulative regulatory burden analysis. 

c. Impacts on Employment 

As discussed in the August 2008 NOPR, DOE expects that employment by 

commercial refrigeration equipment manufacturers would increase under all of the TSLs 

considered for today’s rule. However, this does not take into account any relocation of 

domestic jobs to countries with lower labor costs that might be influenced by the level of 

investment required by new standards. 73 FR at 50120-21. Table VI-24 shows the direct 

employment impacts at each TSL. Further support for this conclusion is set forth in chapter 

13 of the TSD. 

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Table VI-24 Commercial Refrigeration Equipment Estimated Employment 

Impacts in 2012 

Trial Standard Level Base 

Case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

Total Number of Domestic Production 

Employees in 2012 2,199 2,205 2,291 2,371 2,396 2,978 

Change in Total Number of Domestic 

Production Employees in 2012 Due to 

Standards* 

- 6 92 172 197 779 

Total Number of Domestic NonProduction Employees in 2012* 681 683 709 734 742 922 

Total Number of Domestic Employees 

in 2012* 2,880 2,888 3,000 3,105 3,137 3,900 

* Figures do not take into account any relocation of domestic jobs to countries with lower labor costs that 

might be influenced by the level of investment required by new standards. 

d. Impacts on Manufacturing Capacity 

According to the majority of commercial refrigeration equipment manufacturers, 

new energy conservation standards will not significantly affect manufacturers’ production 

capacity. Any necessary redesign of commercial refrigeration equipment will not change the 

fundamental assembly of the equipment. However, manufacturers anticipate some minor 

changes to tooling. Thus, manufacturers will be able to maintain manufacturing capacity 

levels and continue to meet market demand under new energy conservation standards. 

e. Impacts on Manufacturers That Are Small Businesses 

As discussed in the August 2008 NOPR, DOE expects today’s standard to have little 

or no differential impact on small manufacturers of commercial refrigeration equipment. 73 

FR at 50121, 50130-31. DOE found that small manufacturers generally have the same 

concerns as large manufacturers regarding energy conservation standards. DOE also found 

no significant differences in the R&D emphasis or marketing strategies between small and 

large manufacturers. Therefore, DOE believes the GRIM analysis, which models each 

equipment class separately and aggregates the results to produce an industry-wide impact, is 

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representative of the small manufacturers that would be affected by standards. The impacts 

on small manufacturers are discussed further in section VII.B of this preamble (“Review 

Under the Regulatory Flexibility Act”). 

3. National Net Present Value and Net National Employment 

The NPV analysis estimates the cumulative benefits or costs to the Nation that 

would result from particular standard levels. While the NES analysis estimates the energy 

savings from each standard level DOE considers, relative to the base case, the NPV analysis 

estimates the national economic impacts of each level relative to the base case. Table VI-25

provides an overview of the NPV results for each TSL considered for this final rule, using 

both a 7-percent and a 3-percent real discount rate. 

Table VI-25 shows the estimated cumulative NPV for commercial refrigeration 

equipment resulting from the sum of the NPV calculated for each of the 15 primary 

equipment classes analyzed. Table VI-25 assumes the AEO2008 reference case forecast for 

electricity prices. At a 7-percent discount rate, TSLs 1-4 show positive cumulative NPVs. 

The highest NPV is provided by TSL 3 at $1.45 billion. TSL 4 provided $1.41 billion, close 

to that of TSL 3. TSL 5 showed a negative NPV at -$2.59 billion, the result of negative 

NPV observed in five equipment classes (VOP.RC.M, VOP.SC.M, SVO.RC.M, 

SVO.SC.M, and SOC.RC.M). 

At a 3-percent discount rate, the picture is similar across the equipment classes. TSL 

5 showed a negative NPV at -$3.79 billion, whereas the highest NPV was provided at TSL 3 

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(i.e., $3.97 billion). TSL 4 provided a near equivalent NPV at $3.93 billion. TSL 5 provided 

a NPV of -$3.79 billion dollars. Five equipment classes (VOP.RC.M, VOP.SC.M, 

SVO.RC.M, SVO.SC.M, and SOC.RC.M) were determined to have negative NPVs at a 3- 

percent discount rate at TSL 5. See TSD chapter 11 for more detailed NPV results. 

Table VI-25 Overview of National Net Present Value Results 

NPV (billion 2007$) Trial Standard Level 7% Discount Rate 3% Discount Rate

1 0.33 0.83 

2 0.98 2.60 

3 1.45 3.97 

4 1.41 3.93 

5 (2.59) (3.79) 

DOE also estimated the national employment impacts that would result from each 

TSL. As discussed in the August 2008 NOPR, 73 FR at 50107-08, 50122-23, DOE expects 

the net monetary savings from standards to be redirected to other forms of economic 

activity. DOE also expects these shifts in spending and economic activity to affect the 

demand for labor. As shown in Table VI-26, DOE estimates net indirect employment 

impacts—those changes of employment in the larger economy (other than in the 

manufacturing sector being regulated)—from commercial refrigeration equipment energy 

conservation standards to be positive but very small relative to total national employment. 

These impacts might be offset by other, unanticipated effects on employment. For details on 

the employment impact analysis methods and results, see TSD chapter 15. 

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Table VI-26 Net National Change in Indirect Employment, Thousands of Jobs in 

2042 

Net National Change in Jobs Trial Standard Level 2012 2022 2032 2042

1 0 202 289 332

2 (6) 1,056 1,482 1,699

3 (15) 1,591 2,238 2,559

4 (18) 1,658 2,337 2,670

5 (40) 1,856 2,645 3,011

Maximum Job Impact (40) 1,856 2,645 3,011

4. Impact on Utility or Performance of Equipment 

As indicated in section V.B.4 of the August 2008 NOPR, the new standards DOE is 

adopting today will not lessen the utility or performance of any commercial refrigeration 

equipment. 73 FR at 50123. 

5. Impact of Any Lessening of Competition 

As discussed in the August 2008 NOPR, 73 FR at 50079, 50123, and in section 

III.D.1.e of this preamble, DOE considers any lessening of competition likely to result from 

standards. The Attorney General determines the impact, if any, of any lessening of 

competition. 

DOJ concluded that the commercial refrigeration equipment standards contained in 

the proposed rule would not adversely affect competition. In reaching this conclusion, DOJ 

noted that the proposed standards took into account comments from commercial 

refrigeration equipment manufacturers, ASHRAE, ACEEE, and electric utilities. DOJ noted 

further that all key components are available for purchase by any manufacturer; therefore, 

no manufacturer has a technological advantage in meeting the proposed standards. Finally, 

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DOJ noted that DOE found no significant differences between the concerns of large and 

small manufacturers, and DOJ found no evidence that certain manufacturers would be 

placed at a competitive disadvantage to other manufacturers. 

6. Need of the Nation to Conserve Energy 

When economically justified, an improvement in the energy efficiency of commercial 

refrigeration equipment is likely to improve the security of the Nation by reducing overall 

energy demand, thus reducing the Nation’s reliance on foreign sources of energy. Reduced 

demand is also likely to improve the reliability of the electricity system, particularly during 

peak-load periods. As a measure of this reduced demand, DOE expects the new standards 

covered under this rulemaking to eliminate the need for the construction of approximately 

121 megawatts to 2,989 megawatts of new power by 2042. 

Enhanced energy efficiency also produces environmental benefits. The expected 

energy savings from new standards for the equipment covered by this rulemaking will 

reduce the emissions of air pollutants and greenhouse gases associated with electricity 

production. Table VI-27 provides DOE’s estimate of cumulative CO2, NOX, and Hg 

emissions reductions that would result from the TSLs considered in this rulemaking. The 

expected energy savings from new standards for commercial refrigeration equipment may 

also reduce the cost of maintaining nationwide emissions standards and constraints. 

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Table VI-27 Summary of Emissions Reductions for Commercial Refrigeration 

Equipment (cumulative reductions for equipment sold from 2012 to 2042) 

Trial Standard Levels††

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

CO2 (Mt*) 8.5 32.8 50.7 52.6 66.0 

NOX (kt**) 0.59 to 14.58 2.27 to 56.04 3.51 to 86.77 3.64 to 89.97 4.56 to 112.84 

Hg (t†) 0 to 0.224 0 to 0.86 0 to 1.332 0 to 1.381 0 to 1.732 

* Mt = million metric tons 

** kt = thousand tons 

† t = tons 

†† Negative values indicate emission increases. Detail may not appear to sum to total due to rounding. 

 The estimated cumulative CO2, NOX, and Hg emissions reductions for the new 

energy conservation standards range up to 66 Mt for CO2, 1.56 to 112.84 kt for NOX, and 0 

to 1.732 t for Hg for commercial refrigeration equipment from 2012 to 2042. In the EA 

(chapter 16 of the TSD), DOE reports estimated annual changes in CO2, NOX, and Hg 

emissions attributable to each TSL. As discussed in section IV.L of this final rule, DOE 

does not report SO2 emissions reduction from power plants because reductions from an 

energy conservation standard would not affect the overall level of SO2 emissions in the 

United States due to emissions caps for SO2. 

