Building Technologies Program 1 eere.energy.gov

Building Technologies Program

Framework Public Meeting 

for Wine Chillers and Miscellaneous 

Refrigeration Products

pictures 

Lucas Adin

February 22, 2012

Lucas.Adin@ee.doe.gov
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• Meeting Agenda

• Introductions

• Role of the Facilitator

• Ground Rules

– Listen as an ally

– Focus on issues

– Use short, succinct statements/keep to the point

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

name for the record)

– Hold sidebar conversations outside the room

– Set cell phones to silent/vibrate

• Housekeeping Items

Welcome and Introductions
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Attending Parties Opening Statements

At this time DOE welcomes opening remarks/statements on the 

framework document for wine chillers and miscellaneous 

refrigeration products. 
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Preliminary Analysis & Test Procedure

Notice of Proposed Rulemaking (NOPR) Analyses

Closing Remarks, Contacts & Information

Public Meeting Slides Topics

5

6

7

2 Regulatory History

4 Rulemaking Overview and Framework

1 Introduction

3 Scope
Building Technologies Program 5 eere.energy.gov

• Present procedural and analytical approaches to evaluate 

energy conservation standards for wine chillers and 

miscellaneous refrigeration products.

• Provide a forum for public discussion of rulemaking issues.

• Encourage interested parties to submit data, information, 

and written comments.

• Inform interested parties and facilitate the rulemaking 

process.

Introduction

Meeting Purpose
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Introduction

Issue Box In the Rulemaking Framework Document for Wine 

Chillers and Miscellaneous Refrigeration Products, DOE welcomes 

comments on particular issues raised in a text box like this. 

Throughout this presentation, specific issues will be raised for 

discussion on slides such as this, with identifying numbers 

corresponding to those in the framework document. In addition, 

DOE has added some questions that are not in the framework 

document. These questions are identified by a letter. Nonetheless, 

comments concerning any part of the document or presentation 

are welcome.

Request for Comment Format
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Preliminary Analysis & Test Procedure

Notice of Proposed Rulemaking (NOPR) Analyses

Closing Remarks, Contacts & Information

Public Meeting Slides Topics

5

6

7

2 Regulatory History

4 Rulemaking Overview & Framework

1 Introduction

3 Scope
Building Technologies Program 8 eere.energy.gov

• The Energy Policy and Conservation Act (EPCA) of 1975 (Public Law 94-

163) established the energy conservation program.

• The amendments to EPCA in the National Appliance Energy Conservation 

Act of 1987 (Public Law 100-12) established energy conservation 

standards for residential refrigeration products and required that DOE 

conduct two cycles of rulemakings to determine if more stringent 

standards are justified 42 U.S.C. 6295(b). 

– DOE fulfilled this obligation by publishing standards rules in 1989 and 1997.

• The Energy Independence and Security Act (EISA) of 2007 (Public Law 

110-140) required that DOE publish a final rule determining whether to 

amend the standards in effect for residential refrigeration products 

manufactured starting in 2014. 

– DOE fulfilled this obligation by publishing new standards on September 15, 

2011. 76 FR 57516.

Regulatory History

Energy Conservation Standard for Refrigeration Products
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Regulatory History

Current DOE standards do not address wine chillers and related 

refrigeration products.

• In 2001 DOE limited the application of its refrigerator standards to 

exclude wine chillers and similar products, because the 

refrigerator test procedure and standards were unable to account 

for specific wine chiller design and use requirements.

• DOE opted to address wine chillers and other refrigeration 

products separately from refrigerators.

• This action may lead to new and tailored standards for these 

products.

• DOE’s current definition for Electric Refrigerator (see 10 CFR 

430.2) excludes wine chillers due to storage temperature limits:

“. . . designed to be capable of achieving storage temperatures above 32 °F (0 

°C) and below 39 °F (3.9 °C), . . .”
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Regulatory History

Refrigerator Scope of Coverage

• EPCA provides some scope-related criteria, but specifies no 

temperature limits: 

“. . .excluding those consumer products designed solely for use in 

recreational vehicles and other mobile equipment . . .” 42 U.S.C. 6292(a)

“Refrigerators, refrigerator-freezers, and freezers which can be operated by 

alternating current electricity, excluding--

 (A) any type designed to be used without doors; and

(B) any type which does not include a compressor and condenser unit 

as an integral part of the cabinet assembly.” 42 U.S.C. 6292(a)(1)

• DOE has the authority to modify its current refrigerator 

definition (see 10 CFR 430.2) to include wine chiller and similar 

products.

• This specific authority, however, does not cover products using 

thermoelectric or absorption refrigeration.
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Regulatory History

Refrigerator Scope of Coverage

• Establishing coverage over new consumer products requires:

– Minimum annual per household energy use of 100 kWh (42 U.S.C. 6292(b)(1)(B))

• To set an energy efficiency standard for a newly covered product, two key 

criteria must be met: 

– Minimum average annual per household energy use associated with the product 

of 150 kWh, and 

– National annual energy use of 4.2 billion kWh. (42 U.S.C. 6295(l)(1)(A, B)) 

• If national energy use does not exceed 4.2 billion kWh, DOE would be 

authorized to establish coverage but not efficiency standards. 

– Coverage alone without setting a national standard would preempt State 

standards that are already in place

• DOE recently proposed covering AC-powered thermoelectric and 

absorption refrigeration products. See 76 FR 69147 (Nov. 8, 2011).
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Regulatory History

• California has had its current wine chiller standards in effect for at 

least a decade; Canada harmonized with the CA standards in 

2008.1

• The regulations set standards for two product classes: automaticdefrost wine chillers and manual-defrost wine chillers.

• The California wine chiller standards do not make a distinction 

regarding the cooling technology used in the product. 

• DOE has not been able to identify any thermoelectric units in the 

CEC refrigerator database, implying either that these units do not 

meet the standards or that manufacturers are not aware that they 

are covered.

Existing State and Foreign Standards

1 The current set of Appliance Regulations (2010 Appliance Efficiency Regulations, California Code of Regulations, Title 20, 

Sections 1601 through 1608) became effective January 1, 2011. They were adopted by the California Energy Commission 

on November 18, 2009.

CAN - http://oee.nrcan.gc.ca/regulations/product/refrigerators-freezers.cfm?attr=0
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Preliminary Analysis & Test Procedure

Notice of Proposed Rulemaking (NOPR) Analyses

Closing Remarks, Contacts & Information

Public Meeting Slides Topics

5

6

7

2 Regulatory History

4 Rulemaking Overview & Framework

1 Introduction

3 Scope
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Scope

Summary of Coverage Options

• The coverage options DOE considered include:

1. Establish coverage and standards for vapor compression wine chillers by 

modifying the refrigerator and refrigerator-freezer definitions to include these 

products, and either: 

a) Establish coverage for thermoelectric and absorption products; or

b) Do not pursue coverage for thermoelectric and absorption units. 

2. Establish a new category of covered products for wine chillers and related 

products irrespective of the cooling technologies they use. This approach may 

preclude pursuit of energy standards for these products because of the 4.2 

billion kWh statutory threshold.

• DOE is tentatively considering Option 1(a).

Item 1-3 DOE requests comment on whether other coverage/standards 

options in addition to the ones described above are possible. DOE also 

seeks feedback regarding the merits of pursuing an approach based on 

Option 1(a).
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Scope

Item 1-1 DOE requests shipment information from stakeholders for 

wine chillers and related refrigeration products. Segregation of such 

data is desired if possible by type of refrigeration technology 

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

product class, and any other relevant characteristics. 

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

refrigeration products. DOE requests that the data identify model 

numbers or basic product information (e.g. cabinet volume) and that 

the method of determining the energy use be identified for such 

data – i.e. identify the test procedure used and/or indicate that the 

data are estimates, field measurements, or results determined by 

other methods. DOE requests that such data be segregated if 

possible according to refrigeration technology, product class, and/or 

product size.

Request for Comment 
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• Absorption cooling – a refrigeration technology that uses a heat source to provide the 

energy needed to drive the cooling system. These systems do not use a compressor. 

• Thermoelectric cooling – a refrigeration technology using a solid state heat pump to provide 

cooling via the Peltier effect. These systems do not use a compressor and condenser. 

• Vapor compression cooling – a refrigeration technology that uses a compressor and 

condenser to provide cooling. 

• Automatic defrost – 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.

• Manual defrost – a method of removing frost and/or ice from the refrigerated surfaces 

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

the overall defrost operation.

• Off-cycle defrost – a type of automatic defrost in which the re-circulating air, which is 

warmer than 32  ̊F, melts ice build up on the evaporator when the compressor is off. 

Scope

Definitions
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Scope

• DOE is considering adopting the following definition for electric 

wine chiller:

– [A] cabinet designed for the refrigerated storage of beverages, nonperishable food products, and/or any other items, is not designed to be 

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

a source of refrigeration requiring single phase, alternating current electric 

energy input. 

• The definition for refrigerator would be modified to include both 

electric refrigerator and electric wine chiller.

• Because some warmer-storage products are not designed uniquely 

for wine, DOE is considering the possibility of applying a term 

other than electric wine chiller to all products with storage 

temperatures warmer than 39  ̊F. 

Wine Chiller Definition
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Scope

• The majority of residential wine chiller sales are of products that 

fit the size criteria for compact refrigerators/refrigeratorfreezers/freezers.

• If DOE modifies the definition for refrigerator to include wine 

chillers, DOE may modify the definition of compact 

refrigerator/refrigerator-freezer/freezer as follows to avoid 

establishing a separate compact category of wine chiller:

– Compact refrigerator/refrigerator-freezer/freezer means any refrigerator, 

refrigerator-freezer or freezer with total volume less than 7.75 cubic feet 

(220 liters) and 36 inches (0.91 meters) or less in height that is not an 

electric wine chiller. 

Modification of Compact Products Definitions
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Scope

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

wine chiller and the modified definitions for refrigerator and 

compact products described above.

Item 1-5 DOE requests comments from stakeholders regarding the 

selection of a term identifying the product category associated with 

wine chillers and related refrigeration products whose compartment 

temperatures are warmer than 39  ̊F. In addition, DOE seeks 

comment on whether multiple product categories are necessary to 

address such products.

Request for Comment 
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Scope

• During the refrigerator rulemakings, DOE became aware of 

products that combine wine storage compartments with 

refrigerator compartments and/or freezer compartments. 

75 FR 78810, 78816-78817 (December 16, 2010).

• DOE addressed these products in February 2011.2

– For refrigerators and refrigerator-freezers, the addition of a “wine storage” 

compartment does not change its status and does not affect its coverage.

– The addition of a wine storage compartment to a freezer changes that 

product’s status and removes it from current coverage under DOE’s 

regulations.

– DOE indicated that it was considering a rulemaking that would resolve some 

of these issues.

Hybrid Products

2

 This guidance has since been divided into three separate documents, which are available at the links below:

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/hybridwinechiller_faq_2011-02-10.pdf

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/hybridwinechiller_faq2_2011-02-10.pdf

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/hybridwinechiller_faq3_2011-02-10.pdf
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Scope

1. Set a threshold size for a wine storage compartment at which a refrigerator, 

refrigerator-freezer, or freezer is no longer one of these products and is 

instead classified as a “hybrid” product.

2. Establish definitions for hybrid products.

3. Develop test procedures for products for which the wine storage 

compartments are smaller than the thresholds.

4. Apply the existing energy standards to these products that will still be 

refrigerators, refrigerator-freezers, or freezers under the modified definitions. 

5. Develop test procedures and energy standards for hybrid products falling out 

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

Potential Framework for Addressing Hybrid Products

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

addressing products that include fresh food and/or freezer 

compartments as well as wine storage compartments.
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Scope

Item 1-7 DOE seeks information regarding the types and 

configurations of products that might need to be considered under 

such a framework, including examples showing product details and 

information on annual shipments associated with such products.

Item 1-8 DOE seeks comment on whether there should be a 

threshold size or percentage of total volume for wine storage 

compartments that would push a product out of the current 

definitions for refrigerator, refrigerator-freezer, or freezer into hybrid 

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

of hybrid product categories should be established?

Item 1-9 DOE seeks comment on what kinds of test procedure 

revisions would be required to address these products, whether 

covered under the existing product categories or by new categories?

Request for Comment 
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Scope

Item 1-10 DOE seeks comment on whether DOE should include the 

development of definitions, test procedures, and energy standards 

for hybrid products as part of a potential rulemaking.