The NEMS-BT modeling assumed that NOX would be subject to CAIR, issued by 

the U.S. Environmental Protection Agency on March 10, 2005.21 70 FR 25162 (May 12, 

2005). On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit 

(D.C. Circuit) issued its decision in North Carolina v. Environmental Protection Agency,

22

in which the court vacated the CAIR. 531 F.3d 896 (D.C. Cir. 2008). If left in place, CAIR 

would have permanently capped emissions of NOX in 28 eastern States and the District of 

Columbia. As with the SO2 emissions cap, a cap on NOX emissions would have meant that 

 

21 See www.epa.gov/cleanairinterstaterule. 22 Case No. 05-1244, 2008 WL 2698180 at *1 (D.C. Cir. July 11, 2008). 

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energy conservation standards are not likely to have a physical effect on NOX emissions in 

states covered by the CAIR caps. While the caps would have meant that physical emissions 

reductions in those States would not have resulted from the energy conservation standards 

that DOE is establishing today, the standards might have produced an environmental-related 

economic impact in the form of lower prices for emissions allowance credits, if large 

enough. DOE notes that the estimated total reduction in NOX emissions, including projected 

emissions or corresponding allowance credits in States covered by the CAIR cap, was 

insignificant and too small to affect allowance prices for NOX under CAIR. 

Even though the D.C. Circuit vacated CAIR, DOE notes that the D.C. Circuit left 

intact EPA's 1998 NOX SIP Call rule, which capped seasonal (summer) NOX emissions 

from electric generating units and other sources in 23 jurisdictions, and gave those 

jurisdictions the option to participate in a cap and trade program. 63 FR 57356, 57359 (Oct. 

27, 1998).23 The SIP Call rule may provide a similar, although less extensive, regional cap 

and may limit actual reduction in NOX emissions from revised standards occurring in states 

participating in the SIP Call rule. However, the possibility that the SIP Call rule may have 

the same effect as CAIR is highly uncertain. Therefore, DOE established a range of NOX

reductions due to the standards being established in today’s final rule. DOE’s low estimate 

 

23 In the NOx SIP Call rule, EPA found that sources in the District of Columbia and 22 “upwind” states were 

emitting NOx (an ozone precursor) at levels that significantly contributed to “downwind” states not attaining 

the ozone NAAQS or at levels that interfered with states in attainment maintaining the ozone NAAQS. To 

ensure that downwind states attain or continue to attain the ozone NAAQS, EPA established a region-wide cap 

for NOx emissions from certain large combustion sources and set a NOx emissions budget for each State. 

Unlike the cap that CAIR would have established, the NOx SIP Call Rule’s cap only constrains seasonal 

(summertime) emissions. To comply with the NOx SIP Call Rule, states could elect to participate in the NOx 

Budget Trading Program. Under this program, each emission source is required to have one allowance for each 

ton of NOx emitted during the ozone season. States have flexibility in how they allocate allowances through 

their State Implementation Plans, but states must remain within the EPA-established budget. Emission sources 

are allowed to buy, sell, and bank NOx allowances as appropriate. On April 16, 2008, EPA determined that 

Georgia is no longer subject to the NOx SIP Call rule. 73 FR 21528 (April 22, 2008). 

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was based on the emission rate of the cleanest new natural gas combined-cycle power plant 

available for electricity generated, assuming that energy conservation standards would 

displace the generation of only the cleanest available fossil fuels. DOE used the emission 

rate, specified as 0.0341 t of NOX emitted per TWh of electricity generated, associated with 

an advanced natural gas combined-cycle power plant, as specified by NEMS-BT. To 

estimate the reduction in NOX emissions, DOE multiplied this emission rate by the 

reduction in electricity generation due to the new energy conservation standards considered. 

DOE’s high estimate of 0.843 t of NOX per TWh was based on a nationwide NOX emission 

rate for all electrical generation. Use of such an emission rate assumes that future power 

plants displaced are no cleaner than the plants that are being used currently to generate 

electricity. Under the high estimate assumption, energy conservation standards also would 

have little to no effect on the generation mix. Based on AEO2008 for 2006, when no 

regulatory or non-regulatory measures were in effect to limit NOX emissions, DOE 

multiplied this emission rate by the reduction in electricity generation due to the standards 

considered. Table VI-27 shows the range in NOX emission changes calculated using the low 

and high estimate scenarios by TSL. NOX emission reductions range from 0.59 to 112.84 kt 

for the TSLs considered. These changes in NOX emissions are extremely small, ranging 

from 0.001 to 0.168 percent of the national base case emissions forecast by NEMS-BT, 

depending on the TSL. 

 As noted in section IV.L, DOE is able to report an estimate of the physical quantity 

changes in Hg emissions associated with an energy conservation standard. Rather than using 

the NEMS-BT model, DOE established a range of Hg rates to estimate the Hg emissions 

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that could be reduced through standards. DOE’s low estimate assumed that future standards 

would displace electrical generation from natural gas-fired power plants, resulting in an 

effective emission rate of zero. The low-end emission rate is zero because natural gas-fired 

power plants have virtually zero Hg emissions associated with their operation. 

DOE’s high estimate was based on a nationwide mercury emission rate from 

AEO2008. Because power plant emission rates are a function of local regulation, scrubbers, 

and the mercury content of coal, it is extremely difficult to identify a precise high-end 

emission rate. Therefore, DOE believes the most reasonable estimate is based on the 

assumption that all displaced coal generation would have been emitting at the average 

emission rate for coal generation as specified by AEO2008. As noted previously, because 

virtually all mercury emitted from electricity generation is from coal-fired power plants, 

DOE based the emission rate on the tons of mercury emitted per TWh of coal-generated 

electricity. Based on the emission rate for 2006, DOE derived a high-end emission rate of 

0.0255 tons per TWh. To estimate the reduction in mercury emissions, DOE multiplied the 

emission rate by the reduction in coal-generated electricity due to the standards considered 

in the utility impact analysis. The estimated changes in Hg emissions are shown in Table 

VI-27 for commercial refrigeration equipment from 2012 to 2042. Hg emission reductions 

range from 0 to 1.732 tons for the TSLs considered. These changes in Hg emissions are 

extremely small, ranging from 0 to 0.003 percent of the national base case emissions 

forecast by NEMS-BT, depending on the TSL. 

 The NEMS-BT model used for today’s rulemaking could not estimate Hg emission 

reductions due to new energy conservation standards, as it assumed that Hg emissions 

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would be subject to EPA’s Clean Air Mercury Rule24 (CAMR). CAMR would have 

permanently capped emissions of mercury for new and existing coal-fired plants in all states 

by 2010. As with SO2 and NOX, DOE assumed that under such a system, energy 

conservation standards would have resulted in no physical effect on these emissions, but 

might have resulted in an environmental-related economic benefit in the form of a lower 

price for emissions allowance credits, if large enough. DOE estimated that the change in the 

Hg emissions from energy conservation standards would not be large enough to influence 

allowance prices under CAMR. 

 On February 8, 2008, the D.C. Circuit issued its decision in New Jersey v. 

Environmental Protection Agency25 to vacate CAMR. In light of this development and 

because the NEMS-BT model could not be used to directly calculate Hg emission 

reductions, DOE used the current Hg emission rates discussed above to calculate the 

emissions reductions in Table VI-27. 

 In the August 2008 NOPR, DOE considered accounting for a monetary benefit of 

CO2 emission reductions associated with this rulemaking. To put the potential monetary 

benefits from reduced CO2 emissions into a form that is likely to be most useful to decisionmakers and interested parties, DOE used the same methods it used to calculate the net 

present value of consumer cost savings. DOE converted the estimated year-by-year 

reductions in CO2 emissions into monetary values, which were then discounted over the life 

of the affected equipment to the present using both 3-percent and 7-percent discount rates. 

 

24 70 FR 28606 (May 18, 2005). 

25 No. 05-1097, 2008 WL 341338, at * (D.C. Cir. Feb. 9, 2008). 

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In the August 2008 NOPR, DOE proposed to use the range $0 to $14 per ton. These 

estimates were based on an assumption of no benefit to an average benefit value reported by 

the Intergovernmental Panel on Climate Change (IPCC).26 DOE derived the IPCC estimate 

used as the upper bound value from an estimate of the mean value of worldwide impacts due 

to climate change, and not just the effects likely to occur within the United States. As DOE 

considers a monetary value for CO2 emission reductions, the value should, if possible, be 

restricted to a representation of those costs and benefits likely to be experienced in the 

United States. DOE explained in the August 2008 NOPR that it expects such values would 

be lower than comparable global values; however, there currently are no consensus 

estimates for the U.S. benefits likely to result from CO2 emission reductions. However, it is 

appropriate to use U.S. benefit values, where available, and not world benefit values, in its 

analysis.27 Because U.S.-specific estimates are unavailable, and DOE did not receive any 

additional information that would help narrow the proposed range of domestic benefits, 

DOE used the global mean value as an upper bound U.S. value for purposes of the 

sensitivity analysis. 