Item 1-19 DOE seeks comments from stakeholders regarding how 

compartments used in wine chillers and related refrigeration 

products that are currently not covered under the existing 

refrigeration product definitions could be defined. What 

compartment types should be defined and what should their 

standardized temperatures for energy testing be? 

Request for Comment 
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Other Residential Refrigeration Products

Scope

Item 1-13 DOE requests information regarding whether there are 

any residential refrigeration products not yet covered by energy 

conservation standards, other than the wine chillers and related 

hybrid products, that DOE should regulate through energy 

conservation standards. Assuming such products exist, what are they 

(i.e. types), what are their annual shipment levels in the U.S., and 

what are their energy use characteristics?

• DOE is considering, consistent with EPCA, extending coverage and 

establishing energy conservation standards for all other residential 

refrigeration products that are currently unregulated.
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Other Residential Refrigeration Products (cont.)

Scope

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

particularly: the annual sales levels for such products in the U.S.; 

whether test procedures addressing energy use for such products 

exists; the typical annual energy use of such a product in residential 

settings; and other information DOE should consider in determining 

whether to regulate such products?

Item 1-17 DOE seeks information regarding the prevalence of “nearfreezer”3 products. DOE also seeks input regarding the need to 

revise the current definition of the freezer and/or the freezer test 

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

whether these products should fall under existing product classes or 

separate new product classes and energy standards. If the latter, 

DOE requests comments regarding the nature of these revisions.

3

 Near- Freezers are discussed in more detail in the framework document. These are products that 

achieve freezing temperatures (below 32  ̊F), but do not maintain 0  ̊F temperature, as required by the 

DOE “freezer” definition.
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Coverage of Wine Chillers in Residential and Commercial Applications

Scope

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

distinguish wine chillers used in commercial applications from residential wine 

chillers. DOE also requests comment on whether any wine chillers used in 

commercial applications are manufactured on the same product lines as 

residential wine chillers. Finally, DOE seeks information as to whether any 

commercial wine chillers are distributed in commerce for personal or consumer 

use. If so, DOE seeks details regarding the magnitude of those sales as a 

percentage of total sales of commercial products.

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

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

• DOE is aware of several attributes that could distinguish commercial types 

of wine chillers from residential types, but does not have sufficient 

information to definitively conclude that wine chillers with uniquely 

commercial features exist. 
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Products that can Operate on both AC and DC electric power

Scope

Item 1-11 DOE seeks information regarding whether refrigeration products 

which operate on either alternating current (AC) or direct current (DC) 

electricity are distributed to any significant extent in commerce for personal or 

consumer use in stationary applications (e.g., in homes). What types of such 

products are sold, what are their annual shipment levels in the U.S., and what 

are their energy use characteristics? 

Item 1-12 DOE seeks comment on whether it should specifically extend 

coverage and develop test procedures, definitions, and energy standards for 

refrigeration products that operate on either alternating current (AC) or direct 

current (DC) electricity.

• DOE is aware of products that can operate on either AC or DC power. 

• Many of these products are marketed for mobile applications, and for that 

reason would not be subject to EPCA coverage under 42 U.S.C . 6292.

• However, significant numbers of such products may be used in stationary 

applications.
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Preliminary Analysis & Test Procedure

Notice of Proposed Rulemaking (NOPR) Analyses

Closing Remarks, Contacts & Information

Public Meeting Slides Topics

5

6

7

2 Regulatory History

4 Rulemaking Overview & Framework

1 Introduction

3 Scope
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Rulemaking Overview & Framework

• 42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors when setting energy 

conservation standards:

EPCA Factors DOE Analysis

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost Analysis and Manufacturer 

Impact Analysis

2. Lifetime operating cost savings compared to 

increased cost for the equipment

Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis and Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

6. Need for national energy conservation National Impact Analysis

7. Other factors the Secretary considers relevant Environmental Assessment, Utility Impact 

Analysis, and Employment Impact Analysis

EPCA Seven Factors
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Rulemaking Overview & Framework

Framework

Document 

Preliminary 

Analysis 

Notice of 

Proposed 

Rulemaking 

(NOPR)

Final

Rule

• DOE published a Federal Register notice on February 13, 2012.

 

• Today’s public meeting covers the Framework documents for wine chillers and 

miscellaneous refrigeration products.

• Framework document provides:

– Overview of the rulemaking process

– Provides avenues for interested parties to submit comments by March 14, 2012

– The framework information and materials are available online at:

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

Rulemaking Process Steps
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Framework 

Document 

Public Meeting 

February 22, 2012

Rulemaking Overview & Framework

ECS Preliminary 

Analysis

Public Meeting

Planned – January 2013

ECS NOPR

Public Meeting

Planned – Oct. 2013

2011 2012 2013 2014 2015

Estimated ECS Final Rule 

Compliance Date 

Mid 2017

2016

TP NOPR Public 

Meeting 

Planned – Sept. 2012

Rulemaking Timelines

NOPR

2011 2012 2013 2014

Test Procedure

Energy 

Conservation 

Standard

Final Rule

Framework NOPR

Preliminary

Analysis Final Rule
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Acceleration of Potential Rulemaking Timeline

• Options to accelerate the timeline:

1. Stakeholders negotiate an appropriate efficiency level for the standard 

and DOE publishes a direct Final Rule. This could save 7-21 months, 

depending on how early in the process an agreement is reached.

2. DOE bypasses publication of the preliminary analysis documents and 

the preliminary analysis public meeting and proceeds directly to a 

NOPR. This could save 6-8 months.

Rulemaking Overview & Framework

Item 1-22 DOE requests comments from stakeholders regarding the 

possible acceleration of the timeline to publish a possible final rule and 

potential implications. 
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Preliminary Analysis & Test Procedure

Notice of Proposed Rulemaking (NOPR) Analyses

Closing Remarks, Contacts & Information

Public Meeting Slides Topics

5

6

7

2 Regulatory History

4 Rulemaking Overview & Framework

1 Introduction

3 Scope
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Preliminary Analysis & Test Procedure

Test Procedure

• The Code of Federal Regulations (CFR) prescribes the DOE test 

procedures for residential refrigeration products. 

– These test procedures do not include provisions for testing products that 

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

the standardized compartment temperatures specified in the test 

procedures are significantly lower than those typical for wine chillers.

• The Association of Home Appliance Manufacturers (AHAM), the 

California Energy Commission (CEC), and Natural Resources 

Canada (NRCan) all use a standardized compartment temperature 

of 55  ̊F (12.8  ̊C).

Past Test Procedures
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• The AHAM, CEC, and CSA test procedures for wine chillers apply a 

correction factor to the wine chiller energy use calculation to account for 

average product usage. 

• This factor reduces the measured energy use by 15% to determine daily 

energy consumption for a given temperature setting in order to account for 

the expectation that such products would have fewer door openings, on 

average, than a household refrigerator, may not be energized at all times, 

and/or other reasons that would reduce energy use. 

Preliminary Analysis & Test Procedure

Test Procedure

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

appropriate for calculating wine chiller energy use, and whether 0.85 

is an appropriate value for the correction factor. DOE further 

requests information supporting the selection of any recommended 

correction factor.

Correction Factor
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• EPCA requires DOE to consider standby mode and off mode energy 

consumption when amending both its test procedures and energy 

conservation standards. 

• DOE expects that any modified version of the existing test procedures for 

refrigeration products that DOE would develop for these products would 

capture standby and off mode energy use because the test procedure 

measures all product energy use, including compressor “off” periods.

• DOE concludes that establishing special test procedures to address standby 

and off modes is not required.

Preliminary Analysis & Test Procedure

Test Procedure

Item 1-21 DOE requests input from stakeholders on the its tentative 

conclusion that separate test procedures to address standby and off 

modes are not required for wine chillers and related refrigeration 

products.

Standby and Off Modes
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Test Procedure Key Issues

Preliminary Analysis & Test Procedure

Test Procedure

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

issues associated with development of test procedures for wine chillers and 

related refrigeration products, and, if so, what these issues are.

• Establishing definitions for product categories and/or compartment types to 

clarify which products are subject to which test requirements. 

• Establishing standardized compartment temperatures that are appropriate 

for the product categories.

• Testing of hybrid products. 

• Potential consideration of test procedures for commercial wine chillers. 

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

related products.

• Potential consideration of additional test procedure requirements to address 

standby and/or off mode energy use.
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Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 39 eere.energy.gov

Preliminary Analysis & Test Procedure

Market and Technology

• Characterize the markets, the wine chillers and miscellaneous refrigeration 

products industry, and the potential technological measures that improve 

efficiency.

Method

• Identify and characterize manufacturers of wine chillers and miscellaneous 

refrigeration products;

• Estimate shipments and trends in the market;

• Identify regulatory and non-regulatory initiatives intended to improve the 

efficiency of the equipment covered under this rulemaking; and

• Identify technologies that could improve efficiency.

Purpose of Market and Technology Assessment
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Preliminary Analysis & Test Procedure

Market and Technology

Item 3-1 DOE requests information that help it assess the market for 

those products that would be covered in this potential rulemaking. 

Information sought includes, but is not limited to, current product 

features and efficiencies, product-feature and efficiency trends, 

historical product shipments and prices.

Request for Comments
Building Technologies Program 41 eere.energy.gov

Preliminary Analysis & Test Procedure

Market and Technology

Product Classes for Residential Wine Chillers and Miscellaneous 

Refrigeration Products

No. Product Class

1

Residential wine chillers and miscellaneous refrigeration 

products with manual defrost

2

Residential wine chillers and miscellaneous refrigeration 

products with automatic defrost

• General criteria for different classes (42 U.S.C. 6295(q) and 6316(a)) :

– Type of energy used

– Capacity

– Other performance-related features, such as those that provide utility to the 

consumer, that would justify the establishment of separate energy 

conservation standards. 
Building Technologies Program 42 eere.energy.gov

Preliminary Analysis & Test Procedure

Market and Technology

Item 3-2 DOE requests input from stakeholders on the proposed 

product classes. What other factors, if any, should DOE consider 

beyond those identified above as a basis for developing product 

classes? When answering, please explain in detail and cite specific 

examples to the extent possible.

Item 3-3 DOE requests information on solid-door products that 

would fit the definitions anticipated for wine chillers: 

• How prevalent are such products?

• What are the efficiency differences between solid-door and 

transparent-door products?

• Is there sufficient consumer utility associated with transparent doors 

to make product class distinctions upon this basis?

Request for Comments
Building Technologies Program 43 eere.energy.gov

Preliminary Analysis & Test Procedure

Market and Technology

Item 3-4 Do any wine chillers or miscellaneous refrigeration 

products utilize heating (electric or otherwise) on glass surfaces or 

on door face frames to prevent condensation. If so, what types of 

products utilize such heating and what percentage of shipments do 

they represent?

Item 3-5 Do any wine chillers or miscellaneous refrigeration 

products utilize defrost heating (i.e. automatic defrost methods 

other than by frost melting during the compressor off-cycle). If so, 

what types of products utilize defrost heating and what percentage 

of shipments do they represent? Do any wine chillers or 

miscellaneous refrigeration products utilize manual defrost—if so, 

what types of products require manual defrost and what percentage 

of shipments do they represent?

Request for Comments
Building Technologies Program 44 eere.energy.gov

Preliminary Analysis & Test Procedure

Market and Technology

Insulation Compressor

1. Improved resistivity of insulation 11. Improved compressor efficiency

2. Increased insulation thickness 12. Variable-speed compressors

3. Vacuum-insulated panels 13. Linear compressors

Gasket and Door Design Evaporator and Condenser

4. Improved gaskets 14. Increased surface area 

5. Double door gaskets 15. Improved heat exchange

6. Improved door face frame

7. Anti-fog film Cycling Losses

8. Improved thermal resistance glass and frames 16. Fluid control or solenoid valve

Anti-Sweat Heater Defrost System

9. Hot gas or Warm Liquid 17. Compressor cycling defrost

Fans and Fan Motor Other Technologies

10. Fan blade and fan motor improvements 18. Alternative refrigerants 

Wine Chiller and Miscellaneous Refrigeration Product Technologies
Building Technologies Program 45 eere.energy.gov

Preliminary Analysis & Test Procedure

Market and Technology

Item 3-7 Should DOE consider any additional technologies for wine 

chillers and miscellaneous refrigeration products in its analysis? If 

so, which ones and why?

Request for Comment 
Building Technologies Program 46 eere.energy.gov

Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 47 eere.energy.gov

Preliminary Analysis & Test Procedure

Screening Analysis

Impacts on health or safety

Impacts on equipment utility or availability to consumers

Practicability to manufacture, install, and service

Technological feasibility

• Purpose - Screen out technology options that DOE does not consider in the 

engineering analysis for wine chillers and miscellaneous refrigeration products.