 

26 During the preparation of its most recent review of the state of climate science, the IPCC identified various 

estimates of the present value of reducing CO2 emissions by 1 ton over the life that these emissions would 

remain in the atmosphere. The estimates reviewed by the IPCC spanned a range of values. Absent a consensus 

on any single estimate of the monetary value of CO2 emissions, DOE used the estimates identified by the study 

cited in “Summary for Policymakers,” prepared by Working Group II of the IPCC’s Fourth Assessment 

Report, to estimate the potential monetary value of CO2 reductions likely to result from standards finalized in 

this rulemaking. According to IPCC, the mean social cost of carbon (SCC) reported in studies published in 

peer-reviewed journals was $43 per ton of carbon. This translates into about $12 per ton of CO2. The literature 

review (Tol 2005) from which this mean was derived did not report the year in which these dollars were 

denominated. However, DOE understands this estimate was denominated in 1995$. Updating that estimate to 

2007$ yields a SCC of $15 per ton of CO2. 27 In contrast, most of the estimated costs and benefits of increasing the efficiency of commercial refrigeration 

equipment include only economic values of impacts that would be experienced in the United States. DOE 

generally does not consider impacts on manufacturers that occur solely outside of the United States. 

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 DOE received several comments in response to the proposed estimated value of CO2

emissions reductions. In a comment submitted by Earthjustice on behalf of itself and 

NRDC, Earthjustice questioned both the upper and lower bounds of DOE’s range of 

estimated CO2 values, which it argued were too low. (Earthjustice, No. 38 at p. 7) 

Earthjustice also stated that it would be inappropriate to limit the consideration to the value 

of CO2 to a domestic value. (Earthjustice, No. 38 at p. 13) Earthjustice suggested that DOE 

consider relying on the estimate used in DOE’s analysis of the impacts of the LiebermanWarner Climate Security Act of 2007 (S. 2191).28 (Earthjustice, No. 38 at p. 2) AHRI stated 

that DOE should not rely on the IPCC study or values under the European Union cap and 

trade program, because such a program has not yet been established in the United States. 

(AHRI, No. 33 at p. 6) 

 Given the uncertainty surrounding estimates of the social cost of carbon, relying on 

any single estimate may be inadvisable because any estimate will depend on many 

assumptions. Working Group II’s contribution to the Fourth Assessment Report of the IPCC 

notes the following: 

The large ranges of SCC are due in the large part to differences in assumptions 

regarding climate sensitivity, response lags, the treatment of risk and equity, 

 

28 According to Earthjustice’s analysis of the Lieberman-Warner Climate Security Act of 2007, 

implementation of this legislation would lead to a CO2 allowance price of $30 per ton in 2020, rising to $61 

per ton in 2030. 

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economic and non-economic impacts, the inclusion of potentially catastrophic 

losses, and discount rates.29

Because of this uncertainty, DOE used the SCC value from Tol (2005), which was 

presented in the IPCC’s Fourth Assessment Report and provided a comprehensive metaanalysis of estimates for the value of SCC. Earthjustice commented that this value was out 

of date, because Tol released an update of his 2005 meta-analysis in September 2007. This 

update reported an increase in his mean estimate of SCC from $43 to $71/ton carbon. 

Earthjustice stated that DOE should not continue to use old data and should update its 

sources. (Earthjustice, No. 38 at p. 9) 

Although the Tol study was updated in 2007, the IPCC has not adopted the updated 

Tol study for its report. As a result, DOE continues to rely on the same study used by the 

IPCC. Moreover, DOE notes that the conclusions of Tol (2007) are similar to the 

conclusions of Tol (2005). Tol (2007) continues to indicate that there is no consensus 

regarding the monetary value of reducing CO2 emissions by 1 ton. The broad range of 

values in both Tol studies are the result of significant differences in the methodologies used 

in the studies Tol summarized. According to Tol, all of the studies have shortcomings, 

largely because the subject is inherently complex and uncertain and requires broad 

multidisciplinary knowledge. Thus, it is not certain that the values reported in Tol (2007) are 

more accurate or representative than the values reported in Tol (2005). 

 

29 Climate Change 2007 – Impacts, Adaptation and Vulnerability. Contribution of Working Group II to the 

Fourth Assessment Report of the IPCC, 17. Available at www.ipcc-wg2.org (last accessed Aug. 7, 2008). 

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In today’s final rule, DOE is relying on the range of values proposed in the August 

2008 NOPR, which was based on the values presented in Tol (2005), as proposed. DOE 

does note that DOE mistakenly assumed that the values presented in Tol (2005) were in 

2000 dollars. In actuality, the values in Tol (2005) were indicated to be approximately 1995 

values in 1995 dollars. Had DOE at the NOPR stage applied the correct dollar year of the 

values presented in Tol (2005), DOE would have proposed the range of $0 to $15 in the 

August 2008 NOPR. Additionally, DOE has applied an annual growth rate of 2.4 percent to 

the value of SCC, as suggested by the IPCC Working Group II (2007, p. 822). This growth 

rate is based on estimated increases in damage from future emissions that published studies 

have reported. As a result, for today’s final rule, DOE is assigning a range for SCC of $0 to 

$20 ($2007) per ton of CO2 emissions. 

Earthjustice questioned the use of the mean estimated social cost of CO2 as an upper 

bound of the range. (Earthjustice, No. 38 at p. 9) However, the upper bound of the range 

DOE used is based on Tol (2005), which reviewed 103 estimates of SCC from 28 published 

studies. Tol concluded that when only peer-reviewed studies published in recognized 

journals are considered, “climate change impacts may be very uncertain but [it] is unlikely 

that the marginal damage costs of carbon dioxide emissions exceed $50 per ton carbon 

[comparable to a 2007 value of $20 per ton carbon dioxide when expressed in 2007 U.S. 

dollars with a 2.4 percent growth rate.]” 

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Earthjustice also questioned using $0 as the lower bound of DOE’s estimated range. 

(Earthjustice, No. 38 at p. 10) In setting a lower bound, DOE agrees with the IPCC Working 

Group II (2007) report that “significant warming across the globe and the locations of 

significant observed changes in many systems consistent with warming is very unlikely to 

be due solely to natural variability of temperatures or natural variability of the systems” (p. 

9), and thus tentatively concludes that a global value of zero for reducing emissions cannot 

be justified. However, it is reasonable to allow for the possibility that the U.S. portion of the 

global cost of CO2 emissions may be quite low. In fact, some of the studies examined by Tol 

(2005) reported negative values for the SCC. As stated in the August 2008 NOPR, DOE is 

using U.S. benefit values, and not world benefit values, in its analysis. Further, U.S. 

domestic values will be lower than the global values. Additionally, the statutory criteria in 

EPCA do not require consideration of global effects. Therefore, DOE is using a lower bound 

of $0 per ton of CO2 emissions in estimating the potential benefits of today’s final rule. 

Table VI-28 presents the resulting estimates of the potential range of net present 

value benefits associated with reducing CO2 emissions. 

Table VI-28 Estimates of Savings from CO2 Emissions Reductions Under Commercial 

Refrigeration Equipment Trial Standard Levels at a Seven-Percent Discount Rate and 

Three-Percent Discount Rate 

TSL Estimated Cumulative CO2

(Mt) Emission Reductions

Value of Estimated CO2

Emission Reductions (Million 

2007$) at 7% Discount Rate

Value of Estimated CO2

Emission Reductions (Million 

2007$) at 3% Discount Rate

1 8.52 $0 to $76.01 $0 to $154.73

2 32.76 $0 to $292.26 $0 to $594.94

3 50.71 $0 to $452.49 $0 to $921.1

4 52.59 $0 to $469.19 $0 to $955.1

5 65.95 $0 to $588.44 $0 to $1,197.85

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 DOE also investigated the potential monetary impact from today’s energy 

conservation standards of reducing SO2, NOX, and Hg emissions. As previously stated, 

DOE’s initial analysis assumed the presence of nationwide emission caps on SO2 and Hg, 

and caps on NOX emissions in the 28 states covered by CAIR. In the presence of these caps, 

DOE concluded that no physical reductions in power sector emissions would occur, but that 

the lower generation requirements associated with energy conservation standards could put 

downward pressure on the prices of emissions allowances in cap and trade markets. 

Estimating this effect is very difficult because of factors such as credit banking, which can 

change the trajectory of prices. DOE has further concluded that the effect from energy 

conservation standards on SO2 allowance prices is likely to be negligible, based on runs of 

the NEMS-BT model. See chapter 16 (Environmental Assessment) of the TSD for further 

details. 

 Because the courts have vacated the CAIR rule, projected annual NOX allowances 

from NEMS-BT are no longer relevant. In DOE’s subsequent analysis, NOX emissions are 

not controlled by a nationwide regulatory system. DOE estimated the national monetized 

benefits of NOX and Hg emissions reductions from today’s rule based on environmental 

damage estimates from the literature. Available estimates suggest a very wide range of 

monetary values for NOX emissions, ranging from $370 per ton to $3,800 per ton of NOX

from stationary sources, measured in 2001$,30 or a range of $432 per ton to $4,441 per ton 

in 2007$. 

 

30 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, 

Local, and Tribal Entities. Office of Management and Budget Office of Information and Regulatory Affairs, 

Washington, D.C. 

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DOE has conducted research for today’s final rule and determined that the basic 

science linking mercury emissions from power plants to impacts on humans is considered 

highly uncertain. However, DOE identified two estimates of the environmental damage of 

mercury based on two estimates of the adverse impact of childhood exposure to methyl 

mercury on IQ for American children, and subsequent loss of lifetime economic 

productivity resulting from these IQ losses. The high-end estimate is based on an estimate of 

the current aggregate cost of the loss of IQ in American children that results from exposure 

to mercury of U.S. power plant origin ($1.3 billion per year in year 2000$), which works out 

to $32.6 million per ton emitted per year (2007$).31 The low-end estimate was $664,000 per 

ton emitted in 2004$ or $729,000 per ton in 2007$, which DOE derived from a published 

evaluation of mercury control using different methods and assumptions from the first study, 

but also based on the present value of the lifetime earnings of children exposed.32 Table 

VI-29 and Table VI-30 present the resulting estimates of the potential range of present value 

benefits associated with reducing national NOX and Hg emissions . 