• Approach – DOE evaluates each technology option based on the following four 

screening criteria:

Screening Analysis
Building Technologies Program 48 eere.energy.gov

Preliminary Analysis & Test Procedure

Screening Analysis

Item 4-1 Are there any technologies listed in the Wine Chiller and 

Miscellaneous Refrigeration Product Technologies table that DOE 

should not consider because of any of the four screening criteria? If 

so, which screening criteria apply to the cited technology or 

technologies? 

Request for Comment 
Building Technologies Program 49 eere.energy.gov

Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 50 eere.energy.gov

Preliminary Analysis & Test Procedure

Engineering Analysis

• A key factor in setting the standard is the increased cost of more-efficient 

equipment.

• The engineering analysis determines the relationship between cost and efficiency.

Rulemaking Analyses

• Life-Cycle Cost and Payback 

Period

• Manufacturer Impact Analysis 

• Employment Impact Analysis

Manufacturer Selling Price –

Efficiency Relationship

Manufacturer 

Selling Price

Efficiency Level

Engineering Analysis Goals
Building Technologies Program 51 eere.energy.gov

Preliminary Analysis & Test Procedure

Engineering Analysis

• Engineering Analysis Approaches

– Design Option Approach: Determination of efficiency and improvement potential 

based on individual and groups of design options.

– Efficiency Level Approach: Cost information collected (i.e., from the industry) at 

predetermined efficiency levels to represent cost/efficiency relationship.

– Reverse Engineering Approach: Costs for the efficiency levels associated with 

reverse-engineered products are calculated using a manufacturing cost model.

• DOE would use a combination of these approaches, using multiple available 

data sources to develop the cost-efficiency relationships.

Engineering Analysis Methodology 
Building Technologies Program 52 eere.energy.gov

Preliminary Analysis & Test Procedure

Engineering Analysis

Item 5-2 DOE requests feedback on the use of a design-option 

approach based on energy modeling and some energy testing as 

needed, possibly enhanced by data collection organized by AHAM or 

other parties to determine the relationship between manufacturer 

cost and annual energy consumption. Particularly, DOE is interested 

in whether this approach would be appropriate in developing a 

cost/efficiency relationship for use as the basis for setting standards. 

DOE is also interested in whether the industry (including AHAM) or 

any other party would be prepared to provide cost-efficiency 

information to support the rulemaking. If the suggested approach is 

not appropriate, why is it not?

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

Preliminary Analysis & Test Procedure

Engineering Analysis

Product Teardowns and Testing

• DOE is considering the purchase of the following types of vapor-compression cooled 

wine chillers for testing and reverse engineering:

Note 1: Door panel can be selected in either glass or solid outlay. DOE plans to purchase this unit in a glass door and solid door configuration. 

Interior 

Volume 

(Cu.ft)

Capacity 

(bottles)

Annual 

Energy Use 

(KWh)

Installation 

Style

Number 

of Zones

Door Defrost

2 1 7 318 Counter top 1 Tempered Glass Automatic

3 2 4 292 Counter top 1

Tinted, DoublePanned Glass Manual

3 2 6 396

Counter top 

or Built-in 1

Tinted Tempered 

Glass Automatic

6 4 8 350 Built-in 1

Gas Filled 

Thermopane 

Automatic

6 4 8 262 Built-in 1

Gas Filled 

Thermopane 1 Automatic

6 5 7 439 Built-in 1

Tinted Tempered 

Glass Automatic

1 1 7 5 468 Free 

standing 

1 Tempered Glass Automatic

1 4 166 590

Free 

standing or 

Built-in 

2

Tinted Tempered 

Glass Automatic

1 8 147 375 Built-in 2 Tempered Glass Automatic

0

100

200

300

400

500

600

700

800

0 2 4 6 8 1 0 1 2 1 4 1 6 1 8 2 0

Energy Consumption (kWH/Yr)

Total Volume (cu.ft)

CEC Database Selections

Manual Defrost Automatic Defrost
Building Technologies Program 54 eere.energy.gov

Preliminary Analysis & Test Procedure

Engineering Analysis

Baseline Efficiency Levels

Product Class Equations for Maximum Energy Use 

(kWh/yr)

Wine chillers with manual defrost. 13.7AV + 267

0.48 av + 267

Wine chillers with automatic defrost 17.4AV + 344

0.61 av + 344

AV, adjusted volume in cubic feet; av, adjusted volume in liters

Item 5-1 DOE seeks input from stakeholders on whether the equations for 

maximum annual energy consumption based on the California and Canadian 

regulations are appropriate to represent the performance of baseline wine chillers. 

• DOE is considering using the California and Canadian Standards as the Baseline 

Efficiency Levels for its analysis.

• These equations, which are based on the current AHAM/CEC/NRCan test 

procedures, would represent the baseline levels. They may change if test 

procedure modifications are deemed necessary.
Building Technologies Program 55 eere.energy.gov

Preliminary Analysis & Test Procedure

Engineering Analysis

Item 5-3 DOE seeks input from stakeholders regarding the range of 

efficiency levels that should be examined as part of its analysis

• DOE expects to analyze efficiency levels for wine chillers and miscellaneous 

refrigeration products of up to 40% for automatic defrost products and up to 

25% for manual defrost products

Incremental Efficiency Levels
Building Technologies Program 56 eere.energy.gov

Preliminary Analysis & Test Procedure

Engineering Analysis

• In many rulemakings, DOE requests cost-efficiency data from the industry to 

supplement its own analysis.

• These data are generally collected and aggregated by the applicable trade 

organization (AHAM for wine chillers and miscellaneous refrigeration products) 

to protect the privacy of the information provided by individual manufacturers.

Item 5-4 DOE seeks comment on how to select representative 

products for detailed analysis and on how to extrapolate such 

analyses to the full range of wine chiller and miscellaneous 

residential refrigeration products.

Industry Data Collection
Building Technologies Program 57 eere.energy.gov

Preliminary Analysis & Test Procedure

Engineering Analysis

• DOE evaluates all design options that are commercially available or present in 

a working prototype, including proprietary designs and technologies.

• DOE only considers efficiency levels associated with proprietary designs if 

these designs do not present unique paths to the given efficiency levels.