 

31 Trasande, L., et al., “Applying Cost Analyses to Drive Policy that Protects Children,” 1076 ANN. N.Y. 

ACAD. SCI. 911 (2006).

32 Ted Gayer and Robert Hahn, “Designing Environmental Policy: Lessons from the Regulation of Mercury 

Emissions,” Regulatory Analysis 05-01. AEI-Brookings Joint Center For Regulatory Studies, Washington, D.C., 2004. A 

version of this paper was published in the Journal of Regulatory Economics in 2006. The estimate was derived 

by back-calculating the annual benefits per ton from the net present value of benefits reported in the study. 

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Table VI-29 Estimates of Savings from Reducing NOX and Hg Emissions Under 

Commercial Refrigeration Equipment TSLs at a Seven-Percent Discount Rate 

TSL 

Estimated 

Cumulative NOX

(kt) Emission 

Reductions* 

Value of Estimated 

NOX Emission 

Reductions 

(Thousand 2007$) 

Estimated 

Cumulative 

Hg (tons) 

Emission 

Reductions* 

Value of Estimated Hg 

Emission Reductions 

(Thousand 2007$) 

1 0.59 to 14.58 $64 to $1,578 0 to 0.224 $0 to $46

2 2.27 to 56.04 $245 to $6,067 0 to 0.86 $0 to $177

3 3.51 to 86.77 $380 to $9,394 0 to 1.332 $0 to $274

4 3.64 to 89.97 $394 to $9,741 0 to 1.381 $0 to $284

5 4.56 to 112.84 $494 to $12,216 0 to 1.732 $0 to $356

* Values in Table VI-29 may not appear to sum to the cumulative values in Table VI-27 due to rounding. 

Table VI-30 Estimates of Savings from Reducing NOX and Hg Emissions Under 

Commercial Refrigeration Equipment TSLs at a Three-Percent Discount Rate. 

TSL 

Estimated 

Cumulative NOX

(kt) Emission 

Reductions* 

Value of Estimated 

NOX Emission 

Reductions 

(Thousand 2007$) 

Estimated 

Cumulative 

Hg (tons) 

Emission 

Reductions* 

Value of Estimated Hg 

Emission Reductions 

(Thousand 2007$) 

1 0.59 to 14.58 $135 to $3,329 0 to 0.224 $0 to $91

2 2.27 to 56.04 $518 to $12,799 0 to 0.86 $0 to $349

3 3.51 to 86.77 $802 to 19,815 0 to 1.332 $0 to $540

4 3.64 to 89.97 $831 to $20,547 0 to 1.381 $0 to $560

5 4.56 to 112.84 $1,042 to $25,769 0 to 1.732 $0 to $702

* Values in Table VI-30 may not appear to sum to the cumulative values in Table VI-27 due to rounding. 

7. Other Factors 

EPCA allows the Secretary of Energy, in determining whether a standard is 

economically justified, to consider any other factors that the Secretary deems to be relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)(VII) and 6316(e)(1)) Under this provision, DOE considered 

LCC impacts on identifiable groups of customers, such as customers of different business 

types who may be disproportionately affected by any national energy conservation standard 

level. DOE also considered the reduction in generated capacity that could result from the 

imposition of any national energy conservation standard level. 

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D. Conclusion

EPCA contains criteria for prescribing new or amended energy conservation 

standards. It provides that any such standard for commercial refrigeration equipment must 

be designed to achieve the maximum improvement in energy efficiency that the Secretary 

determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) 

and 42 U.S.C. 6316(e)(1)) As stated above, the Secretary must determine whether the 

benefits of the standards exceed its burdens considering the seven factors discussed in 

section II.A. (42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6316(e)(1)) A determination is not 

made based on any one of these factors in isolation. The Secretary must weigh each of these 

seven factors in total. Further, the Secretary may not establish a new or amended standard if 

such standard would not result in “significant conservation of energy.” (42 U.S.C. 

6295(o)(3)(B) and 42 U.S.C. 6316(e)(1)) 

In selecting today’s energy conservation standards for commercial refrigeration 

equipment, DOE started by examining the maximum technologically feasible levels to 

determine whether those levels were economically justified. Upon finding the maximum 

technologically feasible levels not to be justified, DOE analyzed the next lower TSL. DOE 

followed this procedure until it identified a TSL that is economically justified. 

Table VI-31 summarizes DOE’s quantitative analysis results for each TSL it 

considered for this final rule. This table presents the results or a range of results for each 

TSL, and will aid the reader in understanding the costs and benefits of each one. The range 

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of values for industry impacts represents the results for the different markup scenarios that 

DOE used to estimate manufacturer impacts. 

Table VI-31 Summary of Results Based Upon the AEO2008 Reference Case Energy 

Price Forecast* 

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

Primary Energy Saved (quads) 0.168 0.645 1.013 1.035 1.298 

7% Discount Rate 0.041 0.159 0.250 0.256 0.321 

3% Discount Rate 0.088 0.339 0.532 0.544 0.683 

Generation Capacity Reduction 

(GW)** (0.121) (0.465) (0.720) (0.747) (0.936) 

 $ 0.33 $ 0.98 $ 1.45 $1.414 $ (2.59) 

NPV (2007$billion) 

7% Discount Rate 

3% Discount Rate $ 0.83 $ 2.60 $ 3.97 $3.930 $ (3.79) 

Industry Impacts 

Industry NPV (2007$ million) 

Industry NPV (% change) 

0–(7) 

0–(1) 

8–(39) 

1–(7) 

(11)–(99) 

(2)–(18) 

(39)–(148) 

(7)–(27) 

20–(340) 

4–(63) 

Cumulative Emissions Impacts†

 CO2 (Mt) 8.52 32.76 50.71 52.59 65.95 

 NOX (kt) 0.59-14.58 2.27-56.04 3.51-86.77 3.64-89.97 4.56-112.84 

 Hg (t) 0-0.224 0-0.86 0-1.332 0-1.381 0-1.732 

Employment Impacts 

Indirect Employment Impacts 

(2042) 332 1,699 2,559 2,670 3,011 

Direct, Domestic Employment 

Impacts (2012) †† 6 92 172 197 779 

Life-Cycle Cost

 Net Savings (%) 18–45 36–65 61–89 70–92 0–92 

 Net Increase (%) 0–0 0–0 0–0 0–0 0–99 

 No Change (%) 55–82 35–64 11–39 8–30 1–19 

 Mean LCC Savings (2007$) 211–3501 615–4893 797–5450 785–5419 (3959)–5419 

 Mean PBP (years) 0.3–1.1 0.6–2.4 1.2–3.8 1.3–3.9 1.3–196.8 

* Parentheses indicate negative (-) values. For LCCs, a negative value means an increase in LCC by the 

amount indicated. 

** Change in installed generation capacity by 2042 based on AEO2008 Reference Case. 

†

 CO2 emissions impacts include physical reductions at power plants. NOX emissions impacts include physical 

reductions at power plants as well as production of emissions allowance credits where NOX emissions are 

subject to emissions caps. 

†† Change in total number of domestic production employees in 2012 due to standards. 

First, DOE considered TSL 5, the most efficient level for all equipment classes. TSL 

5 would likely save an estimated 1.298 quads of energy through 2042, an amount DOE 

considers significant. Discounted at 7 percent, the projected energy savings through 2042 

would be 0.321 quads. For the Nation as a whole, DOE projects that TSL 5 would result in a 

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net decrease of $2.59 billion in NPV, using a discount rate of 7 percent. Five equipment 

classes (VOP.RC.M, VOP.SC.M, SVO.RC.M, SVO.SC.M, and SOC.RC.M)) show negative 

NPV at TSL 5, primarily due the use of LED lighting for these cases.33 The emissions 

reductions at TSL 5 are 65.95 Mt of CO2 and up to 112.84 kt of NOX. DOE also estimates 

that under TSL 5, total generating capacity in 2042 will decrease compared to the base case 

by 0.936 gigawatts (GW). 

At TSL 5, DOE projects that the average commercial refrigeration equipment 

customer will experience a reduction in LCC compared to the baseline for 10 of the 15 

equipment classes analyzed, while they will experience an increase in LCC for five 

equipment classes (VOP.RC.M, VOP.SC.M, SVO.RC.M, SOC.RC.M). These equipment 

classes are the five that DOE showed had negative NPV. Mean LCC savings for all 15 

equipment classes vary from 

-$3,959 to $5,419. At TSL 5, DOE estimates the fraction of customers experiencing LCC 

increases will vary between 0 and 99 percent depending on equipment class. The mean 

payback period for the average commercial refrigeration equipment customer at TSL 5 

compared to the baseline level is projected to be between 1.3 and 196.8 years, depending on 

equipment class. 

At TSL 5, there is the risk of very large negative impacts on the industry if 

manufacturers’ profit margins are reduced. The investments required to modify all 

equipment lines at the max-tech levels are large. At this level, manufacturers have to make 

 

33 LED lighting for open cases was updated from the August 2008 NOPR to reflect LED lighting fixtures 

currently available for, and specific to, open cases. . DOE also increased the amount of LED lighting assumed 

for open cases. See section V.A.2.a and appendix B of the TSD. 

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costly changes to their production lines. In addition, the incremental cost of adding LED 

lights at TSL 5 are extremely large. Because customers put a much higher priority on 

marketing and displaying their goods than they do on energy efficiency, most manufacturers 

expressed a concern that they would be unable to fully recover the additional cost incurred 

when only manufacturing the most efficient equipment possible. If manufacturers are not 

able to fully pass along these large incremental production costs, the industry could lose up 

to 63 percent of the INPV. 

Although TSL 5 is the most efficient level and thus saves the most energy of all 

TSLs, four of the 15 equipment classes show a reduction in LCC compared to the baseline. 

The energy savings at TSL 5 would reduce installed generating capacity by 0.94 GW, or 

roughly 2.5 large, 400-MW power plants. DOE estimates the associated emissions 

reductions at 66 Mt of CO2. DOE concludes that at TSL 5, the benefits of energy savings, 

generating capacity reductions, and emission reductions would be outweighed by the 

economic burdens on customers as indicated by the net decrease in NPV, long payback 

periods of up to 197 years, and a drop in INPV of up to 63 percent. Consequently, DOE 

concludes that TSL 5 is not economically justified. 

DOE then considered TSL 4, which provides for all equipment classes the maximum 

efficiency levels that the analysis showed to have positive NPV to the Nation. DOE projects 

that the average commercial refrigeration equipment customer will experience a reduction in 

LCC compared to the baseline for all 15 equipment classes analyzed, ranging from $785 to 

$5,419 depending on equipment class. The mean payback period for the average 

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commercial refrigeration equipment customer at TSL 4 is projected to be between 1.3 and 

3.9 years compared to the purchase of baseline equipment. 

TSL 4 would likely save an estimated 1.035 quads of energy through 2042, an 

amount DOE considers significant. Discounted at 7 percent, the projected energy savings 

through 2042 would be 0.256 quads. For the Nation as a whole, DOE projects that TSL 4 

would result in a net increase of $1.41 billion in NPV, using a discount rate of 7 percent. 

The estimated emissions reductions at TSL 4 are 42.6 Mt of CO2 and up to 90 kt of NOX. 

Similar to TSL 5, there is a risk at TSL 4 of large negative impacts on the industry if 

manufacturers’ profit margins are reduced. The investments required at TSL 4 are also large 

because, based on the construction of the TSL, many equipment classes are at the max-tech 

level. Because a large portion of the equipment classes are at max-tech, the incremental 

manufacturing costs are also large. If manufacturers are not able to fully pass along these 

large incremental production costs, the industry could lose up to 27 percent of the INPV. 

After carefully considering the analysis and weighing the benefits and burdens of 

TSL 4, DOE concludes that the benefits of TSL 4 (in terms of energy savings to the Nation 

of 1.035 quads through 2042, economic benefits of $1.41 billion in NPV using a discount 

rate of 7 percent, significant environmental benefits in terms of reduced emissions from 

power plants, and national employment benefits) outweigh the burdens in terms of the range 

of possible reductions in INPV of up to 27 percent, and that TSL 4 represents the maximum 

improvement in energy efficiency that is technologically feasible and economically 

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justified. Therefore, DOE is adopting the energy conservation standards for this equipment 

at TSL 4. 

VII. Procedural Issues and Regulatory Review 

A. Review Under Executive Order 12866

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 

FR 51735 (October 4, 1993), requires each agency to identify in writing the market failure 

or other problem that it intends to address that warrants agency action such as today’s final 

rule, and to assess the significance of that problem in evaluating whether any new regulation 

is warranted. 

In the August 2008 NOPR for this rulemaking, DOE requested feedback related to 

the possible existence of a market failure in the commercial refrigeration equipment 

industry. Because the commercial refrigeration equipment industry is part of the food 

merchandising industry, energy efficiency and energy cost savings are not the primary 

drivers of the business. Selling food products to shoppers is the primary driver. It is difficult 

for store personnel to identify cost-effective efficiency levels for commercial refrigeration 

equipment given reasons identified in the NOPR, and doing so may incur transaction costs, 

thus reducing cost-effectiveness of the energy efficiency investment. 73 FR 50128. DOE 

sought data on the efficiency levels of existing commercial refrigeration equipment by 

owner, electricity price, and equipment class. Following the publication of the August 2008 

NOPR and subsequent public comment period, DOE did not receive any feedback related to 

this request. 

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Because today’s regulatory action is a significant regulatory action under section 

3(f)(1) of Executive Order 12866, section 6(a)(3) of the Executive Order requires DOE to 

prepare and submit for review to the Office of Information and Regulatory Affairs (OIRA) 

in OMB an assessment of the costs and benefits of today’s rule. Accordingly, DOE 

presented to OIRA for review the draft final rule and other documents prepared for this 

rulemaking, including a regulatory impact analysis (RIA). These documents are included in 

the rulemaking record and are available for public review in the Resource Room of DOE’s 

Building Technologies Program, 950 L’Enfant Plaza, SW., 6th Floor, Washington, DC 

20024, (202) 586–9127, between 9 a.m. and 4 p.m., Monday through Friday, except Federal 

holidays. 

The August 2008 NOPR contained a summary of the RIA, which evaluated the 

extent to which major alternatives to standards for commercial refrigeration equipment 

could achieve significant energy savings at reasonable cost, as compared to the effectiveness 

of the proposed rule. 73 FR 50128–29. The complete RIA (Regulatory Impact Analysis for 

Proposed Energy Conservation Standards for Commercial Refrigeration Equipment) is 

contained in the TSD prepared for today’s rule. 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 the feasible policy alternatives to this regulation, (3) a 

quantitative comparison of the impacts of the alternatives, and (4) the national economic 

impacts of today’s standards. 

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As explained in the August 2008 NOPR, none of the alternatives DOE examined 

would save as much energy or have an NPV as high as the proposed standards. That same 

conclusion applies to the standards in today’s rule. Also, several of the alternatives would 

require new enabling legislation, because authority to carry out those alternatives does not 

exist. Additional detail on the regulatory alternatives is found in the RIA report in the TSD. 

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, and a final regulatory flexibility analysis (FRFA) for any such rule that an 

agency adopts as a final rule, unless the agency certifies that the rule, if promulgated, will 

not have a significant economic impact on a substantial number of small entities. A 

regulatory flexibility analysis examines the impact of the rule on small entities and 

considers alternative ways of reducing negative impacts. Also, 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 and policies available on 

the Office of General Counsel’s website: www.gc.doe.gov. 

Small businesses, as defined by the Small Business Administration (SBA) for the 

commercial refrigeration equipment manufacturing industry, are manufacturing enterprises 

with 750 employees or fewer. DOE used the small business size standards published by 

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SBA to determine whether any small entities would be required to comply with the rule. 61 

FR 3286 and codified at 13 CFR part 121. The size standards are listed by North American 

Industry Classification System (NAICS) code and industry description. Commercial 

refrigeration equipment manufacturing is classified under NAICS 333415. 

DOE interviewed two of the nine manufacturers of commercial refrigeration 

equipment it identified as small businesses affected by this rulemaking. 73 FR at 50130. 

DOE reviewed the proposed rule under the provisions of the Regulatory Flexibility Act and 

the procedures and policies published on February 19, 2003. Id. On the basis of this review, 

DOE determined that it could not certify that the proposed standards (TSL 4) would have no 

significant economic impact on a substantial number of small entities. Id. DOE made this 

determination because of the potential impacts of the proposed standard levels on 

commercial refrigeration equipment manufacturers generally, including small businesses. 

Id. 

Because of these potential impacts on small manufacturers, DOE prepared an IRFA 

during the NOPR stage of this rulemaking. DOE provided the IRFA in its entirety in the 

August 2008 NOPR, 73 FR 50130–31, and also transmitted a copy to the Chief Counsel for 

Advocacy of the SBA for review. Chapter 13 of the TSD contains more information about 

the impact of this rulemaking on manufacturers. 

The IRFA divided potential impacts on small businesses into two broad categories: 

(1) impacts associated with commercial refrigeration equipment design and manufacturing, 

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and (2) impacts associated with the effect on customers’ ability to merchandise products by 

limiting the flexibility in choosing design options. The commercial refrigeration industry is 

highly customized, and manufacturers were concerned that limiting the choices in design 

options would commoditize the industry and reduce profit margins. However, this concern 

was echoed by all manufacturers, not just small business manufacturers. 

DOE has prepared a FRFA for this rulemaking, which is presented in the following 

discussion. DOE has transmitted a copy of this FRFA to the Chief Counsel for Advocacy of 

the SBA for review. The FRFA below is written in accordance with the requirements of the 

Regulatory Flexibility Act. 

1. Reasons for the Final Rule 

Part A-1 of Title III of EPCA addresses the energy efficiency of certain types of 

commercial and industrial equipment. (42 U.S.C. 6311-6317) EPACT 2005, Pub. L. 109–

58, included an amendment to Part A-1 requiring that DOE prescribe energy conservation 

standards for the commercial refrigeration equipment that is the subject of this rulemaking. 