• DOE maintains the confidentiality of manufacturers.

Item 5-5 Are there proprietary designs or technologies of which DOE 

should be aware for the products under consideration in this 

potential rulemaking? If so, how should DOE acquire the cost data 

necessary for evaluating these designs?

Proprietary Designs
Building Technologies Program 58 eere.energy.gov

Preliminary Analysis & Test Procedure

Engineering Analysis

Item 5-6 Are there outside regulatory issues that DOE should 

consider in its analysis of residential wine chillers and miscellaneous 

refrigeration products? If so, identify what they are and how DOE 

should consider them for purposes of its analysis.

Outside Regulatory Change 

• In conducting an engineering analysis, DOE takes into consideration the effects 

of regulatory changes outside DOE’s statutory energy conservation standards 

rulemaking process that can affect manufacturers of products addressed by 

the rulemaking, some of which can also affect the energy efficiency or energy 

consumption of those products. 

• DOE considers adjustments to its analysis based on the comments received on 

the engineering analysis documented in the preliminary analysis. 
Building Technologies Program 59 eere.energy.gov

Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 60 eere.energy.gov

Preliminary Analysis & Test Procedure

Markups for Equipment Price Determination

Types of Markups in Distribution Chain

• Baseline Markups:

– Markups relate consumer price to the cost of goods sold (CGS).

– Baseline markups relate price to cost prior to a change in efficiency.

– Baseline markups indicate a consumer price that covers all of a distributor’s or 

contractor’s expenses plus profit.

• Incremental Markups:

– Incremental markups relate the incremental change in consumer price to the 

incremental change in CGS.

– Certain costs, such as direct labor costs (salaries, payroll, rental and occupancy), do 

not vary with efficiency induced changes in CGS and remain constant in the 

calculation of incremental markups.

– Incremental markups cover only expenses that vary with CGS in this case, 

expenses that increase due to an increase in equipment efficiency.
Building Technologies Program 61 eere.energy.gov

Preliminary Analysis & Test Procedure

Markups for Equipment Price Determination

Item 6-1 DOE welcomes suggestions and comments concerning its 

proposed approach for developing estimates of future retail prices.

Request for Comment 
Building Technologies Program 62 eere.energy.gov

Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 63 eere.energy.gov

Preliminary Analysis & Test Procedure

Energy Use Characterization

• Analyze the annual energy consumption of the appliance to assess 

the energy savings potential of different equipment efficiencies. 

• Provide the basis for the unit energy costs used in the life-cycle cost 

analysis.

Energy Use Characterization
Building Technologies Program 64 eere.energy.gov

Preliminary Analysis & Test Procedure

Energy Use Characterization

• Typically, DOE relies on the Residential Energy Consumption Survey (RECS) to 

estimate an appliance’s annual energy consumption. However, RECS has not 

attempted to obtain information on wine chillers.

• Instead, California’s maximum energy use standards can be combined with 

sales data from the NPD Group to estimate a range of annual energy use values 

for vapor-compression wine chillers. Two limitations of this approach are:

1. only the maximum possible energy use of each model in the NPD 

database can be defined, as opposed to its actual rated energy use, and

2. it is unknown as to whether the CEC test procedure provides a 

reasonable estimate of wine chiller annual energy use.

• Because of the apparent lack of energy use data, DOE may rely on in situ field 

measurements as a means to characterize wine chiller energy use.

Energy Use Characterization Issues
Building Technologies Program 65 eere.energy.gov

Preliminary Analysis & Test Procedure

Energy Use Characterization

Item 7-1 DOE seeks comments on the approach of estimating the 

annual energy consumption of wine chillers based on a combination 

of NPD sales data, CEC model data, and California’s energy 

conservation standards equations for establishing maximum energy 

use.

Item 7-2 DOE seeks input on potential data sources for establishing 

the annual energy consumption of wine chillers. 

Item 7-3 DOE seeks comments on the viability of using in situ field 

measurements of wine chiller energy use as a proposed basis for 

characterizing the product’s energy consumption.

Request for Comment
Building Technologies Program 66 eere.energy.gov

Preliminary Analysis & Test Procedure

Energy Use Characterization

Item 7-4 DOE seeks comments on whether annual energy use is best 

characterized with a sensitivity analysis to determine how high and 

low estimates of energy use might impact the economic feasibility of 

any amended energy conservation standards. 

Item 7-5 DOE seeks comments on the rebound effect associated with 

more efficient wine chillers. In other words, DOE seeks input on what 

portion of the energy savings resulting from more efficient 

equipment may be lost due to consumers purchasing larger or more 

feature laden equipment.

Request for Comment
Building Technologies Program 67 eere.energy.gov

Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 68 eere.energy.gov

Preliminary Analysis & Test Procedure

Life-Cycle Cost and Payback Period Analysis

• Assess the net LCC and PBP for different efficiency levels.

Analysis

• LCC equals consumer price plus the sum of annual operating costs discounted to 

a particular base year.

• Economic evaluation performed from the consumer perspective.

• Analysis is implemented in an Excel spreadsheet, using Monte Carlo probability 

approach to sample a full range of uncertain consumer variables.

• Results are expressed as the LCC difference (baseline minus standard level).

• Simple payback equals the incremental first cost divided by the operating cost 

savings for 1 year.

Consumer LifeCycle Cost

(baseline and standard)

LCC Impacts

(difference between

Operating Cost baseline and standard)

(sum & discount to present 

value)

First Cost

(consumer price & 

installation)

Purpose of Life-Cycle Cost (LCC) and Payback Period (PBP) Analysis
Building Technologies Program 69 eere.energy.gov

Preliminary Analysis & Test Procedure

Life-Cycle Cost and Payback Period Analysis

• DOE analyzes the consumer impact of any new standards by dividing 

consumers into subgroups and accounting for variations in key inputs to the 

LCC analysis. 

• A consumer subgroup comprises a subset of the population that is likely, for 

one reason or another, to be affected disproportionately by new or revised 

energy conservation standards.

– In comparing potential impacts on the different consumer subgroups, DOE 

will evaluate variations in regional electricity prices, variations in energy 

use profiles, and variations in purchase prices that might affect the LCC of 

an energy conservation standard to certain consumer subgroups.

Item 11-1 DOE requests input as to what, if any, consumer 

subgroups are appropriate when considering standards for wine 

chillers.

Life-cycle Cost Subgroup Analysis
Building Technologies Program 70 eere.energy.gov

Preliminary Analysis & Test Procedure

Life-Cycle Cost and Payback Period Analysis

LCC Flowchart

Baseline

Manufacturer

Price

Std-Level

Manufacturer

Price

Installation

Cost

From 

Engineering 

Analysis

(Price is a 

Function of 

Efficiency)

From Markups 

for Equipment 

Price 

Determination 

Analysis

Repair Cost

Maintenance

Cost

Lifetime

Discount Rate

Electricity

Price Trend

From Energy Use 

Characterization 

Analysis 

Energy and 

Water 

Consumption

Power and 

Water Demand

Distributor

Markup

Sales Tax

Mechanical

Contractor

Markup

Consumer

Price

Data Inputs

Intermediate Analysis

Output Results

Total Installed

Cost

Annual Energy

Expense

Annual

Operating

Expense

Lifetime

Operating

Expense

Payback

Period

Life-Cycle

Cost

Electricity and 

Water Prices
Building Technologies Program 71 eere.energy.gov

Preliminary Analysis & Test Procedure

Life-Cycle Cost and Payback Period Analysis

• DOE bases repair costs on annualized costs of key components and frequency 

of replacement in the field.

• Typically, small incremental changes in product efficiency incur little or no 

changes in repair and maintenance costs over baseline products. There is a 

greater probability that equipment with efficiencies that are significantly 

higher than the baseline will incur increased repair and maintenance costs, 

since such equipment is more likely to incorporate technologies that are not 

widely available.

• Unless the efficiency increases considered for this rulemaking result in

significantly larger or heavier products, DOE expects that more-efficient wine 

chillers and miscellaneous refrigeration equipment will not incur increased 

installation costs. 

Installation, Maintenance, and Repair Costs
Building Technologies Program 72 eere.energy.gov

Preliminary Analysis & Test Procedure

Life-Cycle Cost and Payback Period Analysis

Item 8-1 DOE seeks stakeholder input on the proposed approach of using 

probability distributions and Monte Carlo simulation to conduct the LCC and PBP 

analysis. 

Item 8-2 DOE requests data from stakeholders to characterize the current mix of 

wine chiller efficiencies in the market.

Item 8-3 DOE seeks stakeholder input on the planned approach for estimating 

current and forecasted energy prices.

Item 8-4 DOE seeks stakeholder input on whether it is correct to assume that 

changes in maintenance, repair, and installation costs will be negligible for moreefficient residential wine chillers. If it is incorrect, DOE is interested in the reasons 

why this is so and in specific ways in which to correct this assumption.

Item 8-6 DOE seeks stakeholder input on the planned approach for estimating 

discount rates for residential consumers.

Request for Comment
Building Technologies Program 73 eere.energy.gov

Preliminary Analysis & Test Procedure

Life-Cycle Cost and Payback Period Analysis

• DOE will use information from available literature sources as well as input from 

manufacturers and other stakeholders to establish specific wine chiller 

lifetimes or whether the product lifetimes for refrigerators, refrigeratorfreezers, and freezers are representative of wine chiller lifetime.

– For standard-sized refrigerator-freezers and freezers, DOE has 

characterized survival functions with Weibull distributions that have mean 

lifetimes of 17.4 and 22.3 years, respectively. 

– For compact refrigerators and freezers, DOE has developed survival 

functions that have mean lifetimes of 5.6 and 7.5 years, respectively.

Item 8-5 DOE seeks stakeholder input on appropriate product 

lifetimes for wine chillers. Specifically, DOE seeks data sources for 

establishing product lifetimes and comments on whether standardsized and compact-sized refrigerator, refrigerator-freezer, and freezer 

lifetimes are representative of wine chillers.

Equipment Lifetimes
Building Technologies Program 74 eere.energy.gov

Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 75 eere.energy.gov

Preliminary Analysis & Test Procedure

Shipment Analysis

• Estimate changes in shipments due to potential new or amended energy 

efficiency standards.

Approach

• Data sources: AHAM, NPD Group

• Estimate base case forecast – what is the effect if the new or amended energy 

standards were not imposed?

• Estimate impact of standards – increase/decrease in shipments in each 

equipment class due to new/amended standards, if any.

Shipments Analysis
Building Technologies Program 76 eere.energy.gov

Preliminary Analysis & Test Procedure

Shipment Analysis

Item 9-1 DOE seeks historical shipments data from stakeholders. If 

such data are provided, DOE requests that market share data 

showing the percentage of product shipments for 

compressor/condenser-based and thermoelectric-based products be 

included.

Item 9-2 If stakeholders are unable to provide historical shipments 

data, DOE seeks comment on which data source is more 

representative of historical shipments -- the AHAM shipments data 

or the NPD Group sales data -- and why.

Request for Comment
Building Technologies Program 77 eere.energy.gov

Preliminary Analysis & Test Procedure

Shipment Analysis

Item 9-3 DOE seeks input on the types of potential scenarios it 

should use to forecast base-case shipments and the reason(s) for the 

suggested scenario(s)

Item 9-4 As part of its preliminary manufacturer impact analysis, 

DOE seeks input from manufacturers on the potential impact of new 

energy conservation standards on wine chiller shipments. DOE also 

seeks input from other stakeholders on the potential impact of 

standards on product shipments.

Item 9-5 DOE also requests input on any market-pull programs that 

currently exist to promote the adoption of more-efficient wine 

chillers.

Request for Comment
Building Technologies Program 78 eere.energy.gov

Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 79 eere.energy.gov

Preliminary Analysis & Test Procedure

National Impact Analysis

• Estimate national energy savings (NES) and national net present value (NPV) of 

consumer savings for higher-efficiency standard levels.

Analysis

• DOE intends to take into account the rebound effect associated with more 

efficient wine chillers. 

• Excel spreadsheets will be used for calculation of NES and NPV of consumer 

savings.

Purpose of National Impact Analysis (NIA) 
Building Technologies Program 80 eere.energy.gov

Preliminary Analysis & Test Procedure

National Impact Analysis

• For past rulemakings, DOE relied on input from stakeholders to develop basecase historical shipment-weighted average efficiencies (SWEF). Although DOE 

hopes that AHAM and manufacturers will provide similar historical SWEF data 

for wine chillers, because of the apparent lack of information for this product, it 

is likely that DOE will need to rely on other sources to develop such data.