(EPACT 2005, Section 136(c); 42 U.S.C. 6313(c)(4)(A)) DOE publishes today’s final rule 

pursuant to Part A-1. The commercial refrigeration equipment test procedures appear at 10 

CFR parts 430-431. 

2. Objectives of, and Legal Basis for, the Rule 

EPCA requires new and amended standards to be designed to achieve the maximum 

improvement in energy efficiency that is technologically feasible and economically justified 

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(see section II.B of this preamble). To determine whether economic justification exists, 

DOE reviews comments received and conducts analysis to determine whether the economic 

benefits of the new standard exceed the burdens to the greatest extent practicable, taking 

into consideration seven factors set forth in 42 U.S.C. 6295(o)(2)(B) and 6316(e)(1) (see 

section II.B of this preamble). Further information concerning the background of this 

rulemaking is provided in chapter 1 of the TSD. 

3. Description and Estimated Number of Small Entities Regulated 

DOE reviewed AHRI’s listing of commercial refrigeration equipment manufacturer 

members and surveyed the industry to develop a list of every manufacturer. DOE also asked 

interested parties and AHRI representatives within the industry if they were aware of any 

other small business manufacturers. DOE then looked at publicly available data and 

contacted manufacturers, when needed, to determine if they meet the SBA’s definition of a 

small business manufacturing facility and if their manufacturing facilities are located within 

the United States. Based on this analysis, DOE identified nine small commercial 

refrigeration equipment manufacturers and conducted on-site interviews with two of them. 

See chapter 13 of the TSD for further discussion about the methodology DOE used in the 

manufacturer impact analysis. 

4. Description and Estimate of Compliance Requirements 

Potential impacts on manufacturers, including small businesses, come from impacts 

associated with commercial refrigeration equipment design and manufacturing. All 

manufacturers, including small businesses, would have to develop designs to comply with 

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higher TSLs. Product redesign costs tend to be fixed and do not scale with sales volume. 

Thus, small manufacturers would be at a relative disadvantage at higher TSLs because 

research and development efforts would be on the same scale as those for larger companies. 

Furthermore, the level of research and development needed to meet energy conservation 

standards increases with more stringent energy conservation standards. DOE expects that 

small manufacturers will have more difficulty funding the required research and 

development necessary to meet energy conservation standards than larger manufacturers. 

However, as explained in part 6 of the IRFA, “Significant Alternatives to the Proposed 

Rule,” DOE explicitly considered the impacts on small manufacturers of commercial 

refrigeration equipment in selecting TSL 4, rather than selecting a higher standard level. 

DOE expects that the differential impact on small manufacturers of commercial refrigeration 

equipment would be smaller in moving from TSL 3 to TSL 4 than it would be in moving 

from TSL 4 to TSL 5. 

5. Significant Issues Raised by Public Comments 

DOE summarized comments from interested parties, including commercial 

refrigeration equipment manufacturers, in sections IV and V of this preamble. However, 

DOE did not receive any comments regarding impacts specific to small business 

manufacturers for the adoption of TSL 4 or the alternatives identified in section 6 of the 

IRFA, “Significant Alternatives to the Rule.” 

6. Steps DOE Has Taken to Minimize the Economic Impact on Small Manufacturers 

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In consideration of the benefits and burdens of standards, including the burdens 

posed on small manufacturers, DOE concluded that TSL 4 is the highest level that can be 

justified for commercial refrigeration equipment. As explained in part 6 of the IRFA, 

“Significant Alternatives to the Rule,” DOE explicitly considered the impacts on small 

manufacturers of commercial refrigeration equipment in selecting TSL 4. Levels at TSL 5 

would place excessive burdens on manufacturers, including small manufacturers, of 

commercial refrigeration equipment. Such burdens would include research and development 

costs and also a potential reduction of profit margins by limiting the flexibility of customers 

to choose design options. However, the differential impact on small businesses is expected 

to be lower in moving from TSL 3 to TSL 4 than in moving from TSL 4 to TSL 5, because 

research and development efforts are less at lower TSLs. Chapter 13 of the TSD contains 

additional information about the impact of this rulemaking on manufacturers. 

Section VI.C.2 discusses how small business impacts entered into DOE’s selection 

of today’s standards for commercial refrigeration equipment. DOE made its decision 

regarding standards by beginning with the highest level considered (TSL 5) and 

successively eliminating TSLs until it found a TSL that is both technically feasible and 

economically justified, taking into account other EPCA criteria. As discussed in section 

VI.C.2.e, DOE expects today’s standard to have little or no differential impact on small 

manufacturers of commercial refrigeration equipment. 

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Finally, in the NOPR, DOE requested comment on the impacts on small business 

manufacturers of TSL 4 and any other alternatives to the proposed rule. DOE received no 

comments in reference to any undue burden placed on small manufacturers. 

C. Review Under the Paperwork Reduction Act

 DOE stated in the August 2008 NOPR that this rulemaking would impose no new 

information and recordkeeping requirements, and that OMB clearance is not required under 

the Paperwork Reduction Act (44 U.S.C. 3501 et seq.). 73 FR at 50131-32. DOE received 

no comments on this in response to the August 2008 NOPR, and, as with the proposed rule, 

today’s rule imposes no information and recordkeeping requirements. Therefore, DOE has 

taken no further action in this rulemaking with respect to the Paperwork Reduction Act. 

D. Review Under the National Environmental Policy Act 

DOE prepared an environmental assessment of the impacts of today’s standards 

which it published as chapter 16 within the TSD for the final rule. DOE found the 

environmental effects associated with today’s various standard levels for commercial 

refrigeration equipment to be insignificant. Therefore, DOE is issuing a Finding of No 

Significant Impact (FONSI) pursuant to the National Environmental Policy Act of 1969 

(NEPA) (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 NEPA (10 CFR part 

1021). The FONSI is available in the docket for this rulemaking. 

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E. Review Under Executive Order 13132

DOE reviewed this rule pursuant to Executive Order 13132, “Federalism,” 64 FR 

43255 (August 4, 1999), which imposes certain requirements on agencies formulating and 

implementing policies or regulations that preempt State law or that have federalism 

implications. In accordance with DOE’s statement of policy describing the 

intergovernmental consultation process it will follow in the development of regulations that 

have federalism implications, 65 FR 13735 (March 14, 2000), DOE examined the proposed 

rule and determined that the rule would not have a substantial direct effect on the States, on 

the relationship between the National Government and the States, or on the distribution of 

power and responsibilities among the various levels of Government. 73 FR at 50132. DOE 

received no comments on this issue in response to the August 2008 NOPR, and its 

conclusions on this issue are the same for the final rule as they were for the proposed rule. 

Therefore, DOE is taking no further action in today’s final rule with respect to 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,” 61 FR 4729 

(February 7, 1996), 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. Section 3(b) of Executive Order 

12988 specifically requires that executive agencies make every reasonable effort to ensure 

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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 meet one or more of them. DOE has 

completed the required review and determined that, to the extent permitted by law, the final 

regulations meet the relevant standards of Executive Order 12988. 

G. Review Under the Unfunded Mandates Reform Act of 1995 

As indicated in the August 2008 NOPR, DOE reviewed the proposed rule under 

Title II of the Unfunded Mandates Reform Act of 1995 (Pub. L. 104–4) (UMRA), which 

imposes requirements on Federal agencies when their regulatory actions will have certain 

types of impacts on State, local, and Tribal governments and the private sector. 73 FR at 

50132. DOE concluded that although this rule would not contain an intergovernmental 

mandate, it may result in expenditure of $100 million or more in one year by the private 

sector. Id. Therefore, in the August 2008 NOPR, DOE addressed the UMRA requirements 

that it prepare a statement as to the basis, costs, benefits, and economic impacts of the 

proposed rule, and that it identify and consider regulatory alternatives to the proposed rule. 

Id. DOE received no comments concerning the UMRA in response to the August 2008 

NOPR, and its conclusions on this issue are the same for the final rule as they were for the 

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proposed rule. Therefore, DOE is taking no further action in today’s final rule with respect 

to the UMRA. 

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

DOE determined that, for this rulemaking, it need not prepare a Family 

Policymaking Assessment under Section 654 of the Treasury and General Government 

Appropriations Act, 1999 (Pub. L. 105–277). Id. DOE received no comments concerning 

Section 654 in response to the August 2008 NOPR, and, therefore, takes no further action in 

today’s final rule with respect to this provision. 

I. Review Under Executive Order 12630

DOE determined under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights,” 53 FR 8859 (March 18, 

1988), that today’s rule would not result in any takings that might require compensation 

under the Fifth Amendment to the U.S. Constitution. 73 FR at 50132. DOE received no 

comments concerning Executive Order 12630 in response to the August 2008 NOPR, and, 

therefore, takes no further action in today’s final rule with respect to this Executive Order. 

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 agencies to review most disseminations of information to the 

public under guidelines established by each agency pursuant to general guidelines issued by 

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OMB. OMB’s guidelines were published at 67 FR 8452 (February 22, 2002), and DOE’s 

guidelines were published at 67 FR 62446 (October 7, 2002). DOE has reviewed today’s 

final rule 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 a Statement of Energy Effects for any significant 

energy action. DOE determined that the proposed rule was not a “significant energy action” 

within the meaning of Executive Order 13211. 73 FR at 50133. Accordingly, it did not 

prepare a Statement of Energy Effects on the proposed rule. DOE received no comments on 

this issue in response to the August 2008 NOPR. As with the proposed rule, DOE has 

concluded that today’s final rule is not a significant energy action within the meaning of 

Executive Order 13211, and has not prepared a Statement of Energy Effects on the 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, issued its “Final Information Quality Bulletin for Peer Review (the Bulletin). 