• NPV of consumer savings will be calculated, as per OMB guidance, with two 

different discount rates: 3% and 7%.

Item 10-1 DOE seeks historical SWEF data for wine chillers. DOE also seeks 

historical market share data showing the percentage of product shipments by 

efficiency level.

Item 10-2 DOE seeks input on its plan to develop Excel spreadsheet models for 

estimating national impacts of amended energy conservation standards for wine 

chillers. For example, are spreadsheet models still the preferred approach for 

estimating national impacts?

National Impact Analysis (cont.)
Building Technologies Program 81 eere.energy.gov

Preliminary Analysis & Test Procedure

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Equipment Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework

Document

 

Preliminary 

Analysis NOPR 

Final

Rule

Preliminary 

Manufacturer 

Impact Analysis
Building Technologies Program 82 eere.energy.gov

Preliminary Analysis & Test Procedure

Preliminary Manufacturer Impact Analysis

• The Preliminary MIA is conducted during the preliminary analysis and provides 

an assessment of the potential impacts of standards on manufacturers of wine 

chillers and miscellaneous refrigeration products. 

• During the preliminary analysis, DOE interviews manufacturers, soliciting 

information on the possible impacts of standards on manufacturing costs, 

equipment prices, sales, direct employment, capital assets, and industry 

competitiveness.

• During the preliminary analysis, DOE also prepares a Government Regulatory 

Impact Model (GRIM). The GRIM analysis uses a number of inputs to 

determine a series of industry annual cash flows beginning from the 

announcement of the new standard and continuing for several years after its 

implementation. 

• Later, during the NOPR phase, DOE completes the MIA, conducting a follow-up 

interview with manufacturers and assessing the financial impact of new 

standards using the GRIM. 

Preliminary Manufacturer Impact Analysis (MIA)
Building Technologies Program 83 eere.energy.gov

Preliminary Analysis & Test Procedure

Preliminary Manufacturer Impact Analysis

• DOE recognizes that smaller manufacturers, niche players, and manufacturers 

exhibiting a cost structure that differs significantly from the industry average 

may be affected differently by the imposition of standards.

– DOE uses the results of the market and technology assessment to group 

manufacturers into subgroups, as appropriate.

– The detailed manufacturer subgroup impact analysis entails calculating 

cash flows separately for each defined class of manufacturer. 

Manufacturer Subgroups

Item 12-1 DOE seeks comment on appropriate manufacturer 

subgroups, if any, for residential wine chillers and miscellaneous 

refrigeration products that DOE should consider in a manufacturer 

subgroup analysis.
Building Technologies Program 84 eere.energy.gov

Preliminary Analysis & Test Procedure

Preliminary Manufacturer Impact Analysis

• DOE is aware that other regulations may apply to equipment covered under 

this rulemaking.

• Multiple regulations may result in a significant, cumulative regulatory burden 

on these manufacturers. 

• Regulations that could affect the industries affected by this rulemaking include:

– DOE standards for residential refrigeration products 

– Phaseout of HCFC blowing agents in 2003

– Reduction of Hazardous Substances directive 

– Legislation limiting emissions of Greenhouse Gases 

Cumulative Regulatory Burden

Item 12-2 What other regulations or pending regulations should DOE 

consider in its examination of cumulative regulatory burden?
Building Technologies Program 85 eere.energy.gov

Preliminary Analysis & Test Procedure

Notice of Proposed Rulemaking (NOPR) Analyses

Closing Remarks, Contacts & Information

Public Meeting Slides Topics

5

6

7

2 Regulatory History

4 Rulemaking Overview & Framework

1 Introduction

3 Scope
Building Technologies Program 86 eere.energy.gov

NOPR Analyses

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Environmental 

Assessment

Regulatory

 Impact 

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

 Impact

Analysis

Revise 

Preliminary 

Analysis

Engineering

Analysis

Framework

Document

 

Preliminary 

Analysis

 

NOPR Final

Rule

NOPR Phase
Building Technologies Program 87 eere.energy.gov

NOPR Analyses

Item 13-1 DOE seeks input from stakeholders on its plans to use the 

Building Technologies National Energy Modeling System (NEMS-BT) 

to conduct the utility impact analysis. Examples of the type of input 

sought by DOE include, but are not limited to, whether the NEMS-BT 

model is appropriate for assessing the utility impacts of efficiency 

standards — and if not, what would be a more appropriate model to 

use?

Item 14-1 DOE welcomes feedback on its planned approach for 

assessing national employment impacts, both direct and indirect, 

and it is interested in whether other tools or factors should be 

considered as part of its analysis. If other tools or factors should be 

considered, please identify them and explain why, and how, they 

should be integrated into DOE's analysis.

Item 15-1 DOE seeks input on its plans to use NEMS-BT to conduct 

the environmental assessment for the products covered by this 

potential rulemaking.

Request for Comment
Building Technologies Program 88 eere.energy.gov

Preliminary Analysis & Test Procedure

Notice of Proposed Rulemaking (NOPR) Analyses

Closing Remarks, Contacts & Information

Public Meeting Slides Topics

5

6

7

2 Regulatory History

4 Rulemaking Overview & Framework

1 Introduction

3 Scope
Building Technologies Program 89 eere.energy.gov

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

– Wine Chiller and Miscellaneous Residential Refrigeration Products Rulemaking

– Docket Number EERE-2011-BT-STD-0043 

– Regulatory Identification Number (RIN) 1904-AC51

Email: WineChillers-2011-STD-0043@ee.doe.gov

Comment period ends: March 14, 2012

Closing Remarks, Contacts & Information 

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

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

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 6th Floor

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202-586-2945

Wine Chiller and Miscellaneous Residential Refrigeration Products 

Comment Submittal Information
Building Technologies Program 90 eere.energy.gov

• DOE Appliance Standards

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

• Wine Chiller and Miscellaneous Refrigeration Products Rulemaking

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

freezers.html

• Contact Lucas Adin, Project Manager, from the Appliance Standards Program for additional 

information: 

– Lucas.Adin@ee.doe.gov

– 202. 287.1317

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

information: 

– John.Cymbalsky@ee.doe.gov

– 202.287.1692

Closing Remarks, Contacts & Information

Wine Chiller and Miscellaneous Residential Refrigeration Products 

WebPages and DOE Contacts