70 FR 2664 (January 14, 2005). The purpose of the Bulletin is to enhance the quality and 

credibility of the Government’s scientific information. The Bulletin establishes that certain 

scientific information shall be peer reviewed by qualified specialists before it is 

disseminated by the Federal Government. As indicated in the August 2008 NOPR, this 

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includes influential scientific information related to agency regulatory actions, such as the 

analyses in this rulemaking. 73 FR at 50133. 

As set forth in the August 2008 NOPR, DOE held formal in-progress peer reviews of 

the types of analyses and processes that DOE has used to develop the energy efficiency 

standards in today’s rule, and issued a report on these peer reviews. Id. 

 

M. Congressional Notification

As required by 5 U.S.C. 801, DOE will submit to Congress a report regarding the 

issuance of today’s final rule prior to the effective date set forth at the outset of this notice. 

The report will state that it has been determined that the rule is a “major rule” as defined by 

5 U.S.C. 804(2). DOE also will submit the supporting analyses to the Comptroller General 

in the U.S. Government Accountability Office (GAO) and make them available to each 

House of Congress. 

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VIII. Approval of the Office of the Secretary 

The Secretary of Energy has approved publication of today’s final rule. 

Issued in Washington, DC, on [DATE] 

 ___________________________________ 

John F. Mizroch 

Acting Assistant Secretary 

Energy Efficiency and Renewable Energy. 

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List of Subjects in 10 CFR Part 431 

Administrative practice and procedure, Confidential business information, Energy 

conservation, Incorporation by reference. 

 For the reasons set forth in the preamble, chapter II of title 10, Code of Federal 

Regulations, part 431 is amended to read as set forth below. 

PART 431 - ENERGY EFFICIENCY PROGRAM FOR CERTAIN COMMERCIAL 

AND INDUSTRIAL EQUIPMENT 

1. The authority citation for part 431 continues to read as follows: 

Authority: 42 U.S.C. 6291-6317. 

2. Section 431.62 of subpart C is amended by adding in alphabetical order new definitions 

for “air-curtain angle,” “commercial hybrid refrigerator, freezer, and refrigerator-freezer,” 

“door angle,” “horizontal closed,” “horizontal open,” “semivertical open,” “vertical closed,” 

“vertical open,” and “wedge case” to read as follows: 

§ 431.62 Definitions concerning commercial refrigerators, freezers, and 

refrigerator-freezers. 

 Air-curtain angle means: 

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(1) For equipment without doors and without a discharge air grille or discharge air 

honeycomb, the angle between a vertical line extended down from the highest point on the 

manufacturer’s recommended load limit line and the load limit line itself, when the 

equipment is viewed in cross-section; and 

(2) For all other equipment without doors, the angle formed between a vertical line 

and the straight line drawn by connecting the point at the inside edge of the discharge air 

opening with the point at the inside edge of the return air opening, when the equipment is 

viewed in cross-section. 

* * * * * 

 Commercial hybrid refrigerator, freezer, and refrigerator-freezer means a 

commercial refrigerator, freezer, or refrigerator-freezer that has two or more chilled and/or 

frozen compartments that are: 

 (1) In two or more different equipment families, 

 (2) Contained in one cabinet, and 

 (3) Sold as a single unit. 

* * * * * 

 Door angle means: 

(1) For equipment with flat doors, the angle between a vertical line and the line 

formed by the plane of the door, when the equipment is viewed in cross-section; and 

(2) For equipment with curved doors, the angle formed between a vertical line and 

the straight line drawn by connecting the top and bottom points where the display area glass 

joins the cabinet, when the equipment is viewed in cross-section. 

* * * * * 

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Horizontal Closed means equipment with hinged or sliding doors and a door angle 

greater than or equal to 45°. 

* * * 

Horizontal Open means equipment without doors and an air-curtain angle greater 

than or equal to 80° from the vertical. 

* * * * * 

Semivertical Open means equipment without doors and an air-curtain angle greater 

than or equal to 10° and less than 80° from the vertical. 

* * * * * 

Vertical Closed means equipment with hinged or sliding doors and a door angle less 

than 45°. 

Vertical Open means equipment without doors and an air-curtain angle greater than 

or equal to 0° and less than 10° from the vertical. 

 Wedge case means a commercial refrigerator, freezer, or refrigerator-freezer that 

forms the transition between two regularly-shaped display cases. 

3. Section 431.63 of subpart C is revised to read as follows: 

IX. 431.36 Materials incorporated by reference. 

 (a) General. We incorporate by reference the following standards into Subpart C of 

Part 431. The material listed has been approved for incorporation by reference by the 

Director of the Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR 51. Any 

subsequent amendment to a standard by the standard-setting organization will not affect the 

DOE regulations unless and until amended by DOE. Material is incorporated as it exists on 

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the date of the approval and a notice of any change in the material will be published in the

Federal Register. All approved material is available for inspection at the National Archives 

and Records Administration (NARA). For information on the availability of this material at 

NARA, call 202-741-6030 or go to 

http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. 

Also, this material is available for inspection at U.S. Department of Energy, Office of 

Energy Efficiency and Renewable Energy, Building Technologies Program, 6th Floor, 950 

L’Enfant Plaza, SW, Washington, DC 20024, 202-586-2945, or go to: 

http://www1.eere.energy.gov/buildings/appliance_standards/. Standards can be obtained 

from the sources listed below. 

 (b) ANSI. American National Standards Institute, 25 W. 43rd Street, 4th Floor, New 

York, NY 10036, 212-642-4900, or go to http://www.ansi.org: 

 (1) ANSI /AHAM HRF-1-2004, Energy, Performance and Capacity of Household 

Refrigerators, Refrigerator-Freezers and Freezers, approved July 7, 2004, IBR approved 

for §431.294(b)(2) and §431.64(b)(3) 

 (2) [Reserved] 

 (c) ARI. Air-Conditioning and Refrigeration Institute, 4100 N. Fairfax Dr., Suite 

200, Arlington, VA 22203, of http://www.ari.org/std/standards.html: 

 (1) ARI Standard 1200–2006, Performance Rating of Commercial Refrigerated 

Display Merchandisers and Storage Cabinets, approved March 8, 2006, IBR approved for 

§431.64 (b), (b)(2); §431.66 (a)(3); (d)(2)(i), (d)(2)(ii), (d)(2)(iii); and (d)(3).

(2) [Reserved] 

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4. Section 431.66 of subpart C is amended by adding new paragraphs (a)(3) and (d) to read 

as follows: 

§431.66 Energy conservation standards and their effective dates.

(a) * * * 

(3) The term “TDA” means the total display area (ft2

) of the case, as defined in 

the ARI Standard 1200-2006, appendix D (incorporated by reference, see §431.63). 

* * * * * 

 (d) Each commercial refrigerator, freezer, and refrigerator-freezer with a selfcontained condensing unit and without doors; commercial refrigerator, freezer, and 

refrigerator-freezer with a remote condensing unit; and commercial ice-cream freezer 

manufactured on or after January 1, 2012, shall have a daily energy consumption (in 

kilowatt hours per day) that does not exceed the levels specified: 

 (1) For equipment other than hybrid equipment, refrigerator-freezers or wedge cases: 

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Equipment 

Category 

Condensing 

Unit 

Configuration 

Equipment Family Rating 

Temp. (°F) 

Operating Temp. 

(°F) 

Equipment 

Class 

Designation* 

Maximum Daily 

Energy 

Consumption 

(kWh/day) 

Vertical Open 38 (M) ≥ 32 VOP.RC.M 0.82 x TDA + 4.07 

(VOP) 0 (L) < 32 VOP.RC.L 2.27 x TDA + 6.85 

Semivertical Open 38 (M) ≥ 32 SVO.RC.M 0.83 x TDA + 3.18 

(SVO) 0 (L) < 32 SVO.RC.L 2.27 x TDA + 6.85 

Horizontal Open 38 (M) ≥ 32 HZO.RC.M 0.35 x TDA + 2.88 

(HZO) 0 (L) < 32 HZO.RC.L 0.57 x TDA + 6.88 

Vertical Closed 38 (M) ≥ 32 VCT.RC.M 0.22 x TDA + 1.95 

Transparent (VCT) 0 (L) < 32 VCT.RC.L 0.56 x TDA + 2.61 

Horizontal Closed 38 (M) ≥ 32 HCT.RC.M 0.16 x TDA + 0.13 

Transparent (HCT) 0 (L) < 32 HCT.RC.L 0.34 x TDA + 0.26 

Vertical Closed Solid 38 (M) ≥ 32 VCS.RC.M 0.11 x V + 0.26 

(VCS) 0 (L) < 32 VCS.RC.L 0.23 x V + 0.54 

Horizontal Closed 38 (M) ≥ 32 HCS.RC.M 0.11 x V + 0.26 

Solid (HCS) 0 (L) < 32 HCS.RC.L 0.23 x V + 0.54 

38 (M) ≥ 32 SOC.RC.M 0.51 x TDA + 0.11 

Remote 

Condensing 

Commercial 

Refrigerators 

and 

Commercial 

Freezers 

Remote 

(RC) 

Service Over Counter 

(SOC) 0 (L) < 32 SOC.RC.L 1.08 x TDA + 0.22 

Vertical Open 38 (M) ≥ 32 VOP.SC.M 1.74 x TDA + 4.71 

(VOP) 0 (L) < 32 VOP.SC.L 4.37 x TDA + 11.82 

Semivertical Open 38 (M) ≥ 32 SVO.SC.M 1.73 x TDA + 4.59 

(SVO) 0 (L) < 32 SVO.SC.L 4.34 x TDA + 11.51 

38 (M) ≥ 32 HZO.SC.M 0.77 x TDA + 5.55 

Self-Contained 

Commercial 

Refrigerators 

and 

Commercial 

Freezers 

without Doors 

Self-Contained 

(SC) 

Horizontal Open 0 (L) < 32 HZO.SC.L 1.92 x TDA + 7.08 

Vertical Open 

(VOP) VOP.RC.I 2.89 x TDA + 8.7 

Semivertical Open 

(SVO) SVO.RC.I 2.89 x TDA + 8.7 

Horizontal Open 

(HZO) HZO.RC.I 0.72 x TDA + 8.74 

Vertical Closed 

Transparent (VCT) VCT.RC.I 0.66 x TDA + 3.05 

Horizontal Closed 

Transparent (HCT) HCT.RC.I 0.4 x TDA + 0.31 

Vertical Closed Solid 

(VCS) VCS.RC.I 0.27 x V + 0.63 

Horizontal Closed 

Solid (HCS) HCS.RC.I 0.27 x V + 0.63 

Remote 

(RC) 

Service Over Counter 

(SVO) SOC.RC.I 1.26 x TDA + 0.26 

Vertical Open 

(VOP) VOP.SC.I 5.55 x TDA + 15.02 

Semivertical Open 

(SVO) SVO.SC.I 5.52 x TDA + 14.63 

Horizontal Open 

(HZO) HZO.SC.I 2.44 x TDA + 9. 

Vertical Closed 

Transparent (VCT) VCT.SC.I 0.67 x TDA + 3.29 

Horizontal Closed 

Transparent (HCT) HCT.SC.I 0.56 x TDA + 0.43 

Vertical Closed Solid 

(VCS) VCS.SC.I 0.38 x V + 0.88 

Horizontal Closed 

Solid (HCS) HCS.SC.I 0.38 x V + 0.88 

Commercial 

Ice-Cream 

Freezers 

Self-Contained 

(SC) 

Service Over Counter 

(SVO) 

-15 (I) ≤ -5** 

SOC.SC.I 1.76 x TDA + 0.36 

* The meaning of the letters in this column is indicated in the three columns to the left. 

** Ice-cream freezer is defined in 10 CFR 431.62 as a commercial freezer that is designed to operate at or below -

5 °F (-21 °C) and that the manufacturer designs, markets, or intends for the storing, displaying, or dispensing of 

ice cream. 

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(2) For commercial refrigeration equipment with two or more compartments (i.e., 

hybrid refrigerators, hybrid freezers, hybrid refrigerator-freezers, and non-hybrid 

refrigerator freezers), the maximum daily energy consumption (MDEC) for each model 

shall be the sum of the MDEC values for all of its compartments. For each compartment, 

measure the TDA or volume of that compartment, and determine the appropriate equipment 

class based on that compartment’s equipment family, condensing unit configuration, and 

designed operating temperature. The MDEC limit for each compartment shall be the 

calculated value obtained by entering that compartment’s TDA or volume into the standard 

equation in paragraph (d)(1) of this section for that compartment’s equipment class. 

Measure the calculated daily energy consumption (CDEC) or total daily energy 

consumption (TDEC) for the entire case: 

(i) For remote condensing commercial hybrid refrigerators, hybrid freezers, hybrid 

refrigerator-freezers, and non-hybrid refrigerator-freezers, where two or more independent 

condensing units each separately cool only one compartment, measure the total refrigeration 

load of each compartment separately according to the ARI Standard 1200-2006 test 

procedure (incorporated by reference, see §431.63).. Calculate compressor energy 

consumption (CEC) for each compartment using Table 1 in ARI Standard 1200-2006 using 

the saturated evaporator temperature for that compartment. The CDEC for the entire case 

shall be the sum of the CEC for each compartment, fan energy consumption (FEC), lighting 

energy consumption (LEC), anti-condensate energy consumption (AEC), defrost energy 

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consumption (DEC), and condensate evaporator pan energy consumption (PEC) (as 

measured in ARI Standard 1200-2006). 

(ii) For remote condensing commercial hybrid refrigerators, hybrid freezers, hybrid 

refrigerator-freezers, and non-hybrid refrigerator-freezers, where two or more compartments 

are cooled collectively by one condensing unit, measure the total refrigeration load of the 

entire case according to the ARI Standard 1200-2006 test procedure (incorporated by 

reference, see §431.63). Calculate a weighted saturated evaporator temperature for the entire 

case by: 

(A) multiplying the saturated evaporator temperature of each compartment by the 

volume of that compartment (as measured in ARI Standard 1200-2006), 

(B) summing the resulting values for all compartments, and 

(C) dividing the resulting total by the total volume of all compartments. 

Calculate the CEC for the entire case using Table 1 in ARI Standard 1200-2006, 

using the total refrigeration load and the weighted average saturated evaporator temperature. 

The CDEC for the entire case shall be the sum of the CEC, FEC, LEC, AEC, DEC, and 

PEC. 

(iii) For self-contained commercial hybrid refrigerators, hybrid freezers, hybrid 

refrigerator-freezers, and non-hybrid refrigerator-freezers, measure the TDEC for the entire 

case according to the ARI Standard 1200-2006 test procedure (incorporated by reference, 

see §431.63). 

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(3) For remote-condensing and self-contained wedge cases, measure the CDEC or 

TDEC according to the ARI Standard 1200-2006 test procedure (incorporated by reference, 

see §431.63). The MDEC for each model shall be the amount derived by incorporating into 

the standards equation in paragraph (d)(1) of this section for the appropriate equipment class 

a value for the TDA that is the product of: 

(i) the vertical height of the air-curtain (or glass in a transparent door) and 

(ii) the largest overall width of the case, when viewed from the front. 

APPENDIX 

[The following letter from the Department of Justice will not appear in the Code of Federal 

Regulations.] 

DEPARTMENT OF JUSTICE 

Antitrust Division 

Main Justice Building 

950 Pennsylvania Avenue, NW. 

Washington, DC 20530–0001 

(202) 514–2401/(202) 616–2645(f) 

antitrust@justice.usdoj.gov 

http://www.usdoj.gov 

October 24, 2008 

Warren Belmar, Esq. 

Deputy General Counsel for Energy Policy 

Department of Energy 

Washington, DC 20585 

Dear Deputy General Counsel Belmar: 

I am responding to your August 12, 2008 letter seeking the views of the Attorney 

General about the potential impact on competition of the proposed energy efficiency 

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standards for commercial refrigeration equipment. The Energy Policy and Conservation Act 

(“EPCA”) authorizes the Department of Energy (“DOE”) to establish energy conservation 

standards for a number of appliances where DOE determines that those standards would be 

technologically feasible, economically justified, and result in significant energy savings. 

Your request was submitted pursuant to Section 325(o)(2)(B)(i) of the Energy Policy 

and Conservation Act, 42 U.S.C. §6295 (“EPCA”), which states that, before the Secretary of 

Energy may prescribe a new or amended energy conservation standard, the Secretary shall 

ask the Attorney General to make a determination of “the impact of any lessening of 

competition ... that is likely to result from the imposition of standard.” The Attorney 

General’s responsibility for responding to requests from other departments about the effect 

of a program on competition has been delegated to the Assistant Attorney General for the 

Antitrust Division in 28 CFR § 0.40(g). In conducting its analysis the Antitrust Division 

examines whether a proposed standard may lessen competition, for example, by placing 

certain manufacturers of a product at an unjustified competitive disadvantage compared to 

other manufacturers, or by inducing avoidable inefficiencies in production or distribution of 

particular products. In addition to harming consumers directly through higher prices, these 

effects could undercut the ultimate goals of the legislation. 

Along with your request, you sent us the draft final rule and a number of other 

documents relating to commercial refrigeration equipment, including a hearing transcript 

and the names of parties interviewed by DOE’s consultant. 

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181

We have concluded that the proposed standards would not adversely affect 

competition. In reaching this conclusion, we note that the proposed standards were 

developed taking into account comments by commercial refrigeration equipment 

manufacturers, the American Society of Heating, Refrigerating, and Air-Conditioning 

Engineers, the American Council for an Energy Efficient Economy and electric utilities. We 

note further that all key components are available for purchase by any manufacturer; 

therefore no manufacturer has a technological advantage in meeting the proposed standards. 

Finally, DOE found no significant differences between the concerns of large and small 

manufacturers, and we found no evidence that certain manufacturers would be placed at a 

competitive disadvantage to other manufacturers. 

In conclusion, the Antitrust Division does not believe the proposed final rule would 

adversely affect competition. 

Yours sincerely, 

Deborah A. Garza, 

Acting Assistant Attorney